China’ s hazardous chemicals reset
Adam Hembrecht of CIRS Group examines how China’ s 2026 hazardous chemicals law could reshape compliance expectations for speciality chemicals supply chains
Figure 1- Scenario of foreign companies importing hazardous chemicals into China
China’ s Hazardous Chemicals Safety Law, adopted on 27 December 2025 and effective from 1 May 2026, establishes the highest-level legal framework for hazardous chemicals safety management in China( a Supreme Law). That status matters in itself. It signals a more formal and integrated legal basis for hazardous chemicals management in China and raises the stakes for companies that have previously treated compliance as a narrow labelling or documentation exercise.
This new law covers the entire lifecycle of hazardous chemicals, including production, storage, use, distribution and transportation. That is important, because regulatory responsibility can now extend across activities that many multinational firms previously treated as operationally separate.
For fine and speciality chemicals companies, the immediate question is not only what the law says but also where it changes practical exposure. Many such businesses operate through fragmented value chains, where manufacturing, import, storage, formulation, sale and end-use may sit with different legal entities or third parties. A lifecycle law can therefore create consequences well beyond the registrant or the importer.
Regulatory duties are no longer easily confined to one department. Product stewardship, regulatory affairs, supply chain, warehousing, sales support and local management may all need to be involved earlier and in a more coordinated way.
Broader scope than expected
One of the most consequential features of the new regime is how a hazardous chemical is determined. The law introduces three routes through which a substance may fall in scope: 1. It is listed in the Catalogue of
Hazardous Chemicals 2. It has been identified as having hazardous characteristics, or
3. It meets the criteria for hazardous chemicals across a broad range of hazard categories
This matters because many portfolio reviews begin and end with the Catalogue. That approach is now too limited. A company may conclude that a product is commercially specialised, low-volume or not commonly perceived as‘ high hazard’ yet still find that the product triggers obligations because of the underlying criteria.
For example, a low-volume electronic chemical or pharmaceutical intermediate that is not explicitly listed in the Catalogue may still fall within scope if its hazard profile meets the relevant determination criteria. For businesses selling differentiated intermediates, additives, electronic chemicals, custom synthesis outputs or application-specific blends, this creates a more searching classification exercise.
In practical terms, companies should revisit the boundary between products they regard as general industrial chemicals and those they treat as speciality materials. That commercial distinction may be irrelevant if the hazard determination places the material within scope. The implication is simple: product portfolios should be screened against the Chinese framework itself, not only against internal commercial categories or non-Chinese classifications.
44 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981