China to Impose Stricter Control Over Identified Hazardous Chemicals

China recently proposed a set of measures for the safe management of 20 hazardous chemicals. These chemicals would be designated as hazardous chemicals subject to special control and therefore subject to additional regulatory requirements concerning the production, storage, use, transport, import and export thereof. Public consultation on the proposal is open until 18 November 2019.

Verisk 3E Review

The Ministry of Emergency Management of China published the Invite for Response to the Proposed Catalog of Hazardous Chemicals Subject to Special Control (First Edition) (关于向社会公开征求《特别管控危险化学品目录（第一版）（征求意见稿）》意见的通知) (the proposal) on 18 October 2019. The proposal, once adopted, would identify hazardous chemicals subject to special control (concerned chemicals), which are defined as hazardous chemicals that are inherently highly hazardous and are highly prone to causing major safety accidents. These chemicals are available in commerce in large quantities and require special control to ensure safety. Stricter administrative requirements, such as packaging and tracking requirements, would be imposed on these chemicals once the proposal is adopted.

Catalog of Hazardous Chemicals Subject to Special Control

This catalog consists of the following four categories of hazardous chemicals:

• Explosive chemicals
• Toxic chemicals
• Flammable gases
• Flammable liquids

A total of 20 hazardous chemicals, along with their CAS RNs, UN numbers and major hazardous characteristics would be provided under the proposal, once adopted.

Tightened administrative measures

In addition to identifying concerned chemicals, the proposal would outline the additional administrative measures and requirements for these chemicals. Major requirements to be introduced under the proposal include:

• Establishing an information-sharing system to track the flow of concerned chemicals. For instance, a tracking system would be launched to collect information on the production, storage, use, transport, import, and export of concerned chemicals in China. QR codes or electronic labels may be required for the product packaging and certain containers of concerned chemicals
• Issuing regulatory requirements for the product packaging of concerned chemicals, including packaging materials used and labeling requirements, for these chemicals
• Tightening market entry requirements for facilities and personnel involved in the handling of concerned chemicals. For instance, no production facilities of concerned chemicals would be permitted to be established in China, unless they are strictly in compliance with legislation concerning production safety.

A number of other requirements concerning the transport and storage of concerned chemicals would also be adopted under the proposal.

Verisk 3E Analysis          

Companies that handle chemicals, such as production, storage, use, import and export, should note that China recently proposed a Catalog of Hazardous Chemicals Subject to Special Control, which would entail stricter administrative requirements for identified chemicals, once adopted. Affected parties are recommended to review the proposal and submit any comments they might have to the Ministry of Emergency Management by 18 November 2019 via one of the following methods:

• Email: shixb@chinasafety.gov.cn
• Phone: +86 10-64463239