Read the list, destination and start date together

China's Ministry of Commerce, Ministry of Public Security, Ministry of Emergency Management, General Administration of Customs and National Medical Products Administration issued Announcement No. 40 on 22 September 2026. It adds two named substances—1-phenethyl-4-oxo-piperidine-3-carboxylic acid methyl ester and the corresponding ethyl ester—to Part I of the destination-specific controlled list. The announcement says the adjustment applies from its publication date.

Under the notice, exports of Part I listed chemicals to the United States, Mexico or Canada require a license under the temporary rules. Part II listed chemicals exported to Myanmar, Laos or Afghanistan also require a license. The notice says exports to other destinations need no license under this particular destination-specific measure; other applicable export, dangerous-goods, end-use and customs rules still need separate review.

Verify chemical identity beyond a broad product name

A supplier's sales description or an HS heading alone may not establish whether a substance matches the controlled list. Compare the exact chemical name, formula, CAS identifier where available, concentration, mixture status and Annex 1 wording with the official attachment. Have the exporter and its compliance professional resolve any synonym or derivative question before accepting a purchase order.

Record the export destination, consignee, end user and stated use consistently across the quotation, contract, shipping instructions and license application. A change from one country to another can change the licensing analysis under this notice. Do not reroute, relabel or split a shipment to avoid a control; ask the competent Chinese authority or qualified export-control counsel when identity or destination is uncertain.

Build an approval gate into procurement

Before paying a deposit or setting a shipment date for a potentially listed chemical, obtain written confirmation from the Chinese exporter about the official list entry, required license and lead time. Make the contract conditional on a lawful export license where required, and specify who supplies supporting product and end-use documents. Keep the official announcement and the version of the annex used for the decision.

This is a narrow export-control update, not a general ban on China's chemical exports. It does not determine the import licensing, sanctions, safety or registration requirements in the buyer's country. The buyer should check its own destination rules independently and avoid treating a supplier's previous shipment as proof that a new transaction is cleared.

Your next-order checklist

  • Compare the exact substance against Part I or Part II of the official Annex 1 list.
  • Apply the notice from 22 September 2026 and check the destination-specific rule.
  • Document consignee, end user and intended use; re-check if the route changes.
  • Obtain the required Chinese export license before committing to shipment where applicable.
  • Review destination-country import, safety and end-use requirements separately.

Sources & reference dates

  1. China Ministry of Commerce and four agencies — Announcement No. 40 of 2026Source published: 2026-09-22Effective: 2026-09-22

Prepared by the Yifeng Sourcing editorial team with AI assistance from the primary sources listed below. Source dates are recorded; destination-specific requirements should be reconfirmed before acting. This is not legal or tax advice.