1. Legal Basis

In February 2024, Shanghai Municipal Emergency Management Bureau and Shanghai Municipal Commission of Communications officially issued the Notice on Promoting the Information Management of Hazardous Chemicals Entry and Exit and Hazardous Goods Loading and Unloading Based on "One Enterprise, One Product with One QR Code", marking the official landing of the Shanghai one enterprise, one product, one code program. After the implementation of the program, it is planned that before December 31, 2024, the hazardous chemicals listed in the Catalogue of Hazardous Chemicals (including 88 items under entry 2828 of the Implementation Guide of the Catalogue of Hazardous Chemicals (2015 Edition) (Trial) ) circulating in Shanghai shall be assigned a traceability  code on the minimum outer package; for the warehouses storing hazardous chemicals that need permission, information transformation is required to be carried out, and the information of hazardous chemicals entering and exiting and inventory shall be submitted to the regulatory authorities in real time.

The main legal basis for the above notice is the Shanghai Measures for the Safety Management of Hazardous Chemicals. According to the Shanghai Measures for the Safety Management of Hazardous Chemicals, Article 19 (Entry and exit information): Enterprises producing and storing hazardous chemicals, enterprises obtaining safety licenses for hazardous chemicals and other units storing highly toxic chemicals and explosive-prone hazardous chemicals shall adopt electronic tags and other automatic identification technologies to realize the dynamic management of hazardous chemicals entering and exiting information. Hazardous chemicals safety regulatory authorities can obtain real-time information on hazardous chemicals inventory and warehousing according to regulatory needs.

2. Scope of Application

Products that need to provide traceable codes include products in entries 1 to 2827 and items 1 to 88 under entry 2828 of the Catalog of Hazardous Chemicals(2015 edition).

Products that are not mandatory to provide traceability codes include products that belong to entry 2828 of the Catalog of Hazardous Chemicals, but do not belong to items 1 to 88; mixtures that meet the 70% rule of the Catalog; chemicals that are not listed in the Catalogue and meet the definition of hazardous chemicals.

3. Situations Where Traceability Codes are Required

1. Within the city of Shanghai, involving the production, filling, sub-packing and replacement of labels of hazardous chemicals;
2. Involving the import of hazardous chemicals at Shanghai ports, circulating within Shanghai;
3. Chemicals produced or imported from other provinces and cities in circulation within Shanghai.

4. Situations Exempted from Providing Traceability Codes

1. Packaging specifications are less than 100g/mL (minimum packaging);
2. Bulk hazardous chemicals which are transported through pipelines or by ship;
3. Directly transported to other provinces and cities after import;
4. Directly transported to the enterprises within Shanghai after import.

5. Difference in Management Scope Between Traceability Code and Warehouse Management System

Although traceability code and hazardous chemicals warehouse management system are mainly for chemicals in the Catalog of Hazardous Chemicals, there are some differences, as shown in the following table:

6. Generation of Traceability Code

There are two ways to generate traceability code:

1. Through the free chemical traceability code generation platform provided by government departments, which needs to be filled in by manual operation;
2. Enterprises can also transform their own supply chain system and establish corresponding functional modules to achieve the function of generating traceability code.

7. Difference Between NRCC Safety Information Code and Traceability Code

Before generating traceability code, enterprises need to complete NRCC registration first. After obtaining NRCC safety information code, add batch, product specifications and other information, and fill in the name of the goods according to the requirements, whether it is imported dangerous chemicals, the number in the directory, the name of dangerous chemicals, whether it is a mixture, physical state, GHS classification, UN number, chemical structure, fire hazard type, and whether it is a highly toxic chemical, monitoring chemicals, special control of dangerous chemicals, focus on the supervision of dangerous chemicals and other content, can generate traceability code according to the corresponding rules (the above content of Catalog of Hazardous Chemicals 1-2827 can be generated automatically).

Therefore, the NRCC security information code is the pre-step of the traceable code. Using wechat, Alipay and other ways to scan the traceability code, the obtained information will be completely consistent with the scanning NRCC security information code. In addition, only by scanning the traceability code through the APP or small program developed by the Shanghai emergency department can the corresponding traceability operation be carried out.

8. Paste Method of Traceability Code

Traceability code should be pasted on the minimum outer packaging. If the product contains inner and outer packaging and involves outer packaging unboxing operation, it is recommended to paste both inside and outside. If the product does not involve outer packaging unboxing operation, it can be pasted on the outer packaging. Please see the figure below.

9. Compliance Obligations of Different Types of Enterprises

1. The main obligations involved in production enterprises are: to transform the warehousing system, and report the warehousing and inventory information of hazardous chemicals to the regulatory authorities in real time; after completing the registration of hazardous chemicals, generate and paste the corresponding traceability code according to the goods, batches and specifications; when making delivery, complete the warehousing and warehousing docking and report to the competent authorities.
2. The main obligations involved in enterprises with warehousing or storage facilities are: to transform the warehousing system, and report the warehousing and inventory information of hazardous chemicals to the regulatory authorities in real time; to receive the goods that have been pasted with traceable code upstream, and scan the code for warehousing operation. If the upstream has not pasted the traceability code, it is necessary to generate and paste the traceability code; when making delivery, complete the warehousing and warehousing docking and report to the competent authorities.
3. The main obligations involved in enterprises with warehousing or storage facilities are: to receive the goods that have been pasted with traceability code upstream, and scan the code for warehousing operation. If the upstream has not pasted the traceability code, it is necessary to generate and paste the traceability code; when making delivery, complete the warehousing and warehousing docking and report to the competent authorities. Scanning code receipt of hazardous chemicals, do not need to report through the hazardous chemicals login reporting system.
4. If the product has been pasted traceability code before customs clearance, it can be recommended as a white list enterprise for customs clearance, enjoying inspection exemption. Enterprises can also choose to paste in the warehouse; if the import is circulated in Shanghai, the traceability code needs to be pasted, and the warehouse reports the in and out information; if the goods are directly transported to other provinces and cities after customs clearance, there is no need to paste the traceability code, nor to report the in and out information; if the import is used as raw materials for the enterprise, there is no need to paste the traceability code, nor to report the in and out information, and the licensed enterprise reports the in and out information.
5. For products that meet the requirements of code assignment, overseas enterprises can consider generating the traceability code in advance before exporting the products to China, and pasting the traceability code in the appropriate position of the minimum outer packaging, and can enjoy the corresponding customs clearance facilitation measures.

10. FAQs

Q: Do cosmetics and consumer goods belonging to hazardous chemicals need to be pasted with traceability codes?
A: The traceability code is mainly for products within the scope of the license, cosmetics and consumer goods generally do not require a license, so there is no need to attach a traceability code.

Q: Does the production and use of raw materials stored in external warehouses need to paste the traceability code?
A: The production and use of the products of the enterprise are stored in the outer warehouse. If the data docking between the enterprise and the warehouse can be achieved, the raw materials temporarily stored in the outer warehouse in a very short time do not need to paste the traceability code.

About the inner package sticker code and the outer package sticker code
Whether you need to paste traceability codes on both the inner and outer packaging depends on whether there is an unpacking operation. If A product goes from enterprise A to enterprise B and from enterprise B to enterprise C, if the product goes from enterprise A to enterprise B without unpacking, the unpacking operation is performed from enterprise B to enterprise C. In this case, from enterprise A to enterprise B, the traceability code can be affixed to the outer package, and from enterprise B to enterprise C, the traceability code should be affixed to the inner package and the outer package.

About the batch number
Batch number is a virtual requirement, there is no need to forcibly associate production batches, its main purpose is to distinguish the same variety, the same specification, different time production of products, different time interval rules are determined by the enterprise.

Q: Do I need to paste the traceability code for the export of hazardous chemicals?
A: The traceability code is assigned to the source, for the hazardous chemicals produced in Shanghai, and the exported hazardous chemicals need to be pasted.

Q: Do I need to paste the traceability code when sending samples to customers for trial?
A: Depending on whether the enterprise involves the production and operation license, if the enterprise does not need the corresponding license, generally do not need to paste the traceability code.

Inventory Search:

Catalog of Hazardous Chemicals in China (2022)