Chemical Registration in China

Chemical Registration in China - Overview

Chemical products used for cleaning and disinfecting purpose are called/identified and regulated very differently across countries and regions, making it very challenging for the industry to place these products in different markets.

Chemical products, being an integral part of the general consumer portfolio, must ensure the quality, efficacy, and safety of the product while being placed in the market. Different Regulatory bodies around the globe enforce regulations w.r.to registration, conformity assessment, standard compliance, sustainability, etc., for chemical products' safety.

In China, disinfectant products are regulated by National Health and Family Planning Commission (NHFPC) under the regulation - Measures on Administration of Disinfection Products. Daily chemical products and disinfectant products shall be registered or notified before sale or import. Only new disinfectants (new materials, new processes and technologies, and new sterilization principles) shall be registered and should be managed under the following three (03) categories depending on the risk:

• Category 1 (High Risk)
• Category 2 (Medium Risk)
• Category 3 (Low Risk)

Category 1 and Category 2 products shall be notified before sale or import. Category 3 products shall be under regular supervision by the manufacturers/companies. They should guarantee product compliance before sale or import.

On the other hand, detergent products should comply with China’s National Standard (GB) such as GB/T 26396-2011 (Technical specifications for safety of soaps and detergents).

Further, active and non-active chemicals used in the product formulation/mixture are subjected to other additional regulations such as GB 38850-2020 (List for materials and restricted substances in disinfectant). It specifies:

• The list of ingredients.
• The scope of application for different disinfection objects along with prohibited and restricted substances in disinfectant formulations.
• China REACH/Inventory of existing chemical substances produced or imported in China.

Table 1: Chemical Regulations in China

Sustainability

In China, the primary Regulatory body responsible for environmental protection and sustainable development is the Ministry of Ecology and Environment of China (MEE). The MEE has implemented various regulations and standards to promote sustainable practices in consumer products. However, it's important to note that specific regulations for sustainability and environmental logos can vary depending on the type of product and industry.

• China Environmental Labeling Program (CELP): The China Environmental Labeling Program, also known as the China Eco-label or the Green Logo, is a voluntary certification program initiated by the Chinese government. It aims to promote products that meet specific environmental standards throughout their life cycle. The program covers various product categories, including household appliances, electronics, paper products, textiles, and more. Products that meet the required standards can display the Green Logo on their packaging.
• Hazardous Substance Control: China has regulations in place to control the use of hazardous substances in consumer products. For example, the China Restriction of Hazardous Substances (RoHS) restricts the use of certain hazardous substances in electrical and electronic products. Compliance with these regulations ensures that products meet specific environmental and health standards.
• Packaging Waste Management: China has also implemented regulations to manage packaging waste. These regulations aim to reduce the environmental impact of packaging materials by promoting recycling and waste reduction. The specific requirements for packaging waste management can vary depending on the region and the type of product.

It's important to note that compliance with these chemical regulations and obtaining the necessary certifications often requires interpretive skills. With experience in sustainability challenges, Freyr is well-positioned to support various sustainability-related services and has been supporting some of the leading global firms with food contact material compliance, consumer product packaging Regulatory services, and ecolabeling requirements. 

Pet Food

Any pet food company willing to export pet snacks and supplements to China must comply with a series of regulations, laws, and registrations. The Chinese authorities involved are the General Administration of China Customs (GACC) and the Ministry of Agriculture and Rural Affairs (MARA). GACC authorizes a foreign company's production facility to export goods to China and MARA authorizes the product for its importation, sale, and use in China. Pet food must be packaged and labeled with Chinese labels that comply with the Pet Food Labeling Regulations, and the product's hygienic indicators must comply with the "Pet Feed Hygiene Regulations."

Table 1: Pet Food Regulatory Snapshot

Freyr provides services in a broad spectrum in the China market from chemical products to pet food. Product regulations vary depending on a market-to-market basis, where the following table in each area summarizes Regulatory classification and associate details required to drive market access in China.