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China Eases Trade Controls on Low-Concentration Triethanolamine Products, Effective January 2025

On December 17, 2024, the Ministry of Industry and Information Technology, the Ministry of Commerce, and the General Administration of Customs jointly issued the "Notice on Optimizing the Import and Export Supervision Measures for Low-Concentration Triethanolamine Mixtures (2024 Edition)." This notice exempts certain low-concentration triethanolamine products from the control of chemicals subject to supervision and control and dual-use items. The notice will officially take effect on January 1, 2025.

Exempted goods include:

  1. Non-medical disinfectants, synthetic detergents, cosmetics, inks, etc. (see Attachment 1 at the end of the document for a list of triethanolamine-containing goods not subject to control).
  2. Goods containing triethanolamine concentrations of less than 10% (inclusive), other than aqueous solutions of triethanolamine alone (see Attachment 2 at the end of the document for a list of related goods with triethanolamine concentrations of less than 10% inclusive).

Specific measures include:

  1. Goods listed in Attachments 1 and 2, which have low concentrations of triethanolamine and controllable proliferation risks, are not subject to the "Regulation of the People's Republic of China on the Administration of Chemicals Subject to Supervision and Control," the "List of Various Chemicals Subject to Supervision and Control," the "Regulation of the People's Republic of China on the Export Control of Dual-use Items," and the "List of Dual-Use Items Subject to Export Control of the People's Republic of China." They are not considered controlled items under triethanolamine (customs commodity code 2922150000) and triethanolamine mixtures (customs commodity code 3824999950) in the "Catalogue of Dual-Use Items and Technologies Subject to Import and Export License Administration," and thus do not require the "Approval Document for the Import and Export of Chemicals Subject to Supervision and Control" or the "Export License for Dual-Use Items and Technologies."
  2. For goods listed in Attachment 2, when declaring imports and exports to customs, it is necessary to accurately declare the percentage by mass of free triethanolamine in the goods, i.e., the concentration of triethanolamine, in the specifications and models section of the customs declaration form.

ChemRadar Insights

  1. If a company's import and export products contain triethanolamine and are not within the exempted range mentioned above, it is important to note that they must be managed in accordance with the "Regulation of the People's Republic of China on the Administration of Chemicals Subject to Supervision and Control" and the "Regulation of the People's Republic of China on the Export Control of Dual-use Items." The company must obtain the "Approval Document for the Import and Export of Chemicals Subject to Supervision and Control" and the "Export License for Dual-Use Items and Technologies."
  2. If a company imports or exports aqueous solutions of triethanolamine alone, regardless of the concentration, it is required to obtain the "Approval Document for the Import and Export of Chemicals Subject to Supervision and Control" and the "Export License for Dual-Use Items and Technologies."

 

Attachment

Notice on Optimizing the Import and Export Supervision Measures for Low-Concentration Triethanolamine Mixtures (2024 Edition)

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