Introduction to China’s 2026 Chemical Licence Catalogue
In 2026, China rolled out an updated Chemical Licence Catalogue that redefines the import and export controls on hazardous chemicals. The new framework aims to tighten regulation, improve safety, and align China’s chemical trade with global best practices. For chemical traders, understanding the catalogue’s categories, licence types, and compliance procedures is essential to avoid costly penalties and maintain market access.
What’s New in the 2026 Catalogue?
Revised Classification System
The catalogue now groups chemicals into six major categories, each with specific licence requirements:
Category A: High‑risk substances (e.g., cyanides, heavy metals) – mandatory import and export licences.
Category B: Controlled industrial chemicals – requires an import licence but no export licence unless used abroad.
Category C: Dual‑use chemicals – dual licensing for both import and export.
Category D: Non‑hazardous but regulated substances – simplified licence with fewer conditions.
Category E: Emerging chemicals – pilot licence program with government oversight.
Category F: Miscellaneous chemicals – no licence needed.
Updated Licence Types
There are now three primary licence types:
Import Licence (IL) – required for Category A, B, and C chemicals.
Export Licence (EL) – mandatory for Category A, C, and selected Category D chemicals.
Dual Use Licence (DUL) – combined IL and EL for Category C.
Enhanced Due Diligence
China now requires detailed risk assessments, supplier verification, and end‑use statements for all licensed chemicals. The criteria emphasize:
Origin of the chemical.
Intended end‑use and destination country.
Safety data sheets (SDS) and compliance certificates.
Compliance Checklist for Traders
Below is a step‑by‑step guide to ensure you meet the new catalogue requirements.
1. Identify the Chemical Category
Match your product against the catalogue’s six categories. Use the official online database or consult with a local regulatory expert.
2. Determine Licence Needs
Based on the category, decide whether you need an IL, EL, or DUL. Remember, Category A chemicals always require both licences.
3. Gather Documentation
Prepare the following:
Manufacturer’s SDS and product specifications.
Supplier invoices and certificates of origin.
Risk assessment report and end‑use declaration.
4. Submit the Licence Application
Use the China Customs Electronic Filing System (CES) to submit your licence application:
Register an account and verify company credentials.
Complete the online form, upload documents, and pay the licence fee.
Wait for the Customs review – processing times vary by category.
5. Maintain Records
Keep all licence documents, SDS, and shipment records for at least five years. China’s customs may audit your files at any time.
Impact on Export Controls
The 2026 catalogue strengthens chemical export controls by:
Expanding the list of dual‑use chemicals.
Introducing stricter end‑use verification.
Mandating real‑time shipment tracking for Category A and C.
Exporters must now provide a detailed end‑use statement for every shipment, confirming that the chemical will not be diverted for prohibited purposes.
Practical Tips for Navigating Hazardous Chemicals China Regulations
Use a Local Partner: Engage a licensed agent in China to handle paperwork and inspections.
Update Your SDS: Ensure SDS comply with Chinese safety standards and include local language translations.
Track Regulatory Changes: Subscribe to the China Import Licence bulletin and join industry forums.
Leverage Technology: Implement a digital compliance platform that auto‑generates licence applications and tracks status.
Conclusion
China’s 2026 Chemical Licence Catalogue represents a significant shift in how hazardous chemicals are regulated. By accurately classifying products, securing the correct licences, and maintaining robust documentation, chemical traders can stay compliant and continue to thrive in the Chinese market.
