“Bromadiolone Technical Material” produced in China under national authorization
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✔ China’s “Hypertoxic” Chemical License since 2002
(now updated to 2015 version)
(hazard #2414 – “Bromadiolone,” “Hypertoxic” labeled)
The main regulatory authorities are the Ministry of Public Security (MPS) and the MEM (former SAWS)
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✔ China’s national pesticide “rodenticide production” license
(1997 – 2017)
Bromadiolone officially became national pesticides in 2007, and as such this rodenticide production in China is subject to the issuance of a Manufacturing License by the AQSIQ, which has been taken over by the MOA (now renamed MARA) since the new pesticide law in 2017.
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✔ 2017 “List of Restricted Pesticides” License
“2017 Regulation on the Administration of Pesticides”
Bromadiolone (Restricted-Pesticides #21, “designated-site operation” labeled)
The export of Bromadiolone is subject to mandatory inspection in accordance with General Administration of Customs (GAC) Announcement No. 129 (2020).
- CAS No.: 28772-56-7
EC No.: 249-205-9
Mol. Formula: C30H23BrO4
IUPAC: 3-[3-(4′-bromo[1,1′-biphenyl]-4-yl)-3-hydroxy-1-phenylpropyl]-4-hydroxy-2-benzopyrone
Bromadiolone Technical Material: MSDS (EU)
- (Coumarin Derivative Pesticides, Solid, Toxic)
IATA DGR/ADR/IMDG: UN 3027, CLASS: 6.1
UN Mark: 1A2/X*/**=Open-Steel-Drum/PG: I*/**
Transportation from China: Only FCL by sea.
GHS/EU CLP/CN: Danger, GHS06, GHS09, GHS08.
HS Code/EU/CN: 293220-90-13 (MOA & GAC)
The leader in rodenticides in China – five active ingredients registered
- As a pioneer in the field of rodenticides in China, Siyang Rodenticide Factory has registered five anticoagulant rodenticide active ingredients with the Ministry of Agriculture (MOA) since the implementation of pesticide registration regulations in 1997. These five active ingredients include: (1) Chlorophacinone (we are the only registrant in China; terminated in 2000 in accordance with policy); (2) Warfarin (MOA’s Reg. No. PD20081154) and (3) Coumatetralyl (MOA’s Reg. No. PD20083600); as well as two rodenticides with national standards: (4) Brodifacoum and (5) Bromadiolone.
- In 1997, China promulgated its first “Pesticide Management Regulations” (Decree No. 216 of the State Council).
- In 1998, the Siyang Rodenticide Factory registered the following two Bromadiolone products with the Ministry of Agriculture: MOA Reg. No. LS981280 (Bromadiolone 97% TC), Reg. No. LS981281 (Bromadiolone 0.5% TK).
- Since 2007, with the implementation of the national standard for Bromadiolone, the temporary registration code “LS” has been changed to the formal “PD” code: our MOA’s Reg. No. PD20070322 (Bromadiolone 98% TC) and PD20081024 (Bromadiolone 0.5% TK).
Siyang Rodenticide Factory is the only legal exporter of Hypertoxic chemical “Technical Bromadiolone” in China, with a “Hazardous Chemicals License” issued by MEM.
Customs and Maritime supervision of the export of the hazardous substance Bromadiolone
Bromadiolone, as a hazardous chemical, requires certification of hazard classification with reference to UN TDG for export from China. The technical material is certified as “UN3027,” Class 6.1, PG: (I); UN Proper Shipping Name: “Coumarin derivative pesticides, Solid, Toxic.” At the same time, it is a mandatory GAC inspection (formerly CIQ) for export from China according to the regulations.
In 2015, the General Office of SAWS issued the “Implementation Guidelines for the List of Hazardous Chemicals (Trial) (2015 Edition)” and attached the table of “Hazards Classification Information” for the List: #2313, Bromadiolone, Hazard Category: “Acute toxicity – Oral, Category 1; Acute toxicity – Dermal, Category 1; Acute toxicity – Inhalation, Category 1; Specific target organ toxicity – repeated exposure ‘STOT RE’, Category 1; Hazardous to the aquatic environment, short-term (Acute) ‘Aquatic Acute’- Category Acute 1, Hazardous to the aquatic environment, long-term (Chronic) ‘Aquatic Chronic’ – Category Chronic 1” and labled “Hypertoxic.”
On July 24, 2024, the State Administration for Market Regulation (SAMR) and the Standardization Administration of China (SAC) released the first part of the GB 30000 series, titled “Classification for Labeling of Chemicals Part 1: General Rules” (GB 30000.1-2024). This revision marks the second major update since the series was first published in 1992. The technically consistent with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) (Eighth Revision) and will take effect on August 1, 2025.
Joint regulation of the export of the pesticide Bromadiolone TC by MARA and GAC
Bromadiolone, as a commodity pesticide, export from China is subject to ICAMA legal approval and the issuance of a release order.
The latest version of the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides” for 2022 was published as an annex to the “Joint Announcement No. 416 of GAC and MARA.” This directory is commonly referred to as the “China Export Pesticides Customs Codes.” The tariff code for pesticide export code #640 Bromadiolone is 2932209013, and this code remain unchanged from the previous version.
In China, industrial Bromadiolone (pure, technical) mainly regulated by the Ministry of Public Security
Technical Bromadiolone has been classified by WHO in class Ia – “Extremely Hazardous,” based on acute oral LD50 of 1.12 mg/kg for rats.
In EU, it is classified as Class I (very toxic) under EU Directive 67/548/EEC (now the CLP Regulation, Regulation (EC) No 1272/2008).
In China, according to the “China Directory of Extremely Toxic Chemicals (2015 edition),” (LD50≤5 mg/kg (rat oral)), Bromadiolone is classified as “Hypertoxic” (Chinese characters: 剧毒, Mandarin: jù dú, meaning Extremely Toxic) chemical under the highest control level by the Ministry of Public Security’s “Measures for the Administration of Permits for the Purchase and Road Transportation of Hypertoxic Chemicals” issued in 2005 and the MPS standard GA 1002-2012, the “Public Safety Protection Requirements for Storage Facilities of Hypertoxic Chemicals and Radioactive Sources” issued in 2012.
Compliant export procedures for Bromadiolone TC in China
- Since obtaining export qualifications in 2006, Siyang Rodenticide Factory has been the only exporter of Bromadiolone TC in China that complies with all regulations.
- Currently, the legal procedures for compliant export are as follows (four certifications):
✔ (1) “Certification of Hazardous Classification and Identification” – (Valid for the current year).
The classification of hazardous chemical “Bromadiolone TC 98%” will be certified as “UN 3027, Class:6.1, PG: I,” with shipping name “Coumarin Derivative Pesticides, Solid, Toxic” with reference to “UN TDG Regulation” (United Nations Recommendations on the Transport of Dangerous Goods – UN Model Regulations, Rev. 23 (2023)).
– Regulation Link: https://unece.org/transport/dangerous-goods/un-model-regulations-rev-23
– Please click to view our “Certificate for Classification of Dangerous Goods” for Bromadiolone 98%.
✔ (2) “Performance Inspection Results of Packages for Transportation of Exported Goods” – (Valid for 12 months).
This certificate is provided by the packaging manufacturer. It is based on the GAC’s “Rules for the inspection of packaging for export dangerous goods – Part 2 : Performance test” (SN/T0370.2-2009) and the International Maritime Dangerous Goods Code (IMDG).
– Please click to view the “Packaging Performance Certificates” we use.
✔ (3) “Certificate of Inspection for the Use of Packaging for the Transport of Dangerous Goods for Export” or translated as “Inspection Certificate for Export of Dangerous Goods Packaging” – (Valid for 12 months).
It needs to be applied for at the customs branch in the location of the factory using the performance sheet above. Currently, our factory in Siyang County is under the jurisdiction of the municipal government, and is inspected on site by the Suqian Customs. It is based on the GAC’s “Rules for the inspection of packaging for export dangerous goods – Part 3: Use appraisal” (SN/T0370.3-2009) and the International Maritime Dangerous Goods Code (IMDG).
– Please click to view our “Inspection Certifiacte” for Bromadiolone TC 98%.
✔ (4) “Pesticide Export Release Certificate” – (Valid for only 3 months).
The export release certificate for Chinese pesticides is issued by the MARA, and the export tariffs code “2932209013 (Bromadiolone)” has been included in the relevant Chinese pesticide management regulations (the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides,” currently the 2022 edition).
– Please click to view our “Export Release Certificate” for Bromadiolone TC 98%
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