China Regulations on the Safety Management of Hazardous Chemicals (Decree No. 591)
ENFORCEMENT TIMELINE
Effective December 1, 2011 (commonly known as "Decree 591"; the core of China's hazardous chemicals registration system)
Overview
China's "Regulations on the Safety Management of Hazardous Chemicals" (State Council Decree No. 591, commonly known as "Decree 591") is China's most fundamental hazardous-chemicals law, uniformly governing the safety management of all stages of production, storage, use, sale, and transport of hazardous chemicals within China, as well as their import and export. First enacted in 1987 and revised in 2002 (Decree No. 344), it underwent a major overhaul that dramatically tightened safety standards and enforcement power, resulting in the current "Decree 591" (effective December 1, 2011). It is a core regulatory requirement for any company exporting to or selling locally in China products falling under the "Catalogue of Hazardous Chemicals" (roughly 2,800 substances with hazardous properties), including inks, paints, adhesives, and cleaning agents. Core obligations for manufacturers and importers under Decree 591 include: (1) Mandatory "national safety registration" of hazardous chemicals -- companies manufacturing hazardous chemicals in China, and importers bringing them into China, must submit detailed hazard data and emergency contact information to the Chemical Registration Center (NRCC) under China's national emergency management authority and complete "hazardous chemicals registration"; (2) Mandatory listing of a "24-hour China-based emergency phone number" on SDS -- the first section of any SDS intended for the Chinese market must list a China-based emergency contact number capable of providing technical support 24 hours a day (either the company's own number or that of an agency such as the NRCC); overseas phone numbers, including Japanese ones, are not accepted under any circumstances; (3) Obtaining a "hazardous chemicals business license" -- companies selling or warehousing hazardous chemicals through a local Chinese entity must meet strict facility safety requirements and obtain a hazardous chemicals business license.
Enforcement Timeline
- 1987: The original "Regulations on the Safety Management of Hazardous Chemical Products" was promulgated by the State Council.
- January 2002: Revised as State Council Decree No. 344, systematizing chemical management.
- December 1, 2011: The current "Decree No. 591" took full effect, consolidating safety oversight under the Ministry of Emergency Management (formerly the State Administration of Work Safety) and dramatically tightening penalties.
- 2015: Following the major chemical warehouse explosion at the Port of Tianjin, spot inspections under Decree 591 and customs inspection and clearance controls for hazardous chemical imports at ports were tightened to the maximum extent.
- From 2023: A major reform introducing "one product, one code" (QR-code traceability) management for hazardous chemical packaging is being progressively rolled out at customs offices in all major cities (per Ministry of Emergency Management notice).
Business Impact
Customs authorities frequently conduct spot inspections leading to seizures and fines: Chinese customs rigorously inspects imported container cargo for substances on the hazardous chemicals catalogue. If a hazardous chemical is misdeclared as an "ordinary chemical," or if the SDS or label fails to comply with Chinese national standards (such as GB 15258) in even a single detail (an incorrect pictogram, a missing emergency phone number, etc.), the entire container can be seized immediately, resulting in substantial fines and a downgrading of the local importer's credit standing. Ongoing costs of outsourcing a "24-hour China-based emergency hotline" service: Companies unable to maintain their own 24-hour hazardous-materials support desk in China must pay a costly annual fee to rent an emergency phone number from an official agency such as the NRCC and list it on the SDS, which becomes a recurring cost of maintaining export operations.
