CAS 77-92-9 · IECSC · People's Republic of China

Citric acid under IECSC

C6H8O7 · 柠檬酸

Status: Listed. Citric acid is on the IECSC public portion as a foundational industrial chemical. New-substance notification under MEE Decree No. 7 (2010) is NOT required. Citric acid is NOT on China's Catalog of Hazardous Chemicals and NOT on the Easily-Made Drugs Precursor Chemicals Catalog. China is the world's dominant producer (~75% of global citric acid capacity) led by RZBC, Weifang Ensign, COFCO Biochemical, and TTCA Co Ltd; the export-side regulatory layer is light, with the operator-relevant complexity sitting in destination-market AD/CVD compliance.

Citric acid is comfortably IECSC-listed and the export-side regulatory work is light. The operator-relevant complexity sits in producer-specific AD/CVD routing for destination-market compliance: the 4 dominant Chinese producers (RZBC, Weifang Ensign, COFCO Biochemical, TTCA) each carry distinct producer-specific AD/CVD margins in US and EU markets, and Sourzi-side practice tracks producer-specific routing for buyer-side cost optimisation. China dominates global supply (~75%) so the export side is structural; the documentation work is light but the AD/CVD intelligence is the binding constraint. 9% VAT rebate is structural margin support.

Listing and threshold

Substance Citric acid (CAS 77-92-9), C6H8O7
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 permit required.

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 1886.235-2016 specification applies for food-grade citric acid (national food standard)
  • GB 17514-2008 specification applies for industrial-grade citric acid
  • GACC export classification: HS 29181400

Restrictions and conditions of use

  • No Hazardous Chemicals Operation Permit required
  • No Easily-Made Drugs Precursor Permit required
  • Customs Inspection Order may apply for food-grade exports (sample-testing per GB 1886.235-2016)
  • No specific export-restriction or quota system applies
  • VAT export rebate currently 9% for citric acid (HS 29181400) per current bulletin

Importer obligations

For Chinese-origin citric acid exported abroad, no IECSC obligation falls on the foreign importer. The export-side documentation pack focuses on grade certification (food vs industrial), the 9% VAT rebate, and producer-specific export-routing for AD/CVD compliance in destination markets. China's 4 dominant producers (RZBC, Weifang Ensign, COFCO Biochemical, TTCA) each carry distinct producer-specific AD/CVD margins in US and EU markets; Sourzi-side practice tracks producer-specific routing for buyer-side cost optimisation.

Required documents

  • GACC export declaration with HS code 29181400
  • Food-grade certificate per GB 1886.235-2016 (where food-grade)
  • Industrial-grade certificate per GB 17514-2008 (where industrial-grade)
  • GHS-compliant SDS in Chinese (per GB/T 17519, brief, minimal hazards)
  • Producer-specific AD/CVD margin documentation (used by destination-market broker for entry filing)
  • Customs Inspection Order export-inspection certificate (where food-grade)

Common compliance traps

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

  • Producer-specific AD/CVD margins in US and EU markets create routing complexity: the Chinese exporter selects producer based on destination buyer's landed-cost preference
  • Calcium-citrate intermediate vs direct fermentation routes differ; some EU and US buyers spec one over the other
  • GACC sometimes blocks shipments if SDS is missing the Chinese-only fields (mainland-China emergency contact, GHS Chinese pictograms)
  • Food-grade vs industrial-grade pricing can differ by 30-50%; verify spec before invoicing
  • 9% VAT rebate is structural margin; verify rebate filing is complete on each shipment
  • Chinese citric acid vs cassava-derived alternatives (Thailand, Vietnam) compete on niche food-grade applications

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for citric acid, see the CAS 77-92-9 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the citric acid 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

Referenced in

6 pages across the Sourzi moat

This term shows up in 4 regulatory pages, 1 topic clusters, 1 CAS profiles. Sample backlinks per content type below.

Regulatory (4)

Plus 1 more regulatory pages.

Topic cluster (1)

CAS (1)

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.