CAS 7647-01-0 · IECSC · People's Republic of China

Hydrochloric acid under IECSC

HCl · 盐酸

Status: Listed. Hydrochloric acid is on the IECSC public portion as a foundational industrial chemical; produced both as a primary product and as a by-product of chlor-alkali, PVC, and TDI/MDI manufacture. New-substance notification under MEE Decree No. 7 (2010) is NOT required. HCl is on China's Catalog of Hazardous Chemicals (2015 edition) and on the more restrictive Easily-Made Drugs Precursor Chemicals Catalog (《易制毒化学品管理条例》 Category 3); domestic distribution requires the corresponding precursor permit chain.

HCl is comfortably IECSC-listed but the Easily-Made Drugs Precursor Catalog Category 3 listing adds the Public Security Bureau permit chain on top of the standard hazardous-chemicals permit chain (same overlay as sulfuric). China is structurally net-positive on HCl because of PVC and chlor-alkali by-product, so the merchant-acid export market is structurally low-margin and competes with by-product disposal economics. Specialty grades (electronic, pharmaceutical, semiconductor) are the export-volume drivers, not bulk technical-grade.

Listing and threshold

Substance Hydrochloric acid (CAS 7647-01-0), HCl
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. General hazardous-chemical handling permits and the precursor-chemicals registration apply above MIIT / MEE / Public Security Bureau thresholds.

Classifications under this regime

  • Listed in China's Catalog of Hazardous Chemicals (《危险化学品目录》, 2015 version)
  • Hazard category: Class 8 corrosive (UN 1789 solution) or Class 2.3 toxic gas plus Class 8 (UN 1050 anhydrous gas) in domestic GB labelling
  • GB 30000.5-2013 GHS: Skin Corr. 1B, STOT SE 3, Met. Corr. 1; gas form adds Acute Tox. 3 inhalation
  • NOT on the China State Council's Highly Toxic Chemicals Catalog (《剧毒化学品名录》)
  • Listed on the Easily-Made Drugs Precursor Chemicals Catalog (《易制毒化学品管理条例》) Category 3: methamphetamine precursor controls (same as sulfuric)

Restrictions and conditions of use

  • Hazardous Chemicals Operation Permit (危险化学品经营许可证) required for distributors and end-users
  • Hazardous Chemicals Storage Approval required for storage above 1 t in single facility
  • Easily-Made Drugs Precursor Permit (易制毒化学品购销备案证明) required for purchase and sale of bulk HCl; Public Security Bureau handles registration
  • Concentrations >32% trigger additional Public Security Bureau monitoring on transactions
  • No specific export-restriction or quota system applies; 0% VAT export rebate per current bulletin (down from 9% in earlier years)

Importer obligations

For Chinese-origin HCl exported abroad, no IECSC obligation falls on the foreign importer. For inbound HCl imports into China (rare; China is structurally net-positive HCl from PVC by-product), the Chinese importer must verify IECSC listing and hold the Hazardous Chemicals Import Filing at the destination customs port. Sourzi-side practice: IECSC compliance is verified via GACC databases and built into the export documentation pack; the precursor-permit chain on the Chinese side is the documentation hot-spot, same workstream as sulfuric acid.

Required documents

  • GACC export declaration with HS code 280610
  • 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)
  • Manufacturer's Hazardous Chemicals Operation Permit copy
  • Easily-Made Drugs Precursor Permit copy from manufacturer (used by export-side broker for verification)
  • Test certificate (合格证) for grade verification (technical, food, pharmaceutical, electronic, semiconductor)

Common compliance traps

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

  • Easily-Made Drugs Precursor Catalog Category 3 listing means the Public Security Bureau is in the chain: manufacturer, distributor, and export-broker handovers all need permit verification (same as sulfuric)
  • 0% VAT export rebate (down from 9% historically) makes the China-export economics tighter; China is a net producer because of PVC and chlor-alkali by-product but exports are structurally low-margin
  • Anhydrous HCl gas (UN 1050) tube-trailers are a separate logistics category from aqueous HCl solution (UN 1789) bulk-tankers
  • Pharmaceutical-grade and electronic-grade HCl command premium pricing 5-10x technical grade; verify spec before invoicing
  • GACC sometimes blocks shipments if SDS is missing the Chinese-only fields (mainland-China emergency contact, GHS Chinese pictograms)

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for hydrochloric acid, see the CAS 7647-01-0 sourcing reference.

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

Referenced in

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