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SIYANG RODENTICIDE FACTORY, CHINA

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Synthesis of Bromadiolone, Brodifacoum, Difenacoum

BRODIFACOUM

  • Brodifacoum Technical Material 98%
  • China MOA Reg. No.: PD20070323
  • The most potent ‘super-warfarin’ rodenticide, ideal for controlling larger pests, features a complex 8-step synthesis process.

BROMADIOLONE

  • Bromadiolone Technical Material 98%
  • China MOA Reg. No.: PD20070322
  • The most widely used 2nd-generation anticoagulant rodenticide, a 4-step manufactured coumarin derivative.

DIFENACOUM

  • Registered Difenacoum Intermediate
  • C22H20O, CAS 56181-66-9, Purity: 99.5%
  • Synthesized in the same manner as Brodifacoum without the Bromine in initiation, ecologically safer for birds.

License as Extremely Hazardous Chemicals

National Legislation & Ministerial Regulations
  • China Hazardous Chemical Regulation (National Legislation, 2002 & 2011)
    On Feb. 16, 2011, the State Council of China approved an amendment to the “Regulation on the Safety Management of Hazardous Chemical” – known as the State Decree No. 591, coinciding with repeal of the 2002 State Decree No. 344.
  • China’s HyperToxic (Mandarin: jù dú, meaning extremely/very toxic) Chemicals List
    On February 27, 2015, ten (10) Chinese national ministries and commissions, including the State Administration of Work Safety (SAWS, now MEM) and the Ministry of Public Security, jointly issued the List of HyperToxic Chemicals, 2015 Edition (Rat Oral LD50≤5mg/kg, Dermal LD50≤50mg/kg), with a total of 148 substances, while repealing the 2002 Edition (Rat Oral LD50≤50mg/kg, Dermal LD50≤200mg/kg). Both Brodifacoum and Bromadiolone are listed in the inventory, which is the highest level of controlled chemicals in China.

2005 – China bans new players in rodenticide

  • Dec. 2, 2005: China’s National Industrial Policy launched: as laid out in the detailed Directive for “Regulations on Promoting Industrial Structure Adjustment,” the “Directory for Guiding Industry Restructuring (2005, version now updated 2019),” China banned the new production of highly toxic pesticides, including rodenticides involved in the list of “Zinc phosphide, Aluminum Phosphide, Diphacinone, Chlorophacinone, Warfarin, Coumatetralyl, Bromadiolone, Brodifacoum.”
2018 – New MEM License (formerly SAWS)
  • Hazardous Permit for Brodifacoum and Bromadiolone required since 2002
    Until the SAWS was merged into the newly created MEM (Ministry of Emergency Management) in 2018, Siyang Rodenticide Factory had gone through five renewals since it was first licensed in 2003. New site for plant relocation in 2021 inspected and awarded new extremely toxic chemical license by MEM. (Attached: Hazardous Chemical Permit)

License as Registered Pesticides in China

(Production Qualification of Rodenticides in China)

  • “Designated-site Rodenticide,” a direct translation from Mandarin, the legal rodenticide in pesticide application, meaning that the active ingredient of the rodenticide produced in China has full qualifications status, it is approved by three ministries: (1) registration of rodenticide with the MOA by the 1997 pesticide regulation, (2) environmental and safety evaluation of production as the designated pesticide sites by NDRC (succeeded by MIIT since 2008), and in particular (3) due to the mandatory national standards that came into effect in 2007, an additional AQSIQ authorisation permit is required over other pesticide production.
  • The AQSIQ of China finally authorised the 2 sites designated by MIIT to produce 2 active ingredients of rodenticides with national standards – Brodifacoum and Bromadiolone. (Attached Pesticide Production License)
2017 – The new Regulation on Pesticide Administration
  • China pesticide regulation (National Legislation first in 1997, then 2001 and now 2017)
    On Feb. 8, 2017, the State Council of China approved an amendment to the “Regulation on the Administration of Pesticides” – known as the State Decree No. 677, coinciding with repeal of the 2001 State Decree No. 326.
  • China rodenticide restriction (Ministerial Regulation, MOA Proclamation No. 2567)
    On August 31, 2017, China’s Ministry of Agriculture (MOA) issued Proclamation No. 2567, the “List of Restricted Use Pesticides,” in which a total of 32 pesticides were included, covering all eight rodenticides that are in active registration status in China, “Type C Botulinum, Type D Botulinum, Flocoumafen, Diphacinone sodium, Warfarin, Coumatetralyl, Bromadiolone and Brodifacoum.”
2019 – New MOA Rodenticide Permit (formerly AQSIQ)
  • Aug. 31, 2017: According to MOA No. 2567 regulation, rodenticides have been classified as restricted pesticides in China and will be subject to designation marketing management, re-planned and designated sales sites, and a new restricted license issued by the state, as well as a requirement for ID-verified at the time of purchase.
  • In 2018, AQSIQ merged with the newly established State Administration of Market Supervision. At the same time, the AQSIQ’s entry-exit inspection and quarantine (well known CIQ, the “China Inspection and Quarantine”) management responsibilities and teams were transferred to the General Administration of Customs (GAC).
  • Feb. 1, 2019: Siyang Rodenticide Factory obtained a new restricted pesticide license, which is a national electronic disclosure of pesticide data with QR code scanning management, and the active ingredient of rodenticide produced in China with authenticity and traceability.

Regulated exports of Brodifacoum, Bromadiolone

The General Administration of Customs (GAC)
  • Dec 18, 2020: The China GAC issued an Announcement No. 129 under the State Council Decree No. 591 (2011 Hazardous Chemicals Regulations) and the regulation of hazardous Chemicals Catalogue in 2015, repealing AQSIQ Announcement No. 30 of 2012. Mandatory inspection of imports and exports of hazardous chemicals listed in the new Catalogue, the measures including hazard classification certification, qualified UN GHS labeling and data, UN TDG required packaging, etc. There are 28 pesticides in the new Catalogue, including three coumarin-based rodenticides as Warfarin, Brodifacoum and Bromadiolone.
  • Dec 31, 2021, In order to implement the obligations of the Rotterdam Convention (entered into force in China on June 20, 2005), the GAC and the MOA jointly issued Announcement the No. 416 in accordance with the Chinese Customs Law and the Regulation on Pesticide Administration. The implementation of electronic customs clearance for import and export of pesticides, data sharing of qualified pesticide producer and certified trade operators in China, only registered pesticides produced by licensed producers can be exported to other countries. The latest 2022 version of the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides” was also released, with the total number of pesticides increased from 1,183 to 1,238. The announcement will be implemented from January 1, 2022.
The licensed Brodifacoum TC and Bromadiolone TC from China

Siyang Rodenticide Factory is the only licensed exporter of Brodifacoum TC and Bromadiolone TC in China since 2006 and the current export process is based on the following international and domestic regulations:

  • (1) The classification of hazardous chemicals is certified as “UN 3027, CLASS 6.1, PG: I” with reference to UN TDG (United Nations Recommendations on the Transport of Dangerous Goods – Model Regulations, now in its 22nd revised edition of 2021);
  • (2) Subject to GAC mandatory export inspection (former CIQ) by IMDG Code (the International Maritime Dangerous Goods Code) for compliance with the TDG-Certified, UN GHS (Globally Harmonized System of Classification and Labelling of Chemicals) or EU CLP (Regulation (EC) No 1272/2008);
  • (3) The pesticide export release order approved and issued by ICAMA to comply with the Rotterdam Convention, and the HS code of the pesticide is “293220-90-11/13″ as specified by the China Regulation (Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides, now 2022 edition).

Siyang Rodenticide Factory – (38th Year)

Siyang Rodenticide Factory, as the name implies, is a professional rodenticide manufacturing plant located in Siyang County, China. It was established in March 1985 as a collectively owned enterprise.

Siyang Rodenticide Factory is the pioneer of rodenticides in China and has been involved in the development of a total of six anticoagulant rodenticides in the past decades, “Chlorophacinone, Warfarin, Coumatetralyl, Bromadiolone, Brodifacoum and Difenacoum.”

Under China’s latest regulatory reform, Siyang Rodenticide Factory is now defined as a “Restricted Pesticide Site designated by the MOA” for supply of  Technical Bromadiolone and Brodifacoum.

Reforms of rodenticide administration

In 2005, Siyang Rodenticide Factory participated in the Review Meeting of Rodenticides in China held by the ICAMA (Institute for the Control of Agrochemicals, MOA): Brodifacoum and Bromadiolone were adopted as official pesticides in China.

In 2006, China SAC and AQSIQ (General Administration of Quality Supervision, Inspection and Quarantine of China) jointly enacted national standards for Brodifacoum and Bromadiolone, which came into effect in 2007.

  • In 2008, the AQSIQ officially authorized and issued the “Manufacturing Permit of National Industrial Product” to the Siyang Rodenticide Factory for national standards Brodifacoum and Bromadiolone. And only 2 manufacturers licensed in China at the production authorisation deadline.

  • In 2013, Siyang Rodenticide Factory obtained a five-year renewal of the “AQSIQ authorisation permit” for the production of Technical Brodifacoum and Brodifacoum, as well as the processing of 0.5% TK (the mandatory national standard for concentrates in China was set at 0.5%).

  • In 2018, the AQSIQ was merged with the newly created State Administration for Market Regulation. According to the new pesticide laws and regulations in 2017, Siyang Rodenticide Factory was granted a new state pesticide license (restricted) by the MOA in 2019, No. (SU) 32000010534.

  • In 2021, the extremely toxic chemical storage facility at the new site of Siyang Rodenticide Factory first passed the security permit of MEM, then the warehouse was relocated, and finally the new plant again passed the inspection of MOA’s Restricted Pesticide Site and was issued a new permit (SU) 32000013199.