Recently, triethanolamine has attracted the attention of many cross-border cosmetics merchants and importers in China. According to the regulations of the General Administration of Customs of the People’s Republic of China (GAC), cosmetics containing this ingredient can only be imported into China after they obtained the import & export license for dual-use items and technologies.
Triethanolamine, also known as tri (2-hydroxyethyl) amine, CAS No.: 102-71-6, is an organic compound. It can be used as emulsifier, humectant, humidifier, thickener and pH balance agent in cosmetics such as skin washing, eye glue, moisturizing, shampoo, etc. As one of the most commonly used emulsifier, it can make the cream product fine and white.
In addition to the applications in cosmetics and other daily necessities, triethanolamine can also be used to make chemical weapons. According to the List of All Types of MCCs issued by Ministry of Industry and Information Technology of the People’s Republic of China, MCCs can be divided into four categories. Category I to Category III MCCs are subject to the management of import & export license of dual-use items and triethanolamine belongs to the Category III MCCs, which can be used to produce nitrogen mustard poison gas.
Therefore, as a sensitive chemical that can be used as main ingredients for the production of chemical weapons, triethanolamine must be managed as “dual-use items”.
According to Article 6 of the Measures for the Administration of Import and Export Licenses for Dual Use Items and Technologies (Decree No. 29 of 2005 of the Ministry of Commerce and the GAC), import or export of dual-use items and technologies in any way, as well as transit, transshipment and transportation of dual use items and technologies, shall apply for import or export licenses for dual-use items and technologies.
As a result, imported cosmetics containing triethanolamine must obtain the import & export licenses for dual-use items and technologies.
If the concentration of triethanolamine in cosmetic products is quite low, do we still need to obtain an import or export license for dual-use items and technologies?
The answer is yes. In general, according to Article 57 of the Detailed Rules for the Implementation of the Regulations of the People’s Republic of China on the Administration of MCCs, when MCCs are lower than the certain concentration threshold, data declaration and import & export licensing can be exempted. However, the research on the exemption limit for triethanolamine is still under discussion, and the relevant documents have not yet been issued. Therefore, as long as your products contain triethanolamine, you must obtain the import license for dual-use items and technologies before importing the products into China.
How to apply for the import license of dual-use items and technologies?
According to Article 30 of the Detailed Rules for the Implementation of the Regulations of the People’s Republic of China on the Administration of MCCs, the import and export business of Category I MCCs, Category II and Category III MCCs and their production technologies and special equipment shall be operated by the designated units. Besides the designated units, no unit or individual shall engage in such import and export business.
CIRS Group warmly suggested enterprises to handle the import & export license of dual-use items and technologies for cosmetics containing triethanolamine in time, in case of any inconvenience in businesses.
If you have any needs or questions, please contact us at email@example.com.