Diammonium phosphate under IECSC
(NH4)2HPO4 · 磷酸二铵
Status: Listed. Diammonium phosphate is on the IECSC public portion as a foundational fertiliser. New-substance notification under MEE Decree No. 7 (2010) is NOT required. DAP is NOT on China's Catalog of Hazardous Chemicals (light hazard profile, dust only). DAP is NOT on the Easily-Made Drugs Precursor Catalog. China is the largest global DAP producer (~30% of global capacity, ~16-18 Mt/yr) led by Yunnan Yuntianhua, Guizhou Kailin Phosphate, Sinochem Lantian (Hubei), Hubei Yihua, and Wengfu Group. **Beijing operates a seasonal export-quota system on DAP** to manage domestic agricultural supply, similar to the urea export-license framework.
DAP is comfortably IECSC-listed and NOT on Catalog of Hazardous Chemicals so the export-side regulatory work is operationally light. The structural intelligence layer is destination-market specific: **EU CBAM Phase 1 from 1 January 2026** + EU 2019/1009 cadmium cap are the dominant EU-lane compliance and cost concerns. Beijing seasonal export-quota system + 0% VAT export rebate are domestic Chinese policy signals (food-security similar to urea pattern, distinct from organic-chemical 13% rebate). Major Chinese producers (Yunnan Yuntianhua, Guizhou Kailin Phosphate, Sinochem Lantian, Hubei Yihua, Wengfu Group) all draw on sedimentary phosphate-rock deposits with elevated cadmium content vs Russian / Moroccan igneous alternatives, which structurally disadvantages Chinese DAP in EU compliance and supports the CBAM cost differential. Brazilian SIPEAGRO is the largest single export-market regulatory framework alongside India MOP.
Listing and threshold
| Substance | Diammonium phosphate (CAS 7783-28-0), (NH4)2HPO4 |
|---|---|
| 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. No Hazardous Chemicals Operation Permit required (DAP is not on Catalog of Hazardous Chemicals) |
Classifications under this regime
- NOT 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/T 10205-2009 specification applies for industrial-grade DAP (Chinese national standard)
- GB/T 10205-2009 covers P2O5 minimum 46%, N minimum 18%, granule size, free water, hardness
- GACC export classification: HS 31053000 (DAP) or 31055100 (NPK with DAP base)
- China is largest global DAP producer (~30% capacity); Yunnan, Guizhou, Hubei are the main producing provinces, all served by sedimentary phosphate-rock deposits with elevated cadmium content vs Russian / Moroccan igneous deposits
Restrictions and conditions of use
- No Hazardous Chemicals Operation Permit required (DAP is not on Catalog of Hazardous Chemicals)
- No Easily-Made Drugs Precursor Permit required
- Customs Inspection Order may apply for export consignments
- **Beijing seasonal export-quota system**: phosphate fertiliser exports tightened during Chinese spring-application season (February to May) to ensure domestic agricultural supply. Quota allocation by GACC and MARA. Quasi-bans imposed 2021-2023 during global fertiliser-price spike
- VAT export rebate currently 0% for DAP (HS 31053000) per current bulletin (was reduced from 13% to manage exports during 2021-2023 supply crunch); verify before invoicing
- GB/T 17519 Chinese-language SDS required for domestic distribution
- Cadmium content monitoring under MARA (Ministry of Agriculture and Rural Affairs) quality-control programmes; sedimentary-rock-derived Chinese DAP carries higher Cd than igneous alternatives
- EU 2019/1009 Cd cap (60 mg/kg P2O5) is destination-market constraint that shapes Chinese export-market routing
Importer obligations
For Chinese-origin DAP exported abroad, no IECSC obligation falls on the foreign importer. The export-side documentation pack focuses on GACC export quota allocation (where seasonal restrictions apply), spec certificate per GB/T 10205-2009 (P2O5 minimum 46%, N minimum 18%), Chinese-language SDS, cadmium content certification (where destination market requires, especially EU 2019/1009 60 mg/kg P2O5 cap), and CBAM verifier-attested embedded-emissions data (for EU lane from 1 January 2026). Producer-specific phosphate-rock origin matters: Yunnan Yuntianhua, Guizhou Kailin Phosphate, Sinochem Lantian, Hubei Yihua, Wengfu Group all draw on sedimentary deposits with elevated Cd.
Required documents
- GACC export declaration with HS code 31053000
- Industrial-grade certificate per GB/T 10205-2009 (P2O5 minimum 46%, N minimum 18%, granule hardness, free water, dust)
- 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)
- GACC export quota allocation certificate (where seasonal export controls apply)
- Cadmium content certification (where destination market requires, especially EU 60 mg/kg P2O5 cap)
- Verifier-attested CBAM embedded-emissions data (EU destination from 1 January 2026)
- For Brazil destination: SIPEAGRO (Brazilian Ministry of Agriculture MAPA) registration certificate
Common compliance traps
The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.
- Beijing seasonal export-quota system on DAP is the dominant operational complexity. Quasi-bans 2021-2023 during global fertiliser-price spike disrupted Chinese-origin lanes; quota tightening continues during Feb-May spring-application season
- 0% VAT export rebate is a Beijing food-security signal (rebate was reduced from 13% to manage exports during 2021-2023 crunch), structurally similar to urea 0% rebate. Verify rebate filing on each shipment as schedules adjust
- Cadmium content of sedimentary-rock-derived Chinese DAP (Yunnan, Guizhou, Hubei) is structurally higher than Russian / Moroccan igneous alternatives. EU 2019/1009 60 mg/kg P2O5 cap is binding destination constraint; verify Cd content before invoicing EU lane
- CBAM Phase 1 from 1 January 2026 imposes EU-side embedded-emissions cost on Chinese DAP. Coal-fed Chinese ammonia (~1.5-2.5 tCO2e per tonne DAP) carries materially higher embedded CO2 vs Russian gas-fed alternatives
- Major Chinese producers: Yunnan Yuntianhua (Yunnan, integrated mine-to-DAP), Guizhou Kailin Phosphate (Guizhou, integrated mine-to-DAP), Sinochem Lantian (Hubei, integrated), Hubei Yihua (Hubei, integrated), Wengfu Group (Guizhou, integrated). Integrated mine-to-DAP cost structure gives ~10-15% cost advantage over merchant-phosphate-rock-fed competitors
- Beijing strategic phosphate reserve policy: Yunnan and Guizhou phosphate-rock deposits are designated strategic resources; export quota tightening tied to Chinese agricultural-supply-security framing
- Brazilian SIPEAGRO is destination-specific registration framework not seen in REACH / TSCA / IECSC / AICIS / K-REACH; Brazil is largest single Chinese DAP export market alongside India
Where to read next
For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for diammonium phosphate, see the CAS 7783-28-0 sourcing reference.
For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the diammonium phosphate 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
Diammonium phosphate under REACH
European Union listing status, classifications, importer obligations.
Regulatory
Diammonium phosphate under TSCA
United States of America listing status, classifications, importer obligations.
Regulatory
Diammonium phosphate under AICIS
Australia listing status, classifications, importer obligations.
Regulatory
Diammonium phosphate 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
4 pages across the Sourzi moat
This term shows up in 4 regulatory pages. Sample backlinks per content type below.
Regulatory (4)
Diammonium phosphate under REACH
European Union compliance profile for Diammonium phosphate.
Diammonium phosphate under TSCA
United States of America compliance profile for Diammonium phosphate.
Diammonium phosphate under AICIS
Australia compliance profile for Diammonium phosphate.
Plus 1 more regulatory pages.
Free download
Free PDF: the same MSDS verification template the Sourzi team uses to cross-reference factory documents against TSCA, REACH, AICIS, and CDR before booking.