CHINA CHEMICAL MIXTURE COMPLIANCE
A chemical mixture supplied to China may require hazard identification, hazardous chemical registration, and Chinese safety data sheets (SDS) and labels—even when its commercial name does not appear in the Catalogue of Hazardous Chemicals. The assessment needs to consider the formulation, its hazardous properties and the activities undertaken by the Chinese manufacturer or importer. A catalogue search or a concentration check alone cannot resolve every mixture's obligations.
At CRAC China 2026, Chen Jinhe of the Chemical Registration Center under China's Ministry of Emergency Management highlighted a practical compliance gap: chemical auxiliaries were being stored as ordinary chemical products without prior hazard identification. His presentation and subsequent audience discussion connected classification evidence, registration and SDS with questions about local repackaging, storage and customs declarations.
Drawing on Chen's presentation, the onsite Q&A and official requirements, this article explains how overseas suppliers and their Chinese partners can connect these tasks before importing or handling a formulated product. The preparation checks are REACH24H's practical recommendations based on those sources.
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Start with the Mixture's Hazards and Intended Activities
Chen's inspection examples included auxiliaries such as initiators, foaming agents and water treatment agents. Their commercial descriptions explain what they do, but provide an incomplete basis for deciding how they should be managed.
For a supplier, this creates an information task before shipment: can the Chinese importer identify the formulation, understand its hazards and support the proposed storage and handling arrangements?
China's Hazardous Chemicals Safety Law has applied since May 1, 2026. In his presentation, Chen highlighted Article 124, which prohibits unauthorized production, storage, use, trading or transport of chemicals whose hazardous properties remain undetermined. The practical implication is to resolve uncertainty early, while there is still time to obtain composition information, review existing evidence and arrange any required identification work.
For the wider legal framework, see REACH24H's overview of China's Hazardous Chemicals Safety Law.
Does the 70% Rule Exempt a Mixture from Regulation?
A mixture below 70% does not automatically fall outside hazardous chemical registration.
Sections 5 and 6 of the Catalogue's Implementation Guide address different situations:
| Mixture situation | Regulatory significance |
|---|---|
| Its main components are all Catalogue-listed hazardous chemicals, together accounting for at least 70% by mass or volume. | It may be regarded as a hazardous chemical and managed accordingly. |
| Its main components are all Catalogue-listed hazardous chemicals, together accounting for less than 70%, or its hazardous properties remain undetermined. | Manufacturers or importers must follow the applicable identification and classification requirements. If the chemical meets the hazardous chemical determination criteria, registration is required. |
Section 6 distinguishes registration from the relevant safety administrative licensing requirements for the circumstances it describes. Registration and licensing therefore require separate conclusions. Direct coverage by a Catalogue entry must also be assessed; the percentage calculation is not a substitute for that review.
The onsite discussion also addressed Catalogue entry 2828. An official Ministry response confirms that this entry applies only to mixtures. Businesses should check the effective entry and its conditions; discussion of possible future changes does not establish an exemption.
A useful screening record should explain which entry or rule was assessed, the composition used and the evidence supporting the conclusion. This gives the importer a basis for proceeding beyond a simple "listed/not listed" result.
When Is Physical Hazard Identification Required?
Under SAWS Order No. 60 on physical hazard identification and classification, relevant triggers include:
A chemical containing one or more Catalogue-listed components whose overall physical hazards remain undetermined.
A chemical outside the Catalogue whose physical hazards remain undetermined.
A chemical used for scientific research or product development, with annual production or use exceeding one tonne, whose physical hazards remain undetermined.
Where this procedure applies, the manufacturer or importer applies to an identification institution. The process distinguishes the physical hazard identification report from the classification report prepared using the identification results and other relevant data. The classification report is submitted to the registration center for review.
Can Overseas Data Support the Assessment?
During the Q&A, participants asked whether existing data could support health and environmental hazard classification and whether further identification was necessary. Chen emphasized the validity of the data and the ability to explain the classification, including the source and applicability of evidence obtained in China or overseas and the basis for any calculations.
For overseas suppliers, the useful starting point is a review of the evidence already available. REACH24H recommends documenting:
Whether the data describe an ingredient, a similar formulation or the mixture actually supplied.
How the tested sample compares with the commercial product's composition, concentration ranges and physical form.
Which classification criteria, data and calculation methods support the conclusion.
How the conclusion is reflected in the classification report, Chinese SDS, label and registration information.
An overseas SDS or test report does not automatically replace a statutory physical hazard identification procedure. Data relevance and the applicability of Order No. 60 should be assessed separately. This review helps identify which conclusions are already supported and where additional evidence or identification work is needed.
Who Registers an Imported Hazardous Mixture?
Article 86 of the Hazardous Chemicals Safety Law places hazardous chemical registration obligations on manufacturers and importers. Under SAWS Order No. 53 on hazardous chemical registration, importers must complete registration before the first import.
An overseas supplier should therefore establish which Chinese entity will import the product and what information that entity needs. The supplier's regulatory team can support the process by providing reliable formulation and hazard information, while keeping responsibilities and information-sharing arrangements clear.
Registration information covers classification and labeling, physicochemical properties, uses, hazards, safe storage, use and transport conditions, and emergency measures. Supporting documents include an SDS and label matching the product and meeting national standards.
For mixtures, consistency is a practical priority. The product name, formulation reference and hazard conclusions should be traceable across the supplier's records, identification reports, registration information and Chinese SDS.
REACH24H's China hazardous chemical registration services support Catalogue screening, hazard identification and registration preparation with Chinese importers.
Does Repackaging in China Create Additional Requirements?
The onsite Q&A raised the example of imported bulk liquids repackaged in China. This matters for suppliers whose Chinese partners receive a formulation in bulk and sell it in smaller containers.
Article 37 of the Measures for the Administration of Hazardous Chemicals Operation Permits brings the purchase of hazardous chemicals for repackaging, refilling, or dilution with a non-hazardous solvent followed by sale within those Measures.
Before agreeing on a local operating model, document whether the partner will only change packaging, dilute or formulate the product, conduct other processing, or store bulk and finished goods. The intended activity and site conditions inform the permit assessment. A registration certificate alone does not establish that repackaging, trading or storage activities meet all applicable requirements.
For further information, see REACH24H's China hazardous chemicals operation permit guidance. A revision draft published on September 21, 2026 was issued for public comment; proposed changes should be distinguished from effective requirements.
Small Shipments Need a Defined Exemption Basis
Chen also highlighted Article 87, which provides for registration exemptions for certain hazardous chemicals involving low quantities, low releases and low exposure during research and development or trial production and sales, with detailed measures to be established.
A small shipment or a "sample" description alone does not establish eligibility. Companies considering this provision should identify the applicable conditions and retain evidence supporting their exemption assessment.
Chinese SDS and Labels Must Reflect the Actual Mixture
Article 31 of the Hazardous Chemicals Safety Law requires manufacturers and importers to provide Chinese SDS and Chinese safety labels matching their hazardous chemicals and complying with national standards.
An overseas SDS is a useful starting point. Preparing it for China requires a review of the applicable classification, product information and local requirements alongside the translation.
For mixtures, REACH24H recommends the following consistency checks:
| Information to review | Practical question |
|---|---|
| Product identity | Can the product code and name be traced across the SDS, label, registration records and supplied formulation? |
| Composition | Does the information available to the assessor support the mixture classification, including relevant concentration ranges? |
| Hazard conclusions | Do the SDS and label reflect the applicable Chinese classification and the available identification evidence? |
| Handling and storage | Do the instructions address the formulation's actual hazards, incompatible materials and intended conditions of use? |
| Supplier and emergency information | Are the contacts and emergency arrangements appropriate for the Chinese supply chain? |
| Version control | Can the importer and downstream users identify the current documents and the changes that prompted their issue? |
These checks help turn separate documents into a coherent set of product information. REACH24H's China GHS, SDS and label services support the preparation and review of those documents.
What If Customs Questions the Mixture's Catalogue Status?
In the Q&A, a participant described a difference in interpretation over a mixture's Catalogue status and a request to state in its SDS that the product was outside the Catalogue. For suppliers and importers, the underlying task is to establish a defensible classification and Catalogue assessment before changing a document.
GACC Announcement No. 129 of 2020 sets inspection and documentation requirements for imported and exported hazardous chemicals listed in the Catalogue. Announcement No. 29 of 2023 requires import consignees or their agents to accurately declare relevant product and hazard information and upload the required materials for each declared goods item.
REACH24H recommends preparing a product-specific explanation covering the Catalogue entries reviewed, composition and concentration evidence, and relevant classification or identification records. The explanation should connect those records to the goods actually imported.
Any statement about Catalogue status in an SDS should follow from that assessment. Coordinate revisions with the Chinese importer so that the SDS, label and customs information remain consistent; an unsupported wording change may create further discrepancies.
Carry Hazard Information Through to Storage and Use
Chen's discussion of inspections extended beyond document preparation. It connected hazardous chemical inventories, SDS and labels, storage incompatibility and employee training.
He highlighted two requirements that make this connection explicit:
At sale: Article 57 requires manufacturers and traders to provide compliant SDS to purchasers and prohibits trading hazardous chemicals without SDS or safety labels.
At the workplace: Article 51 requires users to make SDS and labels available to employees and provide information and training on safe use and emergency measures.
For an overseas supplier, this makes the handover to the Chinese importer and customer part of product stewardship. The people receiving, storing and using the mixture need access to information they can apply.
Small Packages Do Not Resolve Warehouse Requirements
Questions about perfumes, aerosols and other small packaged products highlighted a separate issue: a transport exemption does not, by itself, establish a storage exemption. Chen noted the need to consider transport arrangements separately from warehouse management, including the risks created by the quantity accumulated at a site.
Articles 41 and 42 of the Hazardous Chemicals Safety Law address dedicated storage locations, storage arrangements and quantities, and checks and records for goods entering and leaving storage. Suppliers and their Chinese partners should therefore review hazard classification, individual package sizes, maximum inventory, storage layout and incompatible materials. Assessing only the size of each bottle or can leaves the warehouse's total inventory and storage compatibility unresolved.
A formulation change should also prompt a review of the affected evidence and documents. Where registration information changes, the law requires timely amendments; newly identified hazardous properties also trigger hazard communication updates.
Prepare Your Chemical Mixture for the Chinese Market with REACH24H
For overseas formulators and their Chinese partners, the starting point is a product-specific assessment: what is the mixture, what evidence establishes its hazards, and which obligations follow from its classification and supply arrangements?
REACH24H supports this work through:
Catalogue screening and hazard identification assistance.
Coordination with qualified institutions for physical hazard identification where required.
Hazardous chemical registration support for Chinese importers.
Preparation and updating of China-compliant SDS and labels.
Providing your current SDS, available composition and hazard data, intended Chinese importer and planned business activities helps define the scope of the review. Include any local repackaging, dilution, trading or storage arrangements so that the assessment reflects how the product will reach customers.
This preparation helps connect technical evidence with registration work, import documentation and the information customers need to handle the product.
Prepare Your Chemical Mixture for the Chinese Market
Discuss your chemical mixture's China compliance requirements with REACH24H.
