The Law of the People's Republic of China on the Safety of Hazardous Chemicals officially entered into force on 1 May 2026, establishing a strengthened regulatory framework for hazardous chemical management with mandatory registration, inter-ministerial data sharing, and enhanced enforcement measures. According to the "Regulations on the Registration and Management of Hazardous Chemicals" and the "Hazardous Chemicals Catalogue User Manual", all hazardous chemicals listed in the Catalogue, as well as chemicals not listed in the Catalogue but meeting the determination principles, must be registered in accordance with the law. Foreign manufacturers, importers, exporters, and distributors supplying the Chinese market must achieve full registration compliance to prevent goods detention, customs clearance disruptions, and substantial administrative penalties.
This guide will break down the core requirements and high-frequency pitfalls of hazardous chemicals registration, helping enterprises in industries like chemicals, pharmaceuticals, and electronic materials achieve compliance and avoid penalties.
Core Review Points for Hazardous Chemicals Registration
1. Basic Enterprise Information: Ensure Accuracy and Consistency
Licenses and Certificates: All qualifications must be valid and compliant. Business licenses, production/operating permits, and other certificates should match actual operations.
Emergency Contact: Maintain a 24-hour emergency contact number and assign a dedicated contact person.
Enterprise Type Matching: The validity period of the hazardous chemicals registration certificate is three years. Ensure the enterprise type (e.g., production, import, operation) aligns with the business scope and registration details.
2. Hazardous Chemicals Information: Complete and Error-Free
Comprehensive Scope: Register all products, intermediates, raw materials, and imported hazardous chemicals. No omissions are allowed.
Classification and Identification: Follow national standards for hazard identification and classification. Ensure consistency with the Catalogue of Hazardous Chemicals.
Accurate Parameters: Key details like chemical name, CAS number, and hazard characteristics must align with the Safety Data Sheet (SDS) and safety labels.
3. "One SDS, One Label": Standardized Documentation
SDS Requirements: Provide a complete Chinese version with all 16 sections. Ensure all data matches the registration system.
Safety Labels: Include chemical identification, hazard statements, and emergency contact details. These must align with the SDS.
4. Registration Certificate and Records: Maintain Compliance
Certificate Validity: Ensure the registration certificate is valid and updated for any changes in enterprise details or hazardous chemical varieties.
Recordkeeping: Maintain a comprehensive archive of compliance documents, including SDS, labels, and inspection records.
Renewal Applications: Submit renewal requests three months before certificate expiration to avoid disruptions.
High-Frequency Pitfalls to Avoid
Prohibition of Falsification: All materials, including system-reported information, identification reports, and enterprise qualifications, must be authentic and valid. Falsification or tampering with materials will result in severe administrative penalties.
Consistency Across All Information: Data in the registration system, SDS, safety labels, and actual enterprise production and operation information must be fully consistent. Conflicting or contradictory information is a common reason for registration rejection or inspection failure.
Timely Change Reporting: Changes in enterprise name, address, hazardous chemical varieties/specifications, processes, etc., must be reported within 15 days to avoid overdue violations.
Ensure Comprehensive Registration: Intermediate products, by-products, and small quantities of imported hazardous chemicals must all be registered. There are no "exemptions," and comprehensive inspections must leave no blind spots.
Standardized Registration Process: Follow the process of "Enterprise Application - Preliminary Review by Provincial Registration Office - Re-Examination by Chemical Registration Center - Certificate Issuance." If rejected, rectify according to feedback and avoid resubmitting invalid materials.
REACH24H Recommendations for Enterprises
Hazardous chemicals registration is essential for safe production and legal operations. With the new law's implementation, enterprises must:
Conduct thorough self-inspections and rectify any gaps.
Stay updated on regulatory changes.
Strengthen compliance management to ensure sustainable operations.
For further guidance, explore our related resources or contact us directly.
Not sure where to start? REACH24H's regulatory experts are ready to help you navigate China hazardous chemicals registration compliance.
Email: customer@reach24h.com
