What Are China’s Chemical Restrictions for Imported Products?

China has developed an increasingly comprehensive framework for restricting hazardous chemicals in imported products. These regulations apply not only to chemical substances themselves but also to a wide range of manufactured goods — electronics, toys, textiles, furniture, building materials, packaging, and more. Foreign manufacturers must navigate a complex web of mandatory standards, registration requirements, and labelling obligations to ensure compliance.

1. Overview of China’s Chemical Regulatory Framework

China’s chemical restrictions for imported products operate at multiple regulatory levels:

2. China RoHS — Restriction of Hazardous Substances in Electronic Products

2.1 Scope and Applicability

China RoHS applies to all electrical and electronic products (EEE) sold in the Chinese market, including imported products. The regulation is formally titled “Management Methods for the Restriction of Hazardous Substances in Electrical and Electronic Products” (MIIT Order No. 32, 2016). It covers products in 12 major categories, ranging from household appliances and IT equipment to lighting, medical devices, and industrial monitoring equipment.

2.2 Restricted Substances and Limits

China RoHS restricts the following six substances (matching EU RoHS limits):

2.3 China RoHS Compliance Methods

China RoHS offers two compliance pathways:

Pathway A — Self-Declaration (自我声明):

• The manufacturer or importer tests their product or uses supplier declarations to confirm compliance
• A China RoHS compliance label (green “e” mark) is affixed to the product
• Technical documentation must be maintained for inspection by authorities
• Suitable for most standard EEE products

Pathway B — Third-Party Certification (CCC + RoHS):

• Required for products in the CCC catalogue (see FAQ article)
• The CCC certification process incorporates RoHS testing and verification
• A combined CCC + RoHS mark is applied
• Required for products listed in the “RoHS Compliance Catalogue” published by MIIT

2.4 China RoHS Labelling Requirements

All products subject to China RoHS must display the following information:

• The “Green e” logo — indicating the product meets China RoHS limits (for Pathway A)
• The “Orange 10” logo — for products where restricted substances may exceed limits in certain parts (e.g., spare parts)
• Hazardous substance disclosure table — A table listing the six restricted substances and their concentrations per component, written in simplified Chinese
• Environmentally friendly use period (EFUP) — A number (e.g., 10, 20, 50 years) indicating the period during which the product is expected to remain RoHS-compliant under normal use

3. IECSC and New Chemical Substance Registration

3.1 The Inventory of Existing Chemical Substances in China (IECSC)

The IECSC (Inventory of Existing Chemical Substances in China) is China’s equivalent of the EU’s REACH inventory (EINECS/EC number system). The inventory lists chemical substances that are considered “existing” in China. Substances not on the IECSC are classified as “new chemical substances” and require registration before they can be manufactured in or imported into China.

3.2 New Chemical Substance Registration

Governed by MEP Order No. 7 (Measures for the Environmental Management of New Chemical Substances), any new chemical substance (not listed on IECSC) imported into China in quantities of 1 tonne per year or more must be registered with the MEE. The registration process involves:

• Notification/Registration application — Submit substance identity, physical-chemical properties, toxicological data, and ecotoxicological data
• Risk assessment — Evaluation of the substance’s hazards and exposure potential
• Testing requirements — Ranging from basic data (for ≤ 1 t/y) to full testing suite (for ≥ 100 t/y)
• Registration certificate — Issued by MEE, valid for 5 years

3.3 Exemptions from New Chemical Substance Registration

• Substances in finished products that do not release the substance under normal use
• Substances imported in quantities below the 1 t/y threshold (though recordkeeping is still required)
• Polymers meeting certain criteria (low-risk polymers)
• Food additives, pharmaceuticals, pesticides, and cosmetics (covered by other regulations)

4. Chemical Restrictions by Product Category

4.1 Toys

Chemical restrictions for toys are governed by GB 6675 series standards:

• GB 6675.2-2014 — Physical and mechanical properties
• GB 6675.3-2014 — Flammability
• GB 6675.4-2014 — Migration of certain elements (antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium) — limits aligned with EN 71-3
• Phthalate restrictions — Six phthalates (DEHP, DBP, BBP, DINP, DIDP, DNOP) restricted to ≤ 0.1% in plasticised toy materials
• Formaldehyde limits — For textile toys (≤ 75 mg/kg for direct contact, ≤ 300 mg/kg for non-contact)

4.2 Textiles and Apparel

Chemical restrictions for textiles are governed by GB 18401-2010 (National General Safety Technical Code for Textile Products):

• Formaldehyde — ≤ 20 mg/kg (infants), ≤ 75 mg/kg (direct contact), ≤ 300 mg/kg (non-contact)
• pH value — 4.0–8.5 (varies by category)
• Azo dyes — 24 banned carcinogenic aromatic amines (≤ 20 mg/kg each)
• Heavy metals — Extractable antimony, arsenic, lead, cadmium, chromium, cobalt, copper, nickel, mercury (limits vary by metal and product category)
• Chlorinated phenols — PCP (pentachlorophenol) ≤ 0.5 mg/kg, TeCP ≤ 0.5 mg/kg
• Organotin compounds — TBT, DBT, DOT (varying limits by category)
• Phthalates — Six phthalates restricted in textile coatings

4.3 Furniture and Wood-Based Products

GB 18580-2017 governs formaldehyde emission limits for wood-based panels and flooring:

• E1 grade — Formaldehyde emission ≤ 0.124 mg/m³ (tested by 1m³ chamber method)
• Enf grade — Formaldehyde emission ≤ 0.050 mg/m³ (stricter, similar to Japan’s F★★★★)
• Furniture coating limits — GB 18581-2020 limits VOCs, benzene, toluene, xylene, and heavy metals in solvent-based coatings

4.4 Paints and Coatings

GB 18581-2020 and GB 18582-2020 cover solvent-based and water-based coatings respectively:

• VOC content limits — Vary by coating type (e.g., ≤ 420 g/L for interior wall paint, ≤ 80 g/L for water-based primer)
• Benzene — ≤ 0.1% (excluding solvent-based) or not detected
• Toluene and xylene — Combined limit varies by coating type
• Heavy metals — Lead ≤ 90 ppm, cadmium ≤ 75 ppm, chromium ≤ 60 ppm, mercury ≤ 60 ppm
• Free formaldehyde — ≤ 50 mg/kg (water-based interior wall paint)

4.5 Food Contact Materials

China’s food contact material standards (GB 4806 series) impose strict chemical migration limits:

• GB 4806.1-2016 — General safety requirements for food contact materials
• GB 4806.7-2016 — Plastic food contact materials (migration limits for specific monomers, additives)
• GB 4806.9-2016 — Metal food contact materials (limits on impurity elements)
• GB 4806.10-2016 — Coated food contact materials
• Overall migration limit — 10 mg/dm² (general), with specific migration limits (SML) for individual substances
• Primary aromatic amines (PAAs) — Total migration ≤ 0.01 mg/kg (NOT detectable) for food contact plastics

4.6 Cosmetics and Personal Care

Chemical restrictions for cosmetics are governed by the Cosmetic Supervision and Administration Regulation (CSAR) and the Inventory of Existing Cosmetic Ingredients in China (IECIC):

• Prohibited substances — 1,292 substances prohibited from use in cosmetics (updated from the original 1,388+ list under prior regulation)
• Restricted substances — 47 substances with concentration limits (preservatives, UV filters, colourants)
• Allowed colourants — Positive list of permitted colouring agents
• Heavy metal limits — Lead ≤ 10 ppm, arsenic ≤ 2 ppm, mercury ≤ 1 ppm, cadmium ≤ 5 ppm
• Methanol — ≤ 2,000 ppm (for products containing ethanol)

4.7 Children’s Products

Additional restrictions apply to products intended for children under 14 years:

• GB 21027-2020 — Student supplies (limits on VOCs, solvents, phthalates in erasers, liquid adhesives)
• GB 30585-2014 — Children’s footwear (limits on heavy metals, formaldehyde, azo dyes)
• GB 31701-2015 — Textile products for infants and children (stricter limits on formaldehyde, pH, azo dyes)

5. The VOC Framework — Volatile Organic Compounds

China has been systematically tightening VOC limits across multiple product categories as part of its Air Pollution Prevention and Control Action Plan:

6. Packaging and Packaging Waste Regulations

Imported products must also comply with China’s packaging chemical restrictions:

• GB/T 16716.1-2018 — Packaging and packaging waste (general requirements)
• Heavy metals in packaging — Total concentration of lead, cadmium, mercury, and hexavalent chromium ≤ 100 ppm (similar to EU Packaging Directive)
• Wood packaging — Must comply with ISPM 15 (heat treatment or fumigation) for phytosanitary purposes
• Plastic packaging labels — Must indicate resin identification codes (PETE, HDPE, PVC, etc.)
• Recyclability requirements — Packaging should be designed for recyclability where technically feasible

7. Customs Control and Inspection

China Customs (GACC) enforces chemical restrictions through the following mechanisms:

• CIQ inspection — Products listed in the Inspection and Quarantine Catalogue are subject to mandatory inspection at the port of entry, including chemical testing
• HS code classification — Each product’s HS code determines which chemical restrictions apply at customs clearance
• Import licenses — Products containing restricted chemicals may require additional import licences (e.g., for ozone-depleting substances, toxic chemicals)
• Random sampling — GACC conducts random sampling and testing of imported products for chemical compliance; products found non-compliant are detained
• Recall and notification — Non-compliant chemical products may result in mandatory recall and notification to MEE

8. Penalties for Non-Compliance

Penalties for violating China’s chemical restrictions vary by regulation but can include:

• Product detention and destruction — Non-compliant products are detained at customs and ordered destroyed at the importer’s expense
• Administrative fines — Up to 300,000 RMB under the Product Quality Law; up to 1,000,000 RMB under environmental protection regulations
• Revocation of business licence — In serious cases, the importer’s or manufacturer’s business licence may be revoked
• Customs blacklisting — Companies found violating chemical restrictions may be placed on a customs blacklist, increasing inspection frequency for all future imports
• Environmental liability — Under the Environmental Protection Law, companies causing environmental damage through improper chemical management face remediation costs and potential criminal liability
• Public naming and shaming — SAMR and MEE publish lists of non-compliant products and companies on their official websites

9. Frequently Asked Questions

Q: Is China RoHS the same as EU RoHS?

No — while the six restricted substances have the same concentration limits, China RoHS has different compliance procedures (Pathway A vs. Pathway B), different labelling requirements (Green e / Orange 10 vs. CE marking), and a different scope of covered products. EU RoHS compliance is a helpful starting point but does not guarantee China RoHS compliance.

Q: Does China have a REACH-style registration system?

China does not have a direct equivalent of EU REACH. However, the MEP Order No. 7 system for new chemical substances performs a similar function for chemical substances not on the IECSC. The MEE is also developing a broader chemical management framework similar to EU REACH, but it is not yet in force.

Q: Do I need to register my product’s chemical composition with Chinese authorities?

For manufactured goods (not bulk chemicals), you typically do not need to pre-register the chemical composition unless the product contains substances specifically regulated under China RoHS (Pathway B), GB standards with mandatory testing, or new chemical substances. However, you must be able to demonstrate compliance upon request.

Q: What about PFAS/PFOS restrictions in China?

China has begun restricting per- and polyfluoroalkyl substances (PFAS). Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are listed in the Inventory of Priority Controlled Chemicals, with use restrictions and emission limits. The restrictions are not yet as comprehensive as in the EU, but the scope of regulated PFAS substances is expanding.

Q: How do I prove compliance with China’s chemical restrictions?

Compliance evidence includes:

• China RoHS self-declaration or third-party certification
• Test reports from CNCA-accredited or ISO 17025-accredited laboratories
• Supplier declarations for component-level compliance
• Material Safety Data Sheets (MSDS) in Chinese for chemical products
• IECSC registration certificates (for new chemical substances)

Q: Are imported food products subject to chemical restrictions?

Yes. Imported food products must comply with China’s National Food Safety Standards (GB 2760–GB 2763 series), which set maximum residue limits (MRLs) for pesticides, food additives, and contaminants. Testing is performed by CIQ at the port of entry.

Q: Can I use my EU REACH registration to satisfy China’s new chemical substance requirements?

EU REACH registration data (including IUCLID dossiers) can be used to support China’s new chemical substance registration application, provided the data meets MEE’s requirements for completeness and quality. However, you must still submit a separate application to MEE — REACH registration does not exempt you from China’s registration process.

Q: What is the “Green e” logo and where should it be placed?

The Green e logo (a green-coloured “e” inside a circle) indicates China RoHS compliance. It should be placed on the product itself or its packaging, in a visible location. The label’s minimum size is 5mm × 5mm for small products. The EFUP (Environmentally Friendly Use Period) number should appear adjacent to the logo.