Shanghai Enforces Hazchem Traceability Codes

Feb. 19th, 2024

By December 31, 2024, Hazchem enterprises within Shanghai should complete the generation and affixing of Hazchem traceability codes.

To advance the implementation of the “One Enterprise, One Chemical Product, One Code” Policy in Shanghai, the Shanghai Emergency Management Bureau (SEMB) and the Shanghai Municipal Transportation Commission (SMTC) recently released a joint notification to implement the use of Hazchem traceability codes. For each batch of Hazchem, a unique QR code should be generated and affixed to the smallest outer packaging throughout its circulation within Shanghai.

By December 31, 2024, Hazchem enterprises within Shanghai should fulfill the following two major tasks, including:

– The generation and affixing of Hazchem traceability codes.

– The establishment of dynamic management system for the in and out information of Hazchem in warehouses and connection with the Hazchem whole supply chain supervision information system (hereinafter referred to as Official Platform) launched by the SEMB (

This shows Shanghai’s ambition to facilitate the tracking of Hazchem information and the monitoring of Hazchem business operations throughout the whole supply chain.

Applicable Scope of Chemicals

  1. Entry No. 1 ~ No. 2727 in the China Inventory of Hazardous Chemicals (2015) (hereinafter referred to as Inventory).
  2. 88 example chemicals specified in the Hazardous Chemical Classification Information Sheet attached to the Guidance for Implementation of China 2015 Inventory of Hazardous Chemicals (Trial), which meet the criteria specified for Entry No. 2828 in the Inventory.
  3. Other chemicals include:
    • Chemicals that meet the criteria for Entry No. 2828 in the Inventory (except 88 chemicals specified in scope B).
    • Chemicals eligible for the “70% principle”: chemicals containing ingredients listed in the Inventory and the sum of their contents is no less than 70% (w/w or v/v).

Applicable Scope of Activities

Manufacture, import, transportation, storage, and use.

Mandatory Obligations

  1. Generation and affixing of Hazchem traceability codes for Hazchem specified in scope A and B, which are manufactured/imported, filled, subpackaged, and/or with GHS label updated within Shanghai.
    Notably, for the generation of a Hazchem traceability code, the followings should be provided to Shanghai’s Official Platform:

    • The Hazchem safety information code obtained from the Hazardous Chemical Registration Comprehensive Service System launched by the NRCC after completing the Hazchem registration.
    • Some additional information, including Hazchem name, quantity, specification, batch number, electronic waybill information, transportation vehicle information, etc.
  2. Scan of Hazchem traceability codes for confirmation of goods receipt via the WeChat mini-program called “危化品追溯 (Hazchem traceability)” in WeChat account “上海应急守护”.
  3. Implementation of dynamic information management system for Hazchem in and out of warehouses, and transferring the information to the SEMB via connecting the Official Platform (mandatory for chemicals specified in scope A, B and C).
  4. Check of information concerning the vehicles, personnels, tanks, waybills and carriers of Hazchem that are considered as dangerous goods via the management system ( for road transportation of dangerous goods .

For different types of Hazchem enterprises, different obligations apply (see table below).

Manufacturers Importers Storage and logistics enterprises Users
Obligation I
✔️ ✔️ ✔️
Obligation II ✔️ ✔️
Obligation III ✔️ ✔️
Obligation IIV ✔️

*Note: Importers are encouraged to coordinate with overseas suppliers to affix Hazchem traceability codes overseas, thus the importers may be included in the WHITELIST to enjoy expedited customs clearance.

Exemptions from Affixing Hazchem Traceability Codes

  • Hazchem whose single package volume does not exceed 100 mL or 100 g.
  • Hazchem transported through pipelines, oil tankers, bulk chemical carriers, and liquefied gas carriers.
  • Hazchem directly transported to other provinces/cities after customs clearance at the Shanghai port, or directly transported to enterprises in Shanghai and consumed as raw materials.

Following the Notification, the SEMB will provide supporting documents in the coming future to further detail the corresponding requirements. The implementation of the Hazchem traceability code in Shanghai will serve as a guide to improve the digitalization of Hazchem management nationwide.

To facilitate industry compliance with the Hazchem traceability code application in Shanghai, ChemLinked is going to stage a webinar on February 28, 2024. The webinar is now open for registration. Please click here to save your seat.


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