China’s Hazardous Chemicals Operation Permit: Who Needs It and How to Apply

Regulatory Background

In China, companies engaged in the sale or storage of hazardous chemicals listed in the Catalogue of Hazardous Chemicals (2015 Edition) must obtain a Hazardous Chemicals Operation permit, as mandated by the Measures for the Administration of Operating Licenses for Hazardous Chemicals (2015 Revision). Operating without a permit is prohibited. However, the requirements do not apply to the operation of civil explosives, radioactive materials, nuclear substances, or urban gas.

Who Needs a Hazardous Chemicals Operation Permit?

You must apply for a Hazardous Chemicals Operation permit if:

• Your company engages in the sale or storage of hazardous chemicals within China.
• Your business purchases hazardous chemicals for repackaging, refilling, or diluting with non-hazardous solvents for resale.

You are exempt from obtaining the permit if:

• You are ahazardous chemical production enterprise that has lawfully obtained a work safety license for hazardous chemicals and sells your own products within your factory area.
• You are a port operator that has obtained a port operation permit according to law engagesin the storage of hazardous chemicals within the port area.
• You purchase hazardous chemicals solely for internal use (including imports for self-use).

Chemicals Requiring an Operation Permit

• Chemicals listed in the Catalogue of Hazardous Chemicals (2015 Edition).
• Mixtures whose main components are all hazardous chemicals listed in the Catalogue, and whose mass ratio or volume ratio of the main components are not less than 70% (except those that are not identified as hazardous chemicals).
• Special case (Item 2828): Flammable liquid mixtures such as synthetic resins, paints, coatings, and other products containing flammable solventswith a closed-cup flash point ≤60°C.

Important: Pure substances not listed in the Catalogue do not require the operation permit for sale. 

Types of Permit Applications (For Businesses Without Storage Facilities)

• Initial Application:
  For companies applying for the first time, before engaging in the import or sale of hazardous chemicals.
• Modification Application:
  Required within 20 working daysif there are changes to:
  • Legal representative
  • Company name
  • Registered address
  • Storage facilities or their monitoring measures
  • Construction, renovation, or expansion of hazardous chemical storage facilities
• Renewal Application:
  Submit at least three months beforethe permit expires.
• Reapplication:
  Necessary when:
  • Changing the business premises (for businesses without storage facilities)
  • Relocating storage sites (for businesses with storage facilities)
  • Reconstructing storage facilities at a different location
  • Changing the business model or permit scope
• Cancellation Application:
  Submit when terminating hazardous chemical business activities.

Key Documents Required (For Businesses Without Storage Facilities)

1. Application form and official documents
2. List of safety management systems and operational procedures
3. Copies of qualification certificates for key personnel:
   • Legal representative
   • Safety management personnel
   • Special operations personnel
   • Training certificates for other employees
4. Proof of property ownership or lease agreement for business premises
5. Operation permit or pre-approval document issued by the Administration for Industry and Commerce
6. Record of the hazardous chemicals emergency response plan

Step-by-Step Permitting Process

1. Confirm Requirement:
   Verify whether your chemicals require permitting and if your company’s location is eligible to apply.
2. Prepare Documentation:
   Collect necessary business information, supporting documents, and a list of hazardous chemicals to be sold.
3. Submit Application:
   File your application and respond to any requests for additional documents or site inspections.
4. Approval and Issuance:
   Complete the online operation permit approval process.
5. Receive License:
   Obtain your official Hazardous Chemicals Business Licenses.

Compliance Tips

To avoid business disruptions, companies should plan permitting applications well in advance, especially when dealing with changes in premises, business scope, or regulatory renewals.

Navigating chemical compliance regulations in China can be complex—partnering with REACH24H can greatly streamline the permitting process and ensure full legal compliance.