The Hazardous Chemicals Safety Law of the People's Republic of China was adopted and promulgated at the 19th Session of the Standing Committee of the Fourteenth National People's Congress of the People's Republic of China on December 27, 2025, and will come into effect on May 1, 2026.
After years of multiple draft revisions, the Hazardous Chemicals Safety Law of the People's Republic of China (hereinafter referred to as the Safety Law) is now officially released. What key contents should be focused on, what are the changes, and how to respond? Please see the analysis below.
Key Focus Areas
Catalogue Management System
The Safety Law retains most of the content from the draft. It requires the Ministry of Emergency Management, in conjunction with ten other departments, to determine, publish, and timely adjust the catalogue based on the identification and classification standards for the hazardous properties of chemicals. The emergency management departments are responsible for the supervision and management of hazardous chemicals production safety and the comprehensive supervision and management of hazardous chemicals safety. The draft's mention of principles for determining hazardous chemicals has been removed, highlighting the impact of the inherent hazards of hazardous chemicals themselves on catalogue adjustments. For chemicals with unknown hazards, testing and identification should be completed as early as possible.
Strengthening Management of Personnel Working with Hazardous Chemicals
For personnel employed by hazardous chemicals entities, the Safety Law requires that they receive education and training and must pass assessments before starting work. For positions with qualification requirements, personnel who have legally obtained the corresponding qualifications must be assigned. Employees of hazardous chemicals production enterprises must meet the educational requirements stipulated by the state, receive safety production education and training, and pass assessments before starting work. Hazardous chemicals production enterprises must establish and improve safety training management systems, organize regular training, and enhance the safety awareness and safety production skill levels of their personnel.
Safety Assessment Report Disclosure System
Compared with Decree No. 591, the new Hazardous Chemicals Safety Law adds requirements for making safety assessment reports publicly available.
Article 39 stipulates that enterprises producing or storing hazardous chemicals must commission institutions with qualifications meeting state requirements to conduct a safety assessment of their production safety conditions every three years and produce a safety assessment report. The content of the safety assessment report must include plans for rectifying problems identified in the production safety conditions and conclusive opinions after the rectification is completed. Safety assessment reports must be made publicly available as stipulated.
SDS and Labeling Management Requirements
Hazardous chemicals production enterprises and import enterprises must provide Chinese-language chemical safety data sheets (SDS) consistent with the hazardous chemicals they produce or import. They must also affix, print, or attach Chinese-language chemical safety labels consistent with the hazardous chemicals inside the packaging (including outer packaging, same below) on the packaging of hazardous chemicals. SDS and chemical safety labels must comply with national standard requirements.
If hazardous chemicals production enterprises or import enterprises discover new hazardous properties in the hazardous chemicals they produce or import, they must immediately issue an announcement and promptly revise their SDS and chemical safety labels.
The current Safety Law does not mention specific revision time limits. It is best to refer to international practices and update them promptly within a 6-month to 1-year timeframe.
When hazardous chemicals production enterprises and business operators sell hazardous chemicals, they must provide purchasers (entities or individuals) with SDS that comply with laws, administrative regulations, and national/industry standards. They must not deal in hazardous chemicals without SDS or chemical safety labels, nor may they arbitrarily alter SDS or chemical safety labels.
Any entity or individual purchasing hazardous chemicals has the right to request relevant SDS for the hazardous chemicals from the production enterprise or business operator to understand their hazardous properties, protective measures, and usage methods.
Exemptions from Hazardous Chemicals Registration
Hazardous chemicals production enterprises and import enterprises must register their hazardous chemicals with the hazardous chemicals registration agency. Article 87 adds some exemptions from registration: The state exempts low-quantity, low-release, low-exposure hazardous chemicals used in research, development, trial production, and trial sales from registration. Specific measures for exemptions will be formulated by the State Council's emergency management department in conjunction with departments for industry and information technology, public security, ecology and environment, agriculture and rural affairs, health, customs, etc.
Hazardous Chemicals Transportation Management
Article 64 clarifies that the transportation of hazardous chemicals managed as dangerous goods via road or waterway must comply with this Law and relevant laws, administrative regulations, and the State Council's transportation department regulations on the safety of dangerous goods road and waterway transport. Article 65 further clarifies that hazardous chemicals that can be managed as general cargo after proper treatment can be transported as such. Specific measures will be formulated by the State Council's transportation department.
These two articles clarify the relationship between hazardous chemicals and dangerous goods. Not all hazardous chemicals need to be transported and managed as dangerous goods.
Information-based Supervision of Hazardous Chemicals
Article 11 stipulates that departments of county-level or above people's governments responsible for hazardous chemicals safety supervision and management must strengthen information-based supervision of hazardous chemicals, implementing electronic identification and full life-cycle information management and monitoring for hazardous chemicals.
Management of Chemical Industrial Parks
The new Hazardous Chemicals Safety Law includes chemical industrial parks as regulated entities, adding many management requirements:
Article 17: Chemical industrial parks shall be designated, announced, and periodically reviewed by the people's governments of provinces, autonomous regions, or municipalities directly under the Central Government or their authorized departments.
Provincial-level people's governments shall rationally construct chemical industrial parks, organize safety risk level assessments and evaluations for chemical industrial parks, and establish and implement control measures.
Chemical industrial parks must implement dynamic supervision of all hazardous chemicals entering and leaving the park and conduct risk monitoring and early warning for enterprises, key locations, major hazard sources, and infrastructure within the park.
Article 18: New construction or expansion projects for hazardous chemicals production shall be located within chemical industrial parks, except for projects supporting production facilities in other industries and other projects that comply with state regulations.
Except for enterprises providing supporting services to chemical enterprises, non-chemical enterprises are prohibited from entering chemical industrial parks.
Article 19: Chemical industrial parks must conduct overall safety risk assessments at least once every three years, propose countermeasures to eliminate, reduce, or control safety risks, and implement them effectively.
Clarification of Management Department Responsibilities
Article 121: The safety management of controlled chemicals, pharmaceuticals, and pesticides that are hazardous chemicals shall be implemented in accordance with this Law; unless otherwise provided by laws or administrative regulations, in which case those provisions shall apply.
Article 125: For hazardous chemicals production and production facilities using hazardous chemicals and their connected storage tank sections within port areas, safety supervision and management shall be the responsibility of emergency management departments. For storage tank sections connected solely to hazardous chemicals terminals, safety supervision and management shall be the responsibility of port administrative departments.
Encouraging Reporting, Adding Rewards
Article 10 stipulates that any entity or individual has the right to report or notify departments responsible for hazardous chemicals safety supervision and management of violations of this Law or potential accident hazards. County-level or above people's governments and their relevant departments shall, according to law, reward individuals who have performed meritorious service by reporting illegal acts or reporting major accident hazards, and shall strictly keep confidential the information of reporters and informants.
Legal Liabilities
In any of the following circumstances, the department responsible for hazardous chemicals safety supervision and management shall, according to its division of duties, order corrections within a specified time limit and may impose a fine of up to 100,000 RMB; if corrections are not made by the deadline, a fine between 100,000 and 200,000 RMB shall be imposed, and a fine between 20,000 and 50,000 RMB shall be imposed on the directly responsible supervisors and other directly responsible personnel; if the circumstances are serious, an order to suspend production or business for rectification shall be issued:
(1) Hazardous chemicals production enterprises or import enterprises fail to provide a Chinese SDS, or fail to affix, print, or attach a Chinese chemical safety label on the hazardous chemicals packaging;
(2) The Chinese SDS provided by a hazardous chemicals production enterprise or import enterprise does not match the hazardous chemicals they produce or import; the Chinese chemical safety label affixed, printed, or attached on the hazardous chemicals packaging does not match the hazardous chemicals inside the packaging; or the SDS or chemical safety label does not meet national standard requirements;
(3) A hazardous chemicals production enterprise or import enterprise discovers new hazardous properties in the hazardous chemicals they produce or import but fails to immediately announce it, or fails to promptly revise its SDS or chemical safety label;
(6) Employees of a hazardous chemicals production enterprise fail to meet the state-stipulated educational requirements, fail to receive safety production education and training, or start work without passing the assessment;
(7) The material of hazardous chemicals packaging or containers, or the type, specification, method, and unit mass of the packaging is unsuitable for the nature and purpose of the packaged hazardous chemicals;
(10) A unit producing, storing, or using hazardous chemicals fails to set up obvious safety warning signs at work sites and on safety facilities/equipment, or fails to install and maintain in usable condition communication and alarm devices at work sites;
(11) A dedicated hazardous chemicals storage place fails to assign dedicated personnel for management; fails to implement a dual-person receipt/dispatch and dual-person custody system for stored highly toxic chemicals and other hazardous chemicals whose stored quantity constitutes a major hazard source; or the retention period for receipt/dispatch records is less than three years;
(12) A unit storing hazardous chemicals fails to establish a verification and registration system for inbound and outbound hazardous chemicals;
(13) A dedicated hazardous chemicals storage place fails to set up obvious signs;
(14) A research and development unit directly uses a new process or technology for industrial production without pilot-scale testing, pilot plant testing, or industrialization trials; or when transferring a new hazardous chemicals process or technology, fails to provide a safety demonstration report and related materials for the new process/technology;
(15) A unit using hazardous chemicals fails to provide the SDS and chemical safety labels used at its work sites to its employees, or fails to inform employees of the correct usage methods and measures to be taken in emergencies;
(16) A hazardous chemicals production enterprise or business operator deals in hazardous chemicals without SDS or chemical safety labels, or arbitrarily alters SDS or chemical safety labels;
(17) A hazardous chemicals production enterprise or import enterprise fails to register its hazardous chemicals, or discovers new hazardous properties or other changes in registration content for the hazardous chemicals it produces or imports but fails to go through the registration content modification procedures.
Self-inspection for compliance with the obligations required by the Safety Law should begin immediately, and adjustments and updates should be completed before May 1 next year!
