China Repeals Regulations on Safe Management of Hazardous Chemicals: SDS Update Takes More Than a Name Change

At a Glance: Following the State Council's Decision on Amending and Abolishing Certain Administrative Regulations, the Regulations on the Safe Management of Hazardous Chemicals have been officially repealed. Regulatory oversight for hazardous chemical safety is now unified under the already effective Hazardous Chemicals Safety Law. For companies updating their SDS, simply swapping out the law's name in Section 15 is not enough. Verification of hazard classifications and protective measures, as well as downstream document supply chain alignment, must all be kept up to date. Furthermore, registration exemptions cannot be self-determined; companies must wait for official supporting implementation rules to be issued. CIRS advises businesses to take action across documentation, internal systems, and supply chain management.

On October 29, 2026, Premier Li Qiang signed State Council Decree No. 851, promulgating the Decision of the State Council on Amending and Repealing Certain Administrative Regulations. Adopted during the 99th Executive Meeting of the State Council on October 16, the decree took effect immediately upon publication.

The decree amends 14 administrative regulations and repeals four others—most notably the Regulations on the Safe Management of Hazardous Chemicals (the Regulations). After more than 20 years in force, China's foundational rule governing hazardous chemical supervision has officially passed into history. Consequently, all companies involved in the production, storage, use, distribution, and transport of hazardous chemicals must transition their compliance frameworks immediately.

Regulatory Shift: Supervision Now Anchored by the Hazardous Chemicals Safety Law

Promulgated in 2002, comprehensively revised in 2011 and amended again in 2013, the Regulations long served as the core framework for hazardous chemicals in China. The repeal comes as no surprise: the Hazardous Chemicals Safety Law of the People's Republic of China (the Safety Law), a higher-tier statute, has now fully taken over regulatory oversight.

As the first specialized law in China's hazardous chemicals safety field, the Safety Law contains 10 chapters with 127 articles. It was passed on December 27, 2025 at the 19th session of the Standing Committee of the 14th National People's Congress (Presidential Order No. 64) and took effect on 1 May 2026. It establishes comprehensive controls spanning facility planning, operational safety, registration, accident emergency rescue and legal liability.

By the time the Regulations were repealed, the Safety Law has already been in force for roughly six months, this repeal simply formalizes the sunset of the old framework rather than signaling a sudden shift to tighter enforcement.

Enterprises should not treat this repeal as a new grace period. Obligations for hazardous chemicals safety management have not been relaxed. Mandatory compliance under the Safety Law has been active since May 1, 2026. Additionally, Article 87 of the Safety Law delegates authority to the Ministry of Emergency Management (MEM)—acting alongside ministries responsible for industry and information technology, public security, environmental protection, agriculture, health, and customs—to draft specific registration exemption rules. Multi-agency enforcement is now explicitly mandated by statute. 

Key Impacts on Enterprises: SDS Updates and Hazardous Chemicals Registration

This update affects far more than just chemical manufacturers—importers, distributors, logistics providers, and industrial end-users are all covered. Document reviews must also go beyond Safety Data Sheets (SDSs): any references to the repealed Regulations in internal compliance lists, standard operating procedures, contracts, or vendor audit questionnaires must be updated. Two urgent priorities demand immediate attention:

1. SDS update: replacing the legal reference is only the start; content verification and transmission must follow.

• Replace references to the repealed Regulations in Section 15 with the Safety Law and active implementation rules. A name swap alone is not enough: key information such as hazard classification, precautionary statements and protective measures still needs to be verified item by item against current requirements to make sure nothing is outdated.
• The updated SDS need to be passed along the supply chain: manufacturers should proactively provide the new versions to downstream customers, and importers should obtain from upstream the versions based on current regulations;
• Where the same product has different SDS versions for different markets, the China-market version should be updated in step to prevent non-compliance penalties during customs or emergency management inspections.

2. Hazardous chemicals registration: Registration obligations apply equally to importers, and exemptions cannot be determined by enterprises.

Chapter 7 of the Safety Law establishes the registration system for hazardous chemicals - both manufacturers and importers are subject to the obligation, and imported hazardous chemicals must also be registered. While Article 87 outlines a registration exemption pathway for hazardous chemicals with low quantity, low release, and low exposure in R&D or trial production and trial sales, the specific criteria remain subject to forthcoming supporting measures from the Ministry of Emergency Management and related authorities. It should be noted that before those exemption measures are issued, choosing not to register on the grounds of R&D use or small quantities carries direct compliance risks.

CIRS Insights: A Three-Layer Response Covering Documents, Systems and the Supply Chain

CIRS suggests organizing the response across three layers: documents, management systems, and the supply chain.

1. Document layer: start with a sweep of regulatory citations. Search internal and external company documents using the Regulations as a keyword and build a to-be-updated list. Do the updating in two steps: first standardize the regulatory citations, then verify the substantive content of each document against the Safety Law. As for the ministerial rules made under the Regulations, their validity will be settled by the competent authorities' follow-up review, and enterprises need not presume it on their own;
2. System layer: run a gap analysis using the Safety Law as the index.Go through the Safety Law chapter by chapter, checking the validity of registration information, the match of licenses and permits, training records, storage conditions, and emergency plans; how R&D and trial production and sales scenarios are to be handled should be written into internal systems only after the supporting measures are clear;
3. Supply chain layer: keep the update in sync at both ends. Toward upstream suppliers, add the updated SDS to the required documents for procurement and supplier audits; toward downstream customers, proactively deliver the updated SDS and keep transmission records so that the documents in customers' hands are up to date as well.

What can CIRS Do for You

With years of experience in China's hazardous chemicals compliance field, CIRS offers the following services:

1. SDS review;
2. Hazardous chemicals registration;
3. Agency service for the 24-hour national chemical accident emergency consultation hotline;
4. Preparation of SDS and labels compliant with China GHS;
5. Data and classification retrieval for chemicals listed in the Catalog of Hazardous Chemicals.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

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