Six Departments Impose Emergency Controls on Two Precursor Chemicals!

On June 20, 2025, with State Council approval, China’s Ministry of Public Security, Ministry of Commerce, National Health Commission, Ministry of Emergency Management, General Administration of Customs, and National Medical Products Administration jointly announced the inclusion of 4-piperidone and 1-boc-4-piperidone into the List of Controlled Precursor Chemicals under the Regulations on the Administration of Precursor Chemicals. The controls take effect on July 20, 2025. This move aims to tighten management of precursor chemicals, prevent their diversion for illicit drug manufacturing, and underscores China’s commitment to fulfilling its obligations as a signatory to the UN Convention against Illicit Traffic in Narcotic Drugs.

Newly Controlled Substances

Control Requirements

Both substances are classified as Category II precursor chemicals under the Regulations. Their production, distribution, purchase, transportation, import, and export must comply with rules for non-pharmaceutical precursor chemicals.

China’s Precursor Chemical Control System

Precursor chemicals refer to state-controlled precursors, raw materials, and chemical reagents used in illicit drug production. China implements a categorized licensing system, governed by List of Controlled Precursor Chemicals, Catalog of Precursor Chemicals for Import/Export, Precursor Chemicals section of the Catalog of Dual-Use Items and Technologies. Updates to controlled lists take effect upon inclusion in the List of Controlled Precursor Chemicals.

Corporate Compliance Obligations

For non-pharmaceutical precursor chemicals:

• Import/Export

Obtain an Import/Export License for Dual-Use Items and Technologies from the Ministry of Commerce.

• Production/Distribution:

Class I: Apply for a production/distribution license from provincial Emergency Management authorities.

Class II/III: Apply for production/distribution filing with municipal Emergency Management authorities.

• Purchase:

Class I: Obtain a purchase license from provincial Public Security authorities.

Class II/III: Complete purchase filing with county-level Public Security authorities.

• Cross-City Transportation: Class I: Obtain a transport license from municipal Public Security authorities at the origin.

Class II: Obtain a transport license from county-level Public Security authorities at the origin.

Class III: Complete transport filing with county-level Public Security authorities at the origin.

Note

Products listed as precursor chemicals must also be checked against the Catalog of Hazardous Chemicals and other relevant lists to ensure full compliance.

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Further Information

MPS