On 28 December 2023, six Ministries of China published an Announcement on the optimized management measures for specific products containing γ-butyrolactone. These management measures are scheduled to be effective on 1 January 2024.

What products are exempted from management measures?

• Photoresists, PI, diluents, photo-sensitive fluids, and anti-reflection coatings whose content of γ-butyrolactone is below 60% (including 60%) are exempted from import permits and certificates of domestic purchase and transportation records.
• Printing inks (including cleaning materials for ink cartridge) with γ-butyrolactone content below 20% (including 20%) are exempted from import and export licenses, and are not required to obtain certificates of domestic operation, purchase, and transport record.

What if a product is not among the above-mentioned ones, or if its concentration exceeds the specified limit?

If a product does not fall under the aforementioned product types, or a product meets the criteria but its concentration exceeds the specified limit, then this product will be identified as a mixture of precursor chemicals. In this case, it is necessary to obtain appropriate licenses in its production, operation, purchase, transportation, import, and export procedures.

Miscellaneous obligations

Enterprises should rise their compliance awareness and establish a safe management mechanism.  For example, enterprises should manage the storage, production, consumption, and scrapping of products. Records should be established and various management measures should be implemented. When applying for import and export customs clearance procedures, it is important to declare the content of γ-butyrolactone. Enterprises should fulfill their responsibilities and obligations. Moreover, competent authorities should reinforce their supervision and inspection of precursor chemicals especially in their import, export, production and transportation sectors. They should intensify the oversight of enterprise operations and prevent its illegal operations in compliance with laws and regulations. Legal responsibilities will be pursued in cases where suspected illegal and criminal activities are discovered.