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Exempt from Identification = Not Hazardous? Q&A on Chemical Physical Hazard Identification Is Here!

Mar 18, 2026
China
Hazardous Chemicals
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The Law on the Safety of Hazardous Chemicals was adopted and promulgated on December 27, 2025. Article 3 stipulates that the state establishes a catalog management system for hazardous chemicals. The hazardous chemicals catalog is determined and published by relevant departments based on the identification and classification standards for chemical hazard characteristics, and is adjusted as appropriate. Article 124 stipulates that if the hazard characteristics of a chemical have not been determined, no unit or individual may engage in the production, storage, use, operation, transportation, or other activities involving the chemical without authorization. The release of the new law has prompted more companies to pay attention to identification.

Based on the Measures for the Administration of Identification and Classification of Physical Hazards of Chemicals and the Catalog of Chemicals Exempt from Physical Hazard Identification and Classification issued in 2016, we have compiled a list of frequently asked questions.

Q: What is the identification and classification of physical hazards of chemicals?

A: Identification of physical hazards of chemicals refers to testing and determining based on relevant national or industry standards to establish the hazardous characteristics of chemicals such as flammability, explosiveness, corrosivity, oxidizing properties, self-reaction, and water reactivity.

Classification of physical hazards of chemicals refers to evaluating the identification results or relevant data of chemicals based on relevant national or industry standards to determine their physical hazard categories.

Q: Which chemicals should undergo physical hazard identification and classification?

A: 1. Chemicals that contain one or more components listed in the Inventory of Hazardous Chemicals but whose overall physical hazards have not yet been determined;

2. Chemicals not listed in the Inventory of Hazardous Chemicals and whose physical hazards have not yet been determined;

3. Chemicals intended for scientific research or product development with an annual production or usage exceeding 1 ton, and whose physical hazards have not yet been determined.

Q: What does the physical hazard identification of chemicals include?

A: 1. Physical hazards related to explosives, flammable gases, aerosols, oxidizing gases, gases under pressure, flammable liquids, flammable solids, self-reactive substances, pyrophoric liquids, pyrophoric solids, self-heating substances, substances which in contact with water emit flammable gases, oxidizing liquids, oxidizing solids, organic peroxides, and substances corrosive to metal;

2. Physicochemical properties such as vapor pressure, auto-ignition temperature, and chemical stability and reactivity related to the classification of chemical hazards.

Q: Under what circumstances can chemicals be exempted from physical hazard identification and classification?

A: 1. Substances listed in the first batch of the Catalog of Chemicals Exempt from Physical Hazard Identification and Classification issued in 2016. The catalog can be accessed at: https://hgt.cirs-group.com/tools/cis/inv/69b3bc9bb9ba55b1afc34f88

This catalog is divided into two tables: Chemicals without Physical Hazards and Chemicals with Physical Hazards.

Note: Exemption from identification does not mean the substance is not a hazardous chemical. The determination of hazardous chemicals needs to refer to the "Catalog of Hazardous Chemicals" and the determination principles. Hazardous chemicals should have SDS and safety labels prepared in accordance with regulations, undergo hazardous chemical registration, and strengthen safety management.

2. For the purpose of scientific research or product development, where the annual production or usage does not exceed 1 ton.

 

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