Background

Effective Sept. 1 China will add the following substances to its precursor chemicals list and impose restrictions on the export, production, sale, purchasing, and transportation of these substances.

Product description

CAS

China HS code

4-AP

23056-29-3

2933.39.9073

1-boc-4AP

125541-22-2

2933.39.9073

Norfentanyl

1609-66-1

2933.39.9073

Cannabidiol or CBD

13956-29-1

2907.29.9020

BMK glycidic acid and its esters

25547-51-7

2918.99.0042

3-oxo-2-phenylbutanoic acid and its esters

4433-88-9

2918.30.0021

PMK glycidic acid esters

-

2932.99.9093

These restrictions could impact companies in the U.S. pharmaceutical, life science, and chemical industries that rely on importing these substances from China and their Chinese subsidiaries. For example, an export license from the Ministry of Commerce will be needed to export these substances.

U.S. importers should review their imports from China of chemicals that contain these substances, assess the potential impact of this change on their operations, and determine if their Chinese subsidiaries are impacted. ST&R can assist in these efforts by (1) working with Chinese exporters to facilitate the proper license application process and ensure compliance with applicable China Customs regulations, (2) conducting compliance checks on Chinese subsidiaries to assess local risks, and (3) providing further guidance on additional requirements if these substances are intended for medical use.

For more information, please contact Xiaofeng Xu at (852) 2603 9350 or via email.

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Xiaofeng Xu
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