On 6 June 2023, the Ministry of Commerce issued the announcement of the Catalogue of Banned Imported Goods (Eighth Batch) and the Catalogue of Banned Exported Goods (Seventh Batch), announcing the relevant products banned for import and export in China, which has been continuously updated to the eighth batch of the product list since the State issued the first batch of the Catalogue of Banned Imported and Exported Goods in 2001.

The “Catalogue of Prohibited Imports & Exports”, as the name implies, is a list of goods that the state requires not to be imported or exported. On the one hand, it forms a clear restriction on the enterprises that operate imports and exports, and on the other hand, it reflects China’s attitude towards international trade in special chemicals.

Regarding the catalogue of banned chemicals, a total of 16 chemical products are involved, such as products containing chlorinated biphenyls, polybrominated diphenyl ethers, waste oils, chemical wastes (both primary and secondary), carbon tetrachloride, related chloroethane and other pharmaceutical intermediates. From the catalogue of banned chemicals, the following directions can be seen:

Firstly, chlorine-containing aromatic compounds are an important import restriction. The catalogue does not explicitly give specific names to chemicals that are present in the nature of mixtures containing PCBs or hexabromobiphenyl, mixtures containing tetra-, penta-, hexa- or heptabromobiphenyl ethers, which is on the one hand a mixture status, and on the other hand, compounds containing chlorine and benzene, which may be partially restricted in terms of customs declaration for export or because of the key words chlorine and benzene in the name of the goods.

It is also clear from this aspect that key words such as “chlorine” and “benzene” are subject to certain restrictions on import.

Secondly, the words mixture, waste, waste oil and other such words are among the types of goods whose import is strictly prohibited. As can be seen from the list of banned imports, there are multiple compounds, which are products containing the words “mixture”, “waste oil”, “waste”, “recycled The words “mixture”, “waste oil”, “waste”, “recycled”, etc., where mixtures may be equated with waste, and chemicals in a mixed state equated with primary processing, or by-products, are subject to explicit import restrictions in China.

Thirdly, the import of highly volatile chlorine-containing compounds, such as carbon tetrachloride and trichlorodifluoroethane, is prohibited. These products have been labelled as “highly volatile” and “highly environmentally polluting”, and may cause serious environmental pollution in the course of use, so they are banned from import.

Regarding the list of chemicals banned for export, a total of 21 categories of chemicals are covered, of which 16 categories belong to the list of explicit chemical names and the rest to the list of broad types of chemicals. From the list of chemicals banned for export, the following directions can be seen:

First, the list of chemicals for export is mostly focused on pesticides and pesticide intermediate products. Among them, such as chlordane, mirex, hexachlorobenzene, DDT, chlordecone, etc. These products, mostly pesticides and pesticide intermediates, are on the list of chemicals banned for export from China.

These chemicals are restricted from export because of the environmental impact of the export process. These products are highly polluting and have a certain degree of pollution to marine organisms and agricultural crops, so safety considerations during transportation are the main reason for restricting their export.

Secondly, compounds containing fluorine, bromine and chlorine are the main types of chemicals that are restricted from import. These include, for example, chlordane, pentachlorobenzene, chlordecone, hexachlorocyclohexane, tetrabromodiphenyl ether, pentabromodiphenyl ether, hexabromodiphenyl ether, heptabromodiphenyl ether, ,1,1-trichloro-2,2-bis(4-chlorophenyl)ethane, heptachlor, etc. These products are highly polluting, especially to the environment and to plants and animals.

Many of these banned products are already banned from production and trade within China, and a few are banned from production and import/export globally, in large part because of the serious environmental pollution they cause when dissolved in water.

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