What is the tonnage threshold for IECSC on hydrogen (h2)?

No new-substance threshold applies. Hazardous Chemicals Operation Permit required regardless of volume

CAS 1333-74-0 · IECSC · People's Republic of China

Hydrogen (H2) under IECSC

H2 · 氢气

Status: Listed. Hydrogen is on the IECSC public portion. **H2 IS on China's Catalog of Hazardous Chemicals** (Flam. Gas 1A + Press. Gas). Hazardous Chemicals Operation Permit IS required. NOT on Highly Toxic Chemicals Catalog. NOT on Easily-Made Drugs Catalog. **0% China VAT export rebate** (largely irrelevant due to bulk-trade constraint). China dominates global capacity (~30% of global H2 production capacity, ~40 Mt/yr) led by Sinopec, CNPC, Sinopec Yangzi, chlor-alkali co-product producers. **Chinese 14th Five-Year Plan + Hydrogen Industry Development Plan 2021-2035** drives green-hydrogen capacity expansion (Pilbara-style mega-projects emerging in Inner Mongolia + Xinjiang + Qinghai).

Hydrogen is comfortably IECSC-listed but IS on Catalog of Hazardous Chemicals. NOT on Highly Toxic. NOT on Easily-Made Drugs Catalog. **0% China VAT export rebate**. China dominates global capacity (~30%, ~40 Mt/yr) led by Sinopec, CNPC, chlor-alkali co-product producers. **Coal-gasification Chinese hydrogen carries highest embedded CO2** vs SMR + electrolysis alternatives; EU CBAM Phase 1 reshapes EU lane economics. **Chinese 14th Five-Year Plan + Hydrogen Industry Development Plan 2021-2035** drives green-hydrogen capacity expansion.

Listing and threshold

Substance	Hydrogen (H2) (CAS 1333-74-0), H2
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 required regardless of volume

Classifications under this regime

Listed in China's Catalog of Hazardous Chemicals
NOT on China's Highly Toxic Chemicals Catalog
NOT on the Easily-Made Drugs Precursor Chemicals Catalog
GB 3634-2006 specification applies for industrial-grade hydrogen (Chinese national standard)
GACC export classification: HS 280410 (hydrogen)
China dominates global capacity (~30% of global H2 production capacity, ~40 Mt/yr)
GB 6944-2012 dangerous-goods transport classification: Class 2.1 (flammable gas), UN 1049 (compressed) / UN 1966 (refrigerated liquefied)

Restrictions and conditions of use

**Hazardous Chemicals Operation Permit IS required**
Hazardous Chemicals Road Transport Permit required
**0% China VAT export rebate**
GB/T 17519 Chinese-language SDS required for domestic distribution
**Chinese 14th Five-Year Plan + Hydrogen Industry Development Plan 2021-2035** drives green-hydrogen capacity expansion

Importer obligations

For Chinese-origin hydrogen exported abroad, no IECSC obligation falls on the foreign importer. **H2 is structurally NOT internationally traded as compressed gas at scale**. Major Chinese producers: Sinopec, CNPC, chlor-alkali co-product producers (NaOH batch 1 + Cl2 batch 45 same producers), Sinopec Yangzi, industrial-gas vendors. **Chinese 14th Five-Year Plan + Hydrogen Industry Development Plan 2021-2035** drives green-hydrogen capacity expansion (Pilbara-style mega-projects emerging in Inner Mongolia + Xinjiang + Qinghai with abundant solar + wind + brine for electrolysis).

Required documents

GACC export declaration with HS code 280410
Industrial-grade certificate per GB 3634-2006
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)
Hazardous Chemicals Operation Permit chain documentation
GB 6944-2012 Class 2.1 dangerous-goods transport documentation

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

**0% China VAT export rebate**
Major Chinese producers: Sinopec, CNPC, chlor-alkali co-product producers, Sinopec Yangzi, industrial-gas vendors
Production routes: coal gasification (~70% Chinese capacity due to coal abundance + grey-hydrogen status), steam methane reforming SMR (~20%), chlor-alkali co-product (~5%), water electrolysis green-hydrogen (~5%, growing rapidly)
**Coal-gasification Chinese hydrogen carries highest embedded CO2** vs SMR + electrolysis-renewable alternatives; EU CBAM Phase 1 effective January 2026 reshapes EU lane economics structurally
**Chinese 14th Five-Year Plan + Hydrogen Industry Development Plan 2021-2035** drives green-hydrogen mega-project capacity expansion
Pilbara-style mega-projects emerging in Inner Mongolia + Xinjiang + Qinghai
**H2 is structurally NOT internationally traded as compressed gas at scale**; international trade via green-ammonia carrier (batch 37) emerging

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for hydrogen (h2), see the CAS 1333-74-0 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the hydrogen (h2) 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.

Cross-jurisdiction profile and sourcing references

Referenced in

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