China's MEM Focuses on Management of Hazardous Chemicals Registration and Identification

In March 2024, China's Ministry of Emergency Management (MEM) issued the Guidelines for key issues in the 2024 law enforcement inspection of work safety of hazardous chemicals enterprises, which identified 32 key law enforcement inspection items, including the registration and identification management of hazardous chemicals.

The law enforcement inspection on the registration and identification of hazardous chemicals aims to promote the registration and identification of hazardous chemicals with unknown physical hazards, and urge enterprises to standardize the preparation and use of safety data sheets (SDSs) and labels to push hazard communication and ensure the safe production of hazardous chemicals.

Enterprises involved in 28 types of key hazardous chemicals (listed in Annex 1) and those that were found to have problems during inspections conducted last year will be the targets of this year's inspections. Relevant companies need to register their hazardous chemicals. Establishing management documents, using SDSs and labels for hazardous communication, and setting up safety warning signs in hazardous chemical storage places are also required.

In terms of physical hazard identification and classification management of chemicals, fine chemical companies that have been newly put into production and involved in industrial transfer in the past three years, chemical companies classified as chemical reagent and auxiliary agent manufacturing, special chemical products manufacturing, and lithium battery electrolyte manufacturers will become the main inspection targets. The inspection is about document management of physical hazard identification and classification. For Final products or intermediate products whose components are listed in the Catalog of Hazardous Chemicals (2015) and whose physical hazards have not been determined yet, their physical hazard identification and classification should be checked. For final products or intermediate products that are not listed in the Catalog of Hazardous Chemicals (2015) and whose physical hazards have not been determined yet, their physical hazard identification and classification should also be checked. Hazardous chemicals that have been identified and classified need to be registered in accordance with the regulation, and their SDS and labels shall be prepared and used with compliance.

Evaluation results and summary of the inspection will be completed by the end of November this year. Provincial emergency management departments will summarize typical cases and make reports. National Registration Center for Chemicals of MEM will also evaluate the working results of the registration agency.

The authorities inspected almost 5,000 companies last year to check on the registration of hazardous chemicals. The inspections checked on the compliance of using SDSs and labels and the effectiveness of production safeguards. Companies that don't register or modify registration as required may result in a fine of 50,000 RMB. Companies that fail to correct issues may result in a fine of 100,000 RMB. If the situation is serious, production may be suspended for rectification. The same penalties apply if a company cannot provide the SDS for their hazardous chemicals, or there is no label whose information is consistent with the product inside the package, or they are sell the hazardous chemicals without SDSs and labels.

Annex 1: Twenty-eight types of hazardous chemicals that are subject to key inspections in terms of hazardous chemical registration, and SDSs and labels management

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