What Documentation Is Required to Import Chemical Products from China?
Importing chemical substances and mixtures from China into the European Union is becoming an increasingly popular business model. However, chemical imports are subject to a wide range of regulatory obligations. On one hand, there are customs-related requirements, and on the other—the need to comply with EU chemical legislation. In this article, we will focus on the latter and outline the key obligations that rest with the importer.
Even if a product is labelled in accordance with Chinese regulations, this does not mean it complies with European requirements. Although China has implemented its own version of the GHS (Globally Harmonised System), it differs in several respects (not only linguistically) from the EU implementation. Below we present the most important elements of the required documentation and obligations that you must consider before placing a chemical product on the EU market.
Definition of Importer
Before discussing the importer’s obligations, it is useful to refer to the definitions of "import" and "importer" under EU legislation. Both the CLP Regulation and the REACH Regulation (which form the legal basis for most of the obligations discussed here) define these terms similarly:
Import
“Import: means the physical introduction into the customs territory of the Community.”
Importer
“Importer: means any natural or legal person established within the Community who is responsible for import.”
Most obligations under REACH and CLP apply at the point a chemical product is placed on the market. According to REACH:
Placing on the market
“Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market.”
This means that the moment a chemical product is physically introduced into the EU, it is considered to be placed on the market—and thus, all applicable obligations fall on the importer from that point.
1. Safety Data Sheet (SDS)
The Safety Data Sheet (SDS) is a fundamental document required for the import of chemical substances and mixtures. The importer must ensure that the SDS:
- is prepared in accordance with REACH Annex II (Regulation (EU) 2020/878),
- is available in the official language of the destination country (e.g., Polish),
- contains up-to-date information on classification, precautionary measures, PPE, and physical/chemical properties.
🔍 In practice: SDSs provided by Chinese manufacturers rarely meet EU requirements. In most cases, the SDS must be developed or adapted by a professional familiar with EU regulations.
2. CLP Classification and Labelling
Every chemical product placed on the EU market must be labelled in accordance with the CLP Regulation (EC) No 1272/2008. This means:
- classifying the product according to CLP criteria,
- preparing a label that meets CLP requirements,
- translating the label into the language of the destination country, where applicable.
❗ Note: Compliance with Chinese GHS-based labelling is not sufficient. Even if hazard pictograms appear on the label, other elements often fail to meet EU CLP standards. A new CLP-compliant label is typically required, along with additional labelling elements for specific product groups (e.g., detergents).
3. PCN Notification and UFI Code
If a chemical mixture is classified as hazardous due to its physical or health effects (e.g., flammability or sensitisation) and is placed on the EU market, the importer must:
- submit a Poison Centre Notification (PCN) in accordance with Article 45 of the CLP Regulation,
- generate and place a UFI (Unique Formula Identifier) on the label.
📌 In practice: A Chinese supplier cannot fulfil this obligation. The EU-based importer placing the product on the market must complete the notification.
4. Notification to the C&L Inventory
An importer of a hazardous substance (or in some cases, a substance in a mixture) must submit a notification to the Classification and Labelling Inventory (C&L) in accordance with Articles 39 and 40 of the CLP Regulation, unless the substance has already been registered or notified by another actor and the importer belongs to the same group of manufacturers and importers.
📝 This applies to both pure substances and substances in mixtures if they are hazardous and present above specified concentration thresholds.
5. REACH Registration
If you import a substance in quantities ≥ 1 tonne per year, you are required to register it under the REACH Regulation unless:
- a non-EU supplier has appointed an Only Representative (OR) who has registered the substance on your behalf and included your tonnage in their registration,
- the substance is exempt from the registration requirement.
⚠️ Important: Without registration, legal import of the substance is not allowed. Responsibility for compliance lies fully with the importer.
Summary: What Documents Do You Need?
Document / Obligation |
Applies to |
When Required |
| Safety Data Sheet (SDS) |
Substances and mixtures |
When conditions of Article 31 REACH are met (Read more) |
| CLP Labelling |
Substances and mixtures |
At the time of placing the product on the market |
| UFI Code & PCN Notification |
Hazardous mixtures |
Before placing on the market (Read more) |
| C&L Notification |
Hazardous substances |
Within 30 days of import (Read more) |
| REACH Registration |
Substances ≥1 tonne/year |
Must be completed before import begins; preparation may take several weeks |
What Does This Mean in Practice?
Importing chemicals from China is not just a matter of logistics or customs clearance. It requires full compliance with EU chemical legislation. Failure to meet these obligations may result in:
- detention of goods by customs authorities,
- administrative penalties,
- legal liability of the importer.
Before your first import, it’s advisable to consult a compliance specialist or arrange for a regulatory documentation audit. The obligations listed here represent the most common requirements, but depending on the product, additional specific obligations may apply.
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