China Adds 2 Piperidine Precursor Chemicals to Export Catalog: Exports to US, Mexico and Canada Require Licenses

On September 22, 2026, the Ministry of Commerce (MOFCOM), the Ministry of Public Security (MPS), the Ministry of Emergency Management (MEM), the General Administration of Customs (GACC) and the National Medical Products Administration (NMPA) jointly issued the Announcement of Five Departments Including the Ministry of Commerce on Adjusting the Catalog of Precursor Chemicals Subject to Export Control to Specific Countries (or Regions) (Announcement No. 40 [2026] of the Ministry of Commerce), deciding to add two substances, methyl 1-phenethyl-4-oxo-3-piperidinecarboxylate and ethyl 1-phenethyl-4-oxo-3-piperidinecarboxylate, to Part 1 of Annex 1 of the Catalog of Precursor Chemicals Subject to Export Control to Specific Countries (or Regions) (hereinafter referred to as the “Catalog”). The adjusted Catalog takes effect on the date of issuance of the Announcement. From now on, enterprises exporting chemicals listed in Part 1 of Annex 1 of the Catalog to the US, Mexico and Canada shall apply for a license under the Interim Provisions on the Administration of Export of Precursor Chemicals to Specific Countries (Regions).

Details of This Adjustment

This adjustment only involves Part 1 of Annex 1 (which corresponds to exports to the US, Mexico and Canada). The two newly added substances are listed as items 17 and 18 in the adjusted Catalog, both under the HS code 2933399075, as detailed below:

After the adjustment, Part 1 of Annex 1 contains 18 controlled entries, all of which are piperidine compounds and their derivatives. As clarified in the notes to the Annex, possible salts of the substances listed in the above 18 entries are also subject to control, and the chemicals are controlled by their commodity names, with HS codes provided only as a reference for customs declaration.

Adjusted Catalog and Licensing Requirements

Annex 1 of the adjusted Catalog is divided into two parts: Part 1, targeting the US, Mexico and Canada, contains 18 entries, mainly piperidone- and piperidinamine-based chemicals and their derivatives; Part 2, targeting Myanmar, Laos and Afghanistan, contains 41 entries, covering common chemical raw materials such as ethanol, acetic acid, sodium hydroxide, hydrogen peroxide and magnesium. Annex 2 of the Announcement, the Catalog of Specific Countries (Regions), lists six countries in total: the US, Mexico, Canada, Myanmar, Laos and Afghanistan.

According to the Announcement, from the date of its issuance, an export license shall be applied for under the Interim Provisions on the Administration of Export of Precursor Chemicals to Specific Countries (Regions) for exporting chemicals listed in Part 1 of Annex 1 to the US, Mexico and Canada, and for exporting chemicals listed in Part 2 of Annex 1 to Myanmar, Laos and Afghanistan; exports to other countries (regions) do not require such a license. The Interim Provisions also specify that export licenses for precursor chemicals are subject to the “one shipment, one license” system and the “one license, one customs office” administration.

History of Catalog Adjustments

This is the second adjustment to the Catalog this year. The recent adjustments to the Catalog are as follows:

1. April 23, 2024: MOFCOM and four other departments issued an announcement adding 24 substances, including hydrobromic acid, expanding the Catalog of Precursor Chemicals for Export to Specific Countries (Regions) from 17 to 41 substances, effective from May 1, 2024 and applying to Myanmar, Laos and Afghanistan — the predecessor of Part 2 of Annex 1 of the current Catalog;
2. November 10, 2025: MOFCOM, MPS, MEM, GACC and NMPA issued Announcement No. 73 of 2025, adding the US, Mexico and Canada to the Catalog of Specific Countries (Regions) and adding 13 precursor chemicals for the above three countries, which formed Part 1 of Annex 1;
3. May 22, 2026: the five departments issued Announcement No. 6 of 2026, adding three substances, including methyl 1-(tert-butoxycarbonyl)-4-oxo-3-piperidinecarboxylate, to Part 1 of Annex 1, bringing the Part 1 list to 16 items.

With this adjustment, the number of substances listed in Part 1 of Annex 1 increases to 18, while Part 2 remains unchanged at 41 items.

ChemRadar Insights

In view of this adjustment, enterprises engaged in the export of the relevant chemicals are advised to note the following:

1. Verify the controlled status of products item by item: the Catalog controls chemicals by commodity name, while HS codes are provided only as a reference for customs declaration; moreover, the two newly added substances share the HS code 2933399075 with the existing Part 1 entries, so the controlled status cannot be determined from the HS code alone. Enterprises exporting piperidine chemicals to the US, Mexico and Canada should check their products item by item against the adjusted list of 18 entries by commodity name, and products exported in the form of salts should also be checked;
2. Obtain licenses before export: this adjustment takes effect on the date of issuance of the Announcement, with no transition period. An export license shall be applied for under the Interim Provisions on the Administration of Export of Precursor Chemicals to Specific Countries (Regions) for exporting chemicals listed in Part 1 to the US, Mexico and Canada, and chemicals listed in Part 2 to Myanmar, Laos and Afghanistan. Enterprises with signed but unshipped orders should verify their licensing arrangements as soon as possible to prevent customs clearance from being blocked due to unlicensed export;
3. Distinguish compliance obligations by destination: the licensing requirement of this adjustment applies only to the six countries listed in the Catalog of Specific Countries (Regions), and exports to other countries (regions) do not require a license under the Interim Provisions; if the relevant chemicals are also covered by other export control regimes, the corresponding requirements must still be observed.

Further information

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