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

On 29 October 2026, Premier Li Qiang signed State Council Decree No. 851 to promulgate the Decision of the State Council on Amending and Repealing Certain Administrative Regulations, which was deliberated and adopted at the 99th executive meeting of the State Council on 16 October 2026 and takes effect on the date of promulgation. The Decision amends 14 administrative regulations and repeals 4, with the Regulations on Safe Management of Hazardous Chemicals (the "Regulations") among those repealed. After more than 20 years in force, this core administrative regulation for hazardous chemicals supervision has passed into history, and the compliance basis for enterprises engaged in the production, storage, use, distribution and transport of hazardous chemicals has shifted accordingly.

Regulatory Update: Supervisory Basis Has Shifted to the Hazardous Chemicals Safety Law

Promulgated in 2002, comprehensively revised in 2011 and amended again in 2013, the Regulations long provided the foundational institutional framework across all business stages of hazardous chemicals. The repeal comes as no surprise: the Hazardous Chemicals Safety Law of the People's Republic of China (the "Safety Law"), the legislation superior to the Regulations, has completed the takeover of the regulatory framework as a whole.

As the first specialized law in China's hazardous chemicals safety field, the Safety Law contains 10 chapters and 127 articles. It was passed at the 19th session of the Standing Committee of the 14th National People's Congress on 27 December 2025 (Presidential Order No. 64) and took effect on 1 May 2026, covering planning and layout, safety management at each stage, registration, accident emergency rescue and legal liability. By the time the Regulations were repealed, the Safety Law had already been in force for about half a year, so this adjustment is better seen as the closing step after the new law's entry into force than as the beginning of tighter regulation.

Enterprises should not treat the repeal as a new grace period. Obligations for hazardous chemicals safety management have not been relaxed; since the day the Safety Law took effect, the basis for compliance has been the law itself. In addition, Article 87 of the Safety Law vests the power to formulate the specific measures for registration exemption in the emergency management department under the State Council, acting in conjunction with the authorities for industry and information technology, public security, ecology and environment, agriculture and rural affairs, health and customs, which makes multi-department coordinated supervision explicit at the statutory level.

Key Impacts on Enterprises: SDS Updates and Hazardous Chemicals Registration

Those affected go beyond hazardous chemicals manufacturers, as importers, warehousing and logistics providers, distributors and users are all covered. Document-level screening is not limited to SDS either: wherever the Regulations are cited, whether in internal regulatory lists, workplace operating procedures, purchase and sales contracts or supplier audit questionnaires, the references should be addressed as well. Two tasks are the most urgent:

1. SDS update: replacing the legal reference is only the start; content verification and transmission must follow. Section 15 of the SDS should no longer cite the Regulations; the reference should be replaced with the Safety Law and the supporting regulations currently in force. 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. Updated SDS also need to be passed along the trade 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 citations in the China-market version should be updated in step. For historical versions still citing the Regulations, prompt screening and replacement are recommended to avoid being caught unprepared in inspections by emergency management or customs authorities.

2. Hazardous chemicals registration: importers are equally obligated, and exemption is not for enterprises to self-determine. Chapter 7 of the Safety Law establishes the registration system for hazardous chemicals; both manufacturers and importers are subject to the obligation, so imported hazardous chemicals must also be registered. Article 87 opens a registration exemption pathway for hazardous chemicals with low quantity, low release, and low exposure in research and development or trial production and trial sales, but the specific conditions are to be set by supporting measures formulated by the emergency management department under the State Council together with the relevant authorities. Before those measures are issued, choosing not to register on the grounds of R&D use or small quantities carries direct compliance risk.

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

ChemRadar 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.

CIRS Services

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.

Further information

Gov.