On September 22, the Ministry of Commerce, the Ministry of Public Security, the Ministry of Emergency Management, the General Administration of Customs, and the National Medical Products Administration jointly issued Announcement No.40 of 2026, updating the "Management Catalogue of Precursor Chemicals Exported to Specific Countries (Regions)."
This marks the third revision of this catalog since last November. In less than a year, the number of countries subject to controls has expanded, the range of controlled product categories has continuously grown, and export compliance requirements for relevant goods are being rapidly tightened.
1、Newly regulated varieties
1-Phenylethyl-4-oxo-3-piperidinecarboxylate methyl ester
1-Phenylethyl-4-oxo-3-piperidinecarboxylate ethyl ester
The customs commodity code is 2933399075.
The revised table of contents retains a two-part structure:
Part 1 (United States, Mexico, Canada): 18 items, all of which are synthetic precursors for piperidine-and related fentanyl-like substances;
Part 2 (Myanmar, Laos, Afghanistan): 41 items, consisting of chemical agents for drug manufacturing.
The aforementioned categories of chemicals shall apply for an export license in accordance with the Provisional Administrative Provisions on the Export of Precursor Chemicals to Specific Countries (Regions), and customs clearance shall be processed based on the relevant customs documentation; however, for exports to other countries (regions), such an application for a license under these provisions is not required.
Special attention shall be paid to the fact that salts of the substances listed in Item 18 of Part I may also be subject to control; the announcement further clarifies that the trade name of a chemical shall prevail, while the customs commodity code shall serve only as a reference for customs clearance declarations.
2. Evolution of the Management Catalog
This "Chemical Management Catalogue" is by no means a new development. Its legal basis is a departmental regulation that has been in force for 21 years; the regulation itself underwent only one technical revision in 2015, whereas the two annexes— the Management Catalogue and the Catalogue of Specific Countries—published alongside the regulation, have undergone multiple rounds of revisions. To determine whether your products are subject to this regulation, it is first necessary to understand this evolutionary trajectory clearly.
August 2005: Regulations were established, and the targeted export license regime was implemented.
On August 11,2005, the Ministry of Commerce, the Ministry of Public Security, the General Administration of Customs, the State Administration of Work Safety, and the State Food and Drug Administration jointly promulgated the *Provisional Provisions on the Export of Precursor Chemicals to Specific Countries (Regions)* under Decree No.12 of 2005, which came into force on September 1, 2005.
The regulations establish three core requirements:
First is license management: exports to designated countries are prohibited without a valid license; upon export, the exporter shall present the export license to Customs for verification, and Customs shall then release the goods based on such verification.
The second measure is "one batch, one permit; one permit, one customs clearance," whereby the same contract may be exported in up to 12 batches;
Thirdly, regarding international verification, a license may only be issued after the application materials have been forwarded by the commerce and public security authorities to the competent government authorities of the importing country for confirmation of their lawful use.
The regulations include two annexes: Annex 1, "Management Catalogue of Precursor Chemicals Exported to Specific Countries (Regions)," lists 58 chemical varieties, covering ephedrine derivatives, ergot alkaloids, phenylacetone, acetic anhydride, toluene, diethyl ether, acetone, potassium permanganate, as well as precursor agents such as ammonium chloride and barium sulfate; Annex 2, "Catalogue of Specific Countries (Regions)," lists only Myanmar and Laos.
2006: Alignment with supporting regulations under the Regulations on the Administration of Chemicals Used in the Manufacture of Narcotics
On August 26,2005, State Council Decree No.445 promulgated the *Regulations on the Administration of Chemicals as Precursors*, which came into force on November 1, 2005, establishing a classified licensing regime for the chemicals listed in the annex to the Regulations.
On September 21,2006, the Ministry of Commerce promulgated the "Regulations on the Import and Export Management of Precursor Chemicals" under Order No.7 of 2006, which shall come into force 30 days after the date of promulgation. Concurrently, the "Catalogue of Precursor Chemicals Subject to Import and Export Management" was issued to implement global import and export licensing controls over the varieties listed in the annex to these Regulations; Article 54 of the Catalogue explicitly states that, in the event of any inconsistency between the "Provisional Regulations on the Export of Precursor Chemicals to Specific Countries (Regions)" and these Regulations, the latter shall prevail.
This establishes a two-tier management system: for the varieties listed in the annex to the regulations, certification is required for exports to all countries (or regions); for the 17 auxiliary agents—including ammonium chloride, barium sulfate, palladium chloride, sodium acetate, ethanol, and sodium hydroxide—supplementally listed under the regulations for countries where the toxic substances originate, certification is only required for exports to specific countries. This list of the 17 auxiliary agents has remained stable for a prolonged period thereafter.
August 2007: Afghanistan was added, bringing the number of designated countries to three.
On August 22,2007, the Ministry of Commerce, the Ministry of Public Security, the General Administration of Customs, the State Administration of Work Safety, and the State Food and Drug Administration jointly issued Announcement No.58 of 2007, titled "Announcement on Adding Afghanistan as a Specific Country for Export of Precursor Chemicals."
Afghanistan has since been included in Annex 2, the "List of Specific Countries (Regions)," with the list of specific countries expanded to include Myanmar, Laos, and Afghanistan—each corresponding to one of the two major drug production zones: the "Golden Triangle" and the "Golden Crescent." The export of chemicals listed in this annex to Afghanistan likewise requires the application for an export license and must undergo international verification. Since then, the scope of these three countries has remained unchanged for over a decade, in line with the 17-list of precursor chemicals.
October 2015: The regulation underwent its sole revision; the table of contents remained unchanged.
On October 28,2015, the Ministry of Commerce promulgated "Decision of the Ministry of Commerce on Amending Certain Regulations and Normative Documents" under Order No.2 of 2015, which came into force on the date of promulgation. In accordance with the requirements of the reform of the registered capital registration system, individual provisions of 29 regulations and normative documents were concurrently amended.
The *Provisional Administrative Regulations* have undergone technical revisions based on the foregoing, primarily affecting provisions concerning export application materials; however, core mechanisms—including license management, the "one batch, one license, one permit, one customs clearance" regime, and international inspections—remain unchanged, and the scope of product categories and the scope of specific countries outlined in the two annexes have also remained unchanged.
April 2024: For the first time in many years, the scope was significantly expanded, with the number of varieties increasing from 17 to 41.
On April 23,2024, the Ministry of Commerce, the Ministry of Public Security, the Ministry of Emergency Management, the General Administration of Customs, and the National Medical Products Administration jointly issued Announcement No.16 of 2024 of the Ministry of Commerce, entitled "Announcement on Adjusting the 'Catalogue of Precursor Chemicals Exported to Specific Countries (Regions),' " which shall come into force on May 1, 2024 (the issuing authorities have been reorganized under the Ministry of Emergency Management and the National Medical Products Administration in accordance with the institutional reforms of 2018).
The announcement provides a one-time additional listing of 24 chemical substances, including: hydrobromic acid, benzene, propionyl chloride, diphenylcarbonyl tartrate, potassium hydride, methylamine, cyclopentene, o-chlorobenzoyl chloride, dichloromethane, dichloroethane, hydrogen peroxide, sodium bromide, o-chlorocinnamyl chloride, chlorocyclopentane, ethyl benzoate, cyclohexane, aluminum chloride, xylene, sodium hydride, tartrate, bromocyclopentane, magnesium (those classified as dual-use items shall be subject to export control regulations), brominated o-ketone, and chlorosulfone (sulfonyl chloride).
The number of chemical products included in the catalog has increased from 17 to 41; the applicable countries remain Myanmar, Laos, and Afghanistan. The announcement further specifies that exporters of the chemicals listed in the catalog to the aforementioned three countries shall apply for a permit in accordance with the *Provisional Administrative Regulations*; however, exporters to other countries (or regions) are not required to apply under such regulations.
November 2025: Add the United States, Mexico, and Canada; split the catalog into two parts.
On November 10,2025, the Ministry of Commerce, the Ministry of Public Security, the Ministry of Emergency Management, the General Administration of Customs, and the National Medical Products Administration jointly issued Announcement No.73 of 2025 of the Ministry of Commerce, entitled "Announcement on Adjusting the 'Management Catalogue of Precursor Chemicals Exported to Specific Countries (Regions)' and the 'Catalogue of Specific Countries (Regions),' " which shall come into force as of the date of issuance.
At the national level, Annex 2, "List of Specific Countries (Regions)," has been updated to include the United States, Mexico, and Canada, thereby increasing the number of specific countries from three to six.
Regarding the directory structure, the management directory in Annex 1 has been divided for the first time into two parts: the first part comprises 13 specific fentanyl-related precursors newly added for the US-Mexico-Canada region, including 1-ethoxycarbonyl-4-piperidone, 1-benzyloxycarbonyl-4-piperidone, 1,4-dioxo-8-N-azaspiro[4.5]decane, 1-acetyl-4-piperidone, various 4-anilino-piperidine and 4-piperidone derivatives, among other piperidine compounds; the original 41 excipients have been consolidated into the second part, which continues to apply to Myanmar, Laos, and Afghanistan.
The licensing rules are accordingly divided into two categories: for exporting the first category of products to the United States, Mexico, and Canada, and for exporting the second category of products to Myanmar, Laos, and Afghanistan, an export license must be applied for in accordance with the *Provisional Administrative Regulations*; however, exports to other countries (or regions) are not subject to this requirement.
May 2026: Three new items were added to the first part, bringing the total to 16 items.
On May 22,2026, five government departments jointly issued Announcement No.6 of 2026 of the Ministry of Commerce, titled "Announcement on Adjusting the 'Management Catalogue of Precursor Chemicals Exported to Specific Countries (Regions),' " which shall come into force as of the date of issuance.
In Part I, three new substances have been added: 4-hydroxypiperidine and its carbamate, amide, and sulfonyl derivatives, as well as 1-tert-butoxycarbonyl-4-oxo-3-piperidinecarboxylic acid methyl ester and 1-tert-butoxycarbonyl-4-oxo-3-piperidinecarboxylic acid ethyl ester. The number of items in Part I has increased from 13 to 16, while the number of items in Part II remains unchanged at 41.
September 2026: An additional 2 items will be added to the first part, bringing the total to 18 items (as per this adjustment).
On September 22,2026, five government departments jointly issued the Ministry of Commerce's Announcement No.40 of 2026, which shall come into force as of the date of its issuance.
In Part I, two additional varieties—methyl 1-phenylethyl-4-oxo-3-piperidinecarboxylate and ethyl 1-phenylethyl-4-oxo-3-piperidinecarboxylate (both with Customs Code 2933399075)—have been included, thereby increasing the number of items in Part I from 16 to 18; in Part II, the 41 items remain unchanged, with only technical updates applied to specific Customs Codes in accordance with the annual tariff schedule. Part I further specifies that any salts of the 18 listed substances may also be subject to control.
In summary: over the past 21 years since its implementation, the regulatory framework has remained generally stable, with changes concentrated in two annexes—specifically, the number of designated countries has increased from 2 to 6; and the scope of regulated substances has expanded from the initial 17 supplementary excipients to the current two-part structure—comprising 18 substances under "Part I" and 41 substances under "Part II," totaling 59 substances. In the past year alone, the framework has been revised three times, all of which introduced new provisions targeting fentanyl precursor chemicals for the U.S.-Mexico-Canada corridor.
3. Product Export Red-Line Assessment Checklist
At the regulatory level, targeted exports are subject to licensing management. When applying for such exports, applicants must submit either a legal use certificate issued by the competent authorities of the importing country (or region), or a guarantee document confirming the lawful use by the importing party; these applications shall then be referred by the Ministry of Public Security to the competent authorities of the importing country for international verification. For key regions with high drug prevalence—such as Myanmar, Laos, Afghanistan, the United States, Mexico, and Canada—the verification threshold is exceptionally high, and in practice, such export applications are generally denied.
Therefore, once a commodity matches the catalog and the destination country falls within the aforementioned six countries, the appropriate course of action is to refrain from quoting prices, signing contracts, or arranging shipment. Similarly, the following three points warrant particular attention:
1. Avoid detours via ports of entry, transit zones, and special regulatory zones
Where goods are transshipped or transited through a third country (or region), or where the end user or the actual final destination is located within any of the six aforementioned countries, such transactions may likewise be deemed as exports to a specific country.
Where goods listed in the export catalog of the aforementioned countries are exported from customs special supervision zones—such as bonded zones or export processing zones—or from bonded premises, these provisions shall apply pursuant to Article 15 of the relevant regulations; false declaration or concealment of the product name, or the mixing of controlled goods with ordinary goods for shipment, shall constitute serious violations subject to strict investigation and punishment.
2. Analysis of salts, derivatives, and mixtures
In Part I, the potential salts of the 18 substances are also included under control; several entries further encompass derivatives such as amides, carbamates, halogenated compounds, sulfonamides, as well as combined derivative forms.
For mixtures or admixtures containing listed substances, the relevant chemical contents shall be converted for assessment; such products shall not evade regulatory requirements by being labeled as "mixtures"; for compound pharmaceutical preparations and other cases expressly excluded by law, the relevant provisions shall apply.
3. Beware of "mass-market" products
Among the 41 items in Part II, there are numerous common chemical products, such as sodium bicarbonate (baking soda), sodium carbonate (washing soda), ethanol, acetic acid, ethyl acetate, isopropanol, activated carbon, hydrogen peroxide, xylene, magnesium, etc. The more commonplace and widely used a product is, the greater the likelihood that it will be overlooked during the quotation and document review stages.
