Buying hazardous chemicals from China: the documents to ask your supplier for

China applies two sets of rules

Chinese law asks two separate questions about a chemical product. A product can fall under one, both or neither.

• Is it a hazardous chemical? 危险化学品 This means it is listed in China’s Catalogue of Hazardous Chemicals. The answer decides whether the factory and the trader need licences, and whether China Customs inspects the goods before export.
• Is it dangerous goods for transport? 危险货物 This is decided under the IMDG Code for sea freight. The answer decides the packaging, the marks on each drum, and how the cargo is booked and declared.

Ask your supplier for both answers in writing. “It is not hazardous” is often true under one set of rules and false under the other. Lithium batteries, for example, are dangerous goods for transport but are not in the Catalogue.

Before you place the order: five things to ask for

1. Safety data sheet (SDS) in English. It should follow the GHS format with 16 sections. Section 14 gives the UN number, class and packing group.
2. Classification and identification report. 危险特性分类鉴别报告 A qualified testing body in China issues it, and it states the hazard class. The supplier needs it for the packaging appraisal and for the customs inspection, so a supplier who has exported this product before already has one.
3. Transport classification. UN number, proper shipping name, class and packing group (I, II or III, where I is the most dangerous). A solvent-based adhesive, for example, is UN1133, Class 3, packing group II or III. Shipping lines usually also ask for a cargo transport condition certificate 货物运输条件鉴定书.
4. Licences. The manufacturer needs a hazardous chemicals safety production licence 危险化学品安全生产许可证. A trading company needs a hazardous chemicals business licence 危险化学品经营许可证. China’s Hazardous Chemicals Safety Law, in force since 1 May 2026, requires a licence to trade in hazardous chemicals. A trader without one cannot legally buy and resell them inside China.
5. Any extra export control. Three groups need a separate export approval. Drug precursor chemicals such as acetone, toluene, methyl ethyl ketone, sulphuric acid and hydrochloric acid need a licence from the commerce authorities. Chemicals on China’s list of severely restricted toxic chemicals need an environmental release notice. Monitored and dual-use chemicals fall under the Export Control Law. If your product or one of its ingredients is in these groups, ask the supplier to confirm in writing whether an approval applies, before you agree a delivery date.

Before shipment: the certificates for each consignment

These are issued for the actual goods and packaging in your order. Ask for copies before the container leaves the factory.

The first two together are what Chinese exporters call the dangerous goods packaging certificate 危包证.

Four checks you can make yourself

• The UN mark on the drum. The letter X, Y or Z in the mark shows the drum is approved for packing group I, II or III. It must not be lower than your product’s packing group.
• The validity dates. A performance result is normally valid for up to 12 months from the date the drum was made. A use appraisal for sea freight is normally valid for one year, or six months for Class 8 corrosives, and never beyond the performance result. The dates printed on the documents decide.
• The customs inspection. China Customs inspects export hazardous chemicals at origin, under its Announcement No. 129 of 2020. The factory applies to its local customs office, and the goods move to the port only after they pass.
• The labels. Each package needs a GHS label, the UN number, the proper shipping name and the class diamond. The container carries placards on all four sides. Tell the supplier what language and label content India requires before the labels are printed.

How much time to allow

• A product the supplier already exports. The reports and labels exist. Each shipment still needs a new use appraisal, the customs inspection and the dangerous goods declaration. The packaging certificate usually takes 5 to 7 working days.
• A product exported for the first time. The classification report and the transport certificate need laboratory testing first. This is the longest part of the process, so ask for a written timeline.
• Booking. Dangerous goods have earlier documentation cut-offs than general cargo. Not every vessel or port accepts every class.

A delivery date that counts only production time is too short.

Six warning signs

1. An offer to ship as general cargo. Misdeclared dangerous goods are a priority target for China Customs and the maritime authority. The shipper is liable, shipping lines blacklist offenders, and your cargo is the one that gets held.
2. Documents that disagree. The product name, UN number and class must match across the SDS, the classification report, the packaging certificate and the invoice.
3. A trading company with no hazardous chemicals business licence.
4. Drums with no UN mark, or a mark for a lower packing group than the product needs.
5. Certificates that have expired, or that name a different product or factory.
6. No clear answer on precursor chemicals when the formulation contains common solvents such as acetone, toluene or methyl ethyl ketone.

What these documents do not cover: the Indian side

Chinese paperwork only shows that the goods can leave China legally. Import rules in India are the importer’s responsibility. Check these three with your customs broker before you sign the contract.

• MSIHC Rules, 1989. For chemicals listed in the schedules of the Manufacture, Storage and Import of Hazardous Chemical Rules, the importer must notify the concerned authority at least 30 days before import, with product safety information. Summary by Intertek.
• Petroleum Act, 1934 and Petroleum Rules, 2002. PESO licenses the import and storage of petroleum, classed by flash point: Class A below 23 °C, Class B from 23 °C to below 65 °C, Class C from 65 °C to below 93 °C. The definition includes inflammable mixtures that contain liquid hydrocarbon, so check whether your solvent-based product falls under it. PESO list of petroleum requiring a licence.
• BIS Quality Control Orders. Some chemicals can only be imported from a manufacturer that holds a BIS licence. India withdrew 14 of these orders on 12 November 2025, including those for EVA copolymers, polyurethanes, PVC, polyethylene and polypropylene. Others remain in force, so check the current list for your product. ICIS report on the withdrawal.

Sources

This is a practical guide and does not replace the regulations. Requirements for a specific shipment come from the authorities and the shipping line handling it. The Chinese sources below are in Chinese.

• Hazardous Chemicals Safety Law of the People’s Republic of China, adopted 27 December 2025, in force from 1 May 2026
• General Administration of Customs Announcement No. 129 of 2020, inspection of imported and exported hazardous chemicals and their packaging
• China Customs service guide: use appraisal of export dangerous goods packaging
• Provisions on the Safety Supervision of Dangerous Goods Carried by Ships, Ministry of Transport Order No. 14 of 2024
• IMDG Code Amendment 42-24, mandatory from 1 January 2026
• Catalogue of Hazardous Chemicals, with the 2022 and 2026 adjustments