REGULATION & COMPLIANCE
in pharmaceuticals, agrochemicals, coatings, electronics and personal care increasingly expect suppliers to be able to explain local compliance status clearly and quickly. Poorly aligned Chinese SDSs, outdated labels or uncertainty over product status can weaken customer confidence long before any formal enforcement action occurs.
Digital traceability
China has also been rolling out a digital QR code-based approach to labelling referred to as the‘ one enterprise, one product, one code’, which requires stakeholders to establish a system to record the inventory of every product containing hazardous chemicals. Under these systems, products or batches may be assigned a QR code linked to inventory and traceability records for hazardous chemicals.
Multiple local authorities, including Shanghai, Beijing, Shandong and Guangdong, have already implemented this system. Even if implementation remains local or uneven, the policy direction is clear enough. Hazard communication is moving beyond static paper documentation towards more accessible, productlinked traceability.
For many companies, the challenge here will be data governance rather than the label itself. If a productlevel code must connect reliably to compliant product information, then internal systems for version control, Chinese-language documentation, distributor handover and regional variation all become more important. In a speciality chemicals portfolio with many grades, package sizes or customer-specific variants, this can become a substantial operational issue.
Businesses should therefore resist the temptation to see QR codes as a superficial packaging matter. They may instead represent another step towards tighter digital oversight of hazardous chemicals through the supply chain. Companies that already struggle with product master data, document control or local versioning may find that traceability requirements expose those weaknesses quickly.
R & D materials
Low-volume, low-release and lowexposure substances used for R & D, trial production, and trial sales may qualify for a registration exemption. However, we are still waiting for specific measures to be formulated by the MEM in conjunction with several other authorities.
While this is potentially important for innovation-led firms, it should be treated cautiously. An exemption pathway can be commercially helpful for early-stage materials, pilot work and customer sampling, especially in sectors where new molecules or functional formulations move through iterative development. Yet until the detailed measures are known, companies should avoid assuming that all R & D-related uses will fall outside routine obligations.
The more prudent approach is to identify where the business depends on trial-stage materials entering or moving within China, then monitor closely for the implementing rules. The issue is not simply whether an exemption exists but whether the company can document that the material, volume and use pattern genuinely to meet the conditions attached to it.
What to do now
Companies should reassess their portfolios against the Chinese hazardous chemical determination routes, not just against the catalogue. They should identify which products may trigger registration and which may entail both registration and licensing. They should review Chinese SDS and label readiness against the national standards rather than treating localisation as a final formatting step.
Businesses should also examine whether their operational model can support stronger traceability, including region-specific QR-code
expectations where relevant. Finally, they should map responsibilities across regulatory affairs, supply chain, warehousing, sales and local management so that the lifecycle scope of the law is reflected in internal governance.
For fine and speciality chemicals companies, the significance of the 2026 law lies less in any single obligation than in the way it joins classification, documentation, licensing and traceability into a more coherent legal framework. The firms most at risk may not be those with the most obviously hazardous products, but those whose regulatory data, local execution and commercial decisionmaking are poorly connected.
In that sense, China’ s new Hazardous Chemicals Safety Law is not simply a regulatory development. It is a test of whether a company’ s operating model is robust enough to support continued access to a strategically important market under a regulatory environment that increasingly expects traceability, localisation, and lifecycle accountability as a standard. ●
Adam Hembrecht
REGULATORY AFFAIRS CONSULTANT
CIRS GROUP k + 353 1 477 3706 J adam. hembrecht @ cirs-reach. com j www. cirs-group. com
46 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981