China released the revised version of The Measures for the Administration of Registration of Hazardous Chemicals

On 11 Oct 2011, the State Administration of Work Safety (SAWS) of China released two laws regarding hazardous chemicals for public consultation. The deadline for comments is 18 Nov 2011.

Both laws are sub-measures of the Regulations on Safe Management of Hazardous Chemicals in China released earlier in March this year.

One of them is the revised version of the Measures for the Administration of Registration of Hazardous Chemicals. The revised version will replace the old version issued in 2002.

The other one is called the Measures for The Administration of Safe Use Permit for Hazardous Chemicals, which is a new regulation and will also come into force on 1 Dec 2011.

Measures for the Administration of Registration of Hazardous Chemicals

These Measures stipulate the detailed requirements and procedures regarding the registration of hazardous chemicals in China. The key principle is that manufacturers and importers shall register chemicals listed in the Catalog of Hazardous Chemicals with the National Registration Center of Chemicals (NRCC) of SAWS prior to manufacture or importation for the first time. The validity of registration certificate is 3 years and has to be renewed 3 months prior to the certificates expiry date.

Please note: Manufacturers of hazardous chemicals shall also submit a registration to environment protection authorities. Click here for more info.

Unlike new chemical registration which requires expensive toxicology data, eco-toxicology data and risk assessment, this registration only requires the following information:

  • legal entity information
  • classification and labeling
  • physiochemical properties
  • main uses
  • hazard classes
  • conditions for safe storage, use and transport
  • emergency responses.


Compared to the 2002 version, the Measures include the following major changes:

  • The scope is more clearly defined. Only chemicals listed in the Catalogue of Hazardous Chemicals need to be registered;
  • In the old version, manufacturers and companies who store hazardous chemicals based in China are required to register. In the new version, manufacturers and importers ("registrant") are required to register. Foreign manufacturers do not need to register;
  • Manufacturers shall register hazardous chemicals before a new chemical plant passes inspection and is ready for production;
  • Importers shall register hazardous chemicals after sales contract has been signed and before the hazardous chemicals are imported into China for the first time;
  • If an importer imports the same hazardous chemical from different manufacturers, the importer shall provide information about each manufacturer;
  • Registrants are required to report information regarding actual production or importation of hazardous chemicals of last year to local registration office before 10 Jan of each calendar year;
  • Record-keeping obligations are strengthened. The registrant shall build a file for registered hazardous chemicals. The file shall include product name, quantity, product identifier, hazard identification, safety data sheet and chemical safety label. In addition, the manufacturer shall keep information regarding production capacity. Importer shall keep information regarding manufacturers and the volume of import;
  • Registrants shall provide safety data sheet and chemical safety label compliant with national standards;
  • Registrants shall appoint a qualified person to register hazardous chemicals and this person must have received training from NRCC or local registration office and acquired relevant qualifications;
  • Detailed enforcement and supervision measures have been added.


Note 1:

Manufacturers and companies who use hazardous chemicals to manufacture products shall submit an environmental administration registration to local environmental protection authorities and obtain a registration certificate too. Click here for more information.

Measures for the Administration of Safe Use Permit for Hazardous Chemicals

Theres measures require companies who use hazardous chemicals to manufacture products (excluding manufacturers of hazardous chemicals) to obtain a safe use permit from the administrative department of work safety at city level when:

  • The industry sector of the company is listed in the Catalog of Applicable Industry Sector for the Safe Use Permit of Hazardous Chemicals (for example, production of fertilizer); and
  • The used quantity has reached the threshold volume stipulated by the standard usage quantity of hazardous chemicals (for example, for chlorine, the threshold value is 180t/y). So far, the threshold value has been set for 62 hazardous chemicals.


The requirements for application of safe use permit are listed below:

  • application form for safe use permit;
  • safety management system and safety operation procedure;
  • full-time EHS staff(>=2% of total number of employees);
  • qualifications of safety responsible person and EHS staff;
  • emergency response plan in case of accident;
  • safety data sheet;
  • copy of business license;
  • safety evaluation report by third party;
  • copy of evaluation report of a new chemical plant;
  • list of emergency response personnel, equipments and facilities.


The validity of safe use permit is also 3 years.




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