New Hazardous Chemicals Safety Law Takes Effect May 2026

Effective May 1, 2026, the revised Hazardous Chemicals Safety Law introduces mandatory reclassification and documentation updates for potting compounds exported from China — particularly halogen-containing epoxy-based formulations widely used in power semiconductor and thermal management component encapsulation. Exporters, manufacturers, and logistics providers serving electronics, automotive, and industrial equipment supply chains must act now to align with new SDS and transport classification requirements.

Event Overview

The revised Hazardous Chemicals Safety Law enters into force on May 1, 2026. It explicitly classifies halogen-containing epoxy-based potting compounds — commonly applied in power semiconductor (Power Semi) and heat dissipation component encapsulation — under Category 3 (Flammable Liquids) or Category 8 (Corrosive Substances) of the UN Model Regulations. Exporters are required to: (1) assign updated UN identification numbers; (2) revise Section 14 (Transport Information) of Safety Data Sheets (SDS); and (3) submit declarations via the Customs ‘Hazardous Chemicals Export Declaration Verification System’ prior to shipment. Failure to comply triggers customs inspection and port detention.

Which Subsectors Are Affected

Direct Export Trading Companies

These firms face immediate operational impact because they bear legal responsibility for SDS accuracy and pre-shipment verification. Under the new law, customs clearance hinges on system-validated compliance — meaning incomplete or outdated SDS submissions will halt shipments before vessel loading.

Electronics Component Manufacturers (Power Semi & Thermal Management)

Manufacturers using halogenated epoxy potting compounds in final assembly are indirectly but significantly affected: their export-ready products may be deemed non-compliant if downstream suppliers (e.g., material vendors or contract packagers) fail to update classifications and SDS. This introduces traceability and audit risk across Tier-2 and Tier-3 supply tiers.

Chemical Formulators & Potting Compound Suppliers

Suppliers of epoxy-based potting compounds must reassess formulations against the new regulatory definition of hazardous chemicals. Those supplying halogen-containing variants must conduct UN classification testing, assign correct UN numbers, and issue revised SDS — not only for export batches but also for domestic distribution where classification cascades into labeling and storage obligations.

Logistics & Freight Forwarding Providers

Forwarders handling electronics-related cargo must verify SDS Section 14 content before tendering shipments to carriers. Misclassified or unverified consignments risk rejection by shipping lines or inland transport operators — especially those adhering to IMDG Code or ADR requirements aligned with China’s updated definitions.

What Relevant Enterprises or Practitioners Should Focus On and How to Respond

Confirm applicability through formulation review — not product name alone

Analysis shows that classification depends on halogen content and physical properties (e.g., flash point, pH), not generic naming like “epoxy potting compound.” Companies should cross-check raw material SDS and lab test reports against the law’s technical annexes before assuming exemption or category assignment.

Prioritize SDS revision and UN reclassification for high-volume export SKUs

Observably, the greatest near-term pressure falls on SKUs with recurring export destinations (e.g., EU, US, ASEAN). Firms should identify top 20 export SKUs by volume/value, initiate UN classification assessments, and draft updated SDS Section 14 — allowing time for internal validation and bilingual translation ahead of May 2026.

Integrate verification into existing export workflows — not as a standalone step

From industry perspective, treating the Customs ‘Hazardous Chemicals Export Declaration Verification System’ as an after-the-fact checkpoint invites delays. Instead, companies should embed SDS validation and UN number confirmation into order processing and document preparation stages — ideally linking to ERP or PLM systems for version control.

Engage customs brokers early on interpretation of borderline cases

Current more relevant than broad policy monitoring is clarifying gray areas — such as low-halogen formulations or cured-state vs. uncured-state classification — with licensed customs brokers familiar with both chemical regulations and local port practices. Early engagement helps avoid last-minute disputes during declaration submission.

Editorial Perspective / Industry Observation

This regulation is better understood as a procedural enforcement signal — not a substantive shift in hazard criteria. The law codifies existing UN GHS and IMDG frameworks into domestic statutory authority, tightening accountability rather than introducing novel hazard thresholds. Observably, its significance lies less in defining *what* is hazardous and more in mandating *how consistently and verifiably* classification data flows across the export chain. Industry attention should therefore focus on traceability infrastructure, not hazard reinterpretation. Continued observation is warranted for official guidance documents expected from MEE and GACC in Q1 2026 — particularly on transitional arrangements and small-batch exemptions.

Conclusion

The revised Hazardous Chemicals Safety Law marks a formalization of documentation rigor for potting compound exports — shifting compliance from voluntary best practice to legally enforceable process control. It does not redefine chemical hazards per se, but it does elevate the operational cost of non-standardized classification and fragmented SDS management. For affected stakeholders, the most pragmatic stance is to treat May 2026 not as a deadline, but as the start of sustained alignment with integrated chemical regulatory reporting across manufacturing, trade, and logistics functions.

Information Sources

Main source: Official text of the revised Hazardous Chemicals Safety Law, published by the Standing Committee of the National People’s Congress, effective May 1, 2026.
Additional reference: Public notice on implementation of the ‘Hazardous Chemicals Export Declaration Verification System’, issued jointly by General Administration of Customs (GACC) and Ministry of Ecology and Environment (MEE), 2025.
Note: Guidance documents clarifying classification methodology, transitional provisions, and SME accommodations remain pending and are subject to ongoing observation.