What Should Enterprise Do after Filing of Imported Paints and Coatings Cancelled?

The Filing of Imported Paints and Coatings in China has been cancelled since 1 Mar. 2022. However, the cancel of filing of imported paints and coatings doesn’t mean that the national standards for harmful limits related to paints and coatings also lose effective. In fact, it is more important for related enterprises to do self-check after the abolishment of the filing of imported paints and coatings as the Customs will still spot-check the products. Besides, other regulations on imported paints and coatings still apply.

In order to help enterprises better know about what they should do, CIRS has summarized the frequently asked questions as follows:

Q: As there are so many regulations and national standards on paints and coatings, how do I distinguish them?

A: Standards named as GB XXX are mandatory national standards; Standards named as GB/T XXX are recommended national standards; while standards named as HJ XXX are environmental standards;

Q: If my company only involves in the import of paints and coatings, do I need to comply with all the relevant regulations and standards?

A: According to the current requirements, you should at least meet the limits of related harmful substances under the mandatory national standards. Please click here to know more about the standards.

Q: There are so many different kinds of paints and coatings, such as woodenware coatings, agricultural wall coatings and industrial protective coatings. However, as the classifications are not mentioned in the name of the products, how do I classify these products?

A: The naming and classification methods are given in GB/T 2705-2003 (Classification and Nomenclature for Coating Products). Basically, the products are classified based on their usage and the film former.

Q: What is VOC? I have only complied with the requirements of VOCs for the imported paints and coatings, is that enough?

A: VOC is the abbreviation for volatile organic compound. In China, VOC refers to the organic compounds that can participate in atmospheric photochemical reactions, or organic compounds that are determined by measurement or calculation according to the prescribed regulations.

Also, it is not enough to just meet the limits for VOCs for the imported paints and coatings. You still have to meet the limits of other harmful substances in the paints and coatings, such as the benzene, heavy metals and halogenated hydrocarbon, according to the requirements of the mandatory national standards.

To know more detailed information about the harmful limits of VOCs, please go to CIRS VOC Database.

Q: What kind of testing agencies are qualified to do the tests?

A: The tests should be done by testing agencies with CMA qualification. Besides, the tests must be conducted according to the testing methods recorded in the national standards.

Q: What kind of standards and regulations do I need to comply with?

A:

1. You need to provide the Chinese safety data sheets and labels complying with national standards to the Customs during importation;
2. If your products are classified as hazardous chemicals, you need to complete hazardous chemical registration before importation;
3. If your products contain new substances, you need to process new chemical substance registration before importation;
4. If your products fall in the scope of Catalog of Hazardous Chemicals (2015), you must apply for the Hazardous Chemicals Business License before importation;
5. If your products contain precursor chemicals, you must apply for Import License for Dual-use Items before importation.

Our Services

• Import Paints and Coatings Testing;
• Chinese GHS and Labelling;
• China Hazardous Chemical Registration;
• China New Chemical Substance Registration;
• Application of Hazardous Chemicals Business License;
• Application of Import License for Dual-use Items

If you have any needs or questions, please contact us at service@cirs-group.com.

Further Information

Filing of Imported Paints and Coatings Cancelled in China