Phenol under IECSC
C6H5OH · 苯酚
Status: Listed. Phenol is on the IECSC public portion as a foundational aromatic chemical. New-substance notification under MEE Decree No. 7 (2010) is NOT required. **Phenol IS on China's Catalog of Hazardous Chemicals** (skin corrosion + acute toxicity classification) AND on the **Highly Toxic Chemicals Catalog** (acute toxicity Cat 3 inhalation classification). Hazardous Chemicals Operation Permit IS required for production / storage / distribution AND Highly Toxic Chemicals Permit is required for handling and transport. China is largest global producer (~45% of global capacity, ~12 Mt/yr) led by Sinopec Yanshan, Mitsui-Sinopec joint ventures, Hangzhou Nanhua, Wanhua Chemical, Bluestar Chemical, Jiangsu Lihuayi.
Phenol is the heaviest-compliance Chinese-export substance in this regulatory dataset because it is on **BOTH** the Catalog of Hazardous Chemicals AND the Highly Toxic Chemicals Catalog (similar pattern to acrylonitrile, hydrogen cyanide, dimethyl sulfate). Public Security Bureau supervision drives traceability, training, and inventory-control requirements at every node in the export chain. 0% VAT export rebate reflects Beijing aromatic-petrochemical export-discouragement signal. China is largest global producer (~45% capacity, ~12 Mt/yr) led by Sinopec Yanshan, Mitsui-Sinopec joint ventures, Hangzhou Nanhua, Wanhua Chemical, Bluestar Chemical, Jiangsu Lihuayi. Acetone co-product fixed 1.6:1 ratio drives integrated plant economics. The downstream BPA cascade (~50% of phenol demand) creates structural medium-term demand-side regulatory uncertainty as EU and US BPA restrictions tighten.
Listing and threshold
| Substance | Phenol (CAS 108-95-2), C6H5OH |
|---|---|
| Regime | China Inventory of Existing Chemical Substances (IECSC), administered by the Ministry of Ecology and Environment (MEE) |
| Jurisdiction | People's Republic of China |
| Status | Listed |
| Tonnage threshold | No new-substance threshold applies. Hazardous Chemicals Operation Permit AND Highly Toxic Chemicals Permit required regardless of volume |
Classifications under this regime
- Listed in China's Catalog of Hazardous Chemicals
- **Listed in China's Highly Toxic Chemicals Catalog** (acute toxicity Cat 3 inhalation classification)
- NOT on the Easily-Made Drugs Precursor Chemicals Catalog
- NOT on the Explosives Precursor Catalog
- GB 339-2001 specification applies for industrial-grade phenol (Chinese national standard)
- GB 339-2001 covers minimum 99.5% purity (industrial-grade), free water, colour, distillation range
- GACC export classification: HS 29071100 (phenol)
- China is largest global producer (~45% capacity, ~12 Mt/yr); cumene-process accounts for ~95% of production capacity
- Acetone co-product fixed at 1.6:1 phenol-to-acetone ratio drives integrated plant economics
Restrictions and conditions of use
- **Hazardous Chemicals Operation Permit IS required** for any party producing, storing, or distributing phenol
- **Highly Toxic Chemicals Permit (高毒物品作业许可证) IS required** for handling under Highly Toxic Chemicals Catalog rules
- Hazardous Chemicals Road Transport Permit required for road shipment of bulk phenol
- Public Security Bureau (PSB) supervision applies to the Highly Toxic Chemicals chain (purchase / transport / storage / use traceability)
- Customs Inspection Order applies to export consignments
- No specific export-restriction or quota system applies (unlike urea / DAP fertilisers)
- VAT export rebate currently 0% for phenol (HS 29071100); historically variable, currently 0% reflecting Beijing aromatic-petrochemical export-discouragement signal
- GB/T 17519 Chinese-language SDS required for domestic distribution
- Highly Toxic Chemicals Catalog inclusion drives stricter inventory controls, traceability, and employee training requirements at handling facilities
Importer obligations
For Chinese-origin phenol exported abroad, no IECSC obligation falls on the foreign importer. The export-side documentation pack is the heaviest in this dataset to date because phenol is on **BOTH** the Catalog of Hazardous Chemicals AND the Highly Toxic Chemicals Catalog: producer must hold Hazardous Chemicals Operation Permit + Highly Toxic Chemicals Permit + Public Security Bureau supervision compliance. The export chain (producer → forwarder → port operator) requires permit chain through every node. Major Chinese producers (Sinopec Yanshan, Mitsui-Sinopec joint ventures, Hangzhou Nanhua, Wanhua Chemical, Bluestar Chemical, Jiangsu Lihuayi) routinely meet these requirements. 0% VAT export rebate reflects Beijing aromatic-petrochemical export-discouragement signal.
Required documents
- GACC export declaration with HS code 29071100
- Industrial-grade certificate per GB 339-2001 (minimum 99.5% purity)
- GHS-compliant SDS in Simplified Chinese per GB/T 17519-2013 (effective 31 January 2014, references UN GHS 4th revised edition; verify against the current version of GB/T 17519 at https://www.codeofchina.com/standard/GBT17519-2013.html) reflecting hazardous + highly toxic classification
- **Hazardous Chemicals Operation Permit chain documentation** (producer / forwarder / port operator)
- **Highly Toxic Chemicals Permit (高毒物品作业许可证) chain documentation**
- Hazardous Chemicals Road Transport Permit (where road-shipped from inland producers)
- Public Security Bureau supervision compliance documentation (purchase / transport / storage / use traceability)
- For destination markets requiring CBAM data (EU destination): verifier-attested embedded-emissions data for cumene-process route (potential CBAM Phase 2 inclusion post-2026)
Common compliance traps
The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.
- **Highly Toxic Chemicals Catalog inclusion is the dominant operational complexity for Chinese phenol** (heavier compliance burden than Catalog-only substances like sulfuric, methanol, HCl). Public Security Bureau supervision drives traceability, training, and inventory-control requirements at every node in the export chain
- 0% VAT export rebate reflects Beijing aromatic-petrochemical export-discouragement signal (similar to methanol pattern). Verify rebate filing on each shipment as schedules adjust
- Acetone co-product fixed 1.6:1 phenol-to-acetone ratio drives integrated plant economics; weak acetone markets compress phenol export pricing 10-15% over a quarter
- Major Chinese producers concentrated in coastal integrated petrochemical complexes: Sinopec Yanshan (Beijing), Mitsui-Sinopec Yangzi (Jiangsu), Hangzhou Nanhua (Zhejiang), Wanhua Chemical (Shandong / Fujian), Bluestar Chemical (Tianjin), Jiangsu Lihuayi (Jiangsu). Inland production is limited
- Chinese capacity additions 2024-2026 (Wanhua Yantai expansion, CNOOC-Shell Huizhou expansion, Hengyi Phase 2) extend Chinese capacity dominance from ~45% toward ~50%
- NOT in CBAM Phase 1 scope but potential Phase 2 candidate; cumene-process embedded-emissions data preparation is forward-looking for EU lane
- GACC sometimes blocks shipments if SDS is missing the Chinese-only fields (mainland-China emergency contact, GHS Chinese pictograms) or if Highly Toxic Chemicals permit chain documentation is incomplete
- BPA downstream demand cascade: BPA is ~50% of Chinese phenol demand; EU + US BPA regulatory pressure cascades to Chinese phenol producer pricing
Where to read next
For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for phenol, see the CAS 108-95-2 sourcing reference.
For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the phenol cornerstone hub covers the full sourcing chain.
For the structure and history of IECSC, see the IECSC glossary entry.
Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.
Read next
Cross-jurisdiction profile and sourcing references
Regulatory
Phenol under REACH
European Union listing status, classifications, importer obligations.
Regulatory
Phenol under TSCA
United States of America listing status, classifications, importer obligations.
Regulatory
Phenol under AICIS
Australia listing status, classifications, importer obligations.
Regulatory
Phenol under K-REACH
Republic of Korea listing status, classifications, importer obligations.
Glossary
IECSC, Inventory of Existing Chemical Substances in China
The Chinese national chemical inventory listing substances legally manufactured, imported, used, or sold in China before 2003. A substance not on IECSC requires a New Chemical Substance Notification (NCSN) under MEE Order 12 before it can be manufactured or imported into China. Functionally similar to TSCA in the US and REACH in the EU but with distinct procedural requirements.
Referenced in
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Free download
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