Contact Siyang Rodenticide Factory

The relocation site (20 mu, ≈13,333 ㎡) in Sept. 2021.
Add.: North of Wujiang Road and west of Gedonghe Road in Siyang Economic Development Zone (Siyang County), Jiangsu Province, China 223700.
The new site has obtained a “Hazardous Chemical Permit” from MEM and a “Restricted Pesticide Permit” from MARA in accordance with the law.

We supply Brodifacoum TC, Bromadiolone TC and Difenacoum intermediate 6

State designated rodenticide manufacturer (China)

SIYANG RODENTICIDE FACTORY (General Partnership)
(The relocation site in Sept. 2021.)
Add.: North of Wujiang Road and west of
Gedonghe Road in Siyang Economic Development
Zone (Siyang County), Jiangsu Province, China 223700.
~~Tel.: +86 (527) 85377 667, Fax.: +86 (527) 85377 947~~
~~Email: export@rodenticide.com.cn~~
Website: https://www.rodenticide.com.cn

Please click on the following links to view various licenses:

• Business License (Notary in English)
• Quality Management Certificate (ISO)
• MOA’s Pesticide Registration Certificates
• ICAMA Free Sales Certificates
• Extreme Toxicity Operation Permit
• AQSIQ Production Permit (Notarized)
• New ‘2017 Restricted Pesticide License’

Extremely Toxic Chemicals Permit (new site)
Restricted Pesticide License (new site)

International Representative (Singapore)

RODEN CHEMICAL PTE. LTD.
Add.: 12 Woodlands Square, #13-79
Woods Square, Singapore 737715.
Online: +65-98690800 (Signal/WhatsApp)
Email: jianguo@roden.com.sg
Website: https://www.roden.com.sg

• Business License (201014267H)
• Date of incorporation: 06/07/2010
• Paid-up Capital: SGD$1,500,000.00

“Bromadiolone” and “Brodifacoum” have been included in the “2015 List of Hypertoxic Chemicals,” classified as the highest-level controlled hazardous substances in China.

Siyang Rodenticide Factory is the sole legally authorized enterprise in China for exporting hypertoxic “Bromadiolone TC and Brodifacoum TC” holds a Hazardous Chemicals Permit issued by the Ministry of Emergency Management (MEM).

Storage of Brodifacoum TC and Bromadiolone TC

According to the “Public Security Protection Requirements for Hypertoxic Chemicals and Radioactive Sources Storage Site” (GA 1002-2012) promulgated by the Ministry of Public Security (MPS) in 2012, hypertoxic chemicals (Bromadiolone TC and Brodifacoum TC) are stored in compliance with regulatory standards. The warehouse monitoring system is interconnected with the county public security bureau’s 110 emergency response system and operates under real-time surveillance.

Copyright © Siyang Rodenticide Factory

2025 marks the 40th anniversary of our factory’s establishment

Since obtaining export qualifications in 2006, our factory has primarily engaged in the production and export of technical materials for Brodifacoum and Bromadiolone. Over the past two decades, both domestic and international industry regulations have undergone significant changes. Internationally, the most notable changes include the European Union’s replacement of the Biocidal Products Directive (BPD) with the Biocidal Products Regulation (BPR) in 2013, followed by the implementation of the Classification, Labelling, and Packaging of Chemicals Regulation (CLP).

China’s major changes included a phase-out of the rodenticide industry during the first decade: the promulgation of the National Industrial Policy in 2005; the Catalogue of Projects Prohibited from Land Use issued in 2006; the formal implementation of the national standard (GB) for Bromadiolone and Brodifacoum in 2007; and the establishment of the Ministry of Industry and Information Technology (MIIT) in 2008. These reforms, policies and regulations eliminated three manufacturers, resulting in the reduction of China’s original five producers of technical rodenticides to just two. Then, over the subsequent decade, the state introduced a series of new policies and revised numerous laws and regulations.

In 2018, China underwent institutional reforms that also led to changes in the regulatory bodies overseeing the rodenticide industry. Currently, the administrative departments previously responsible for “technical rodenticides” have been consolidated from multiple ministries and commissions – namely the Institute for the Control of Agrochemicals, Ministry of Agriculture (ICAMA); the Ministry of Environmental Protection (MEP); the National Development and Reform Commission (NDRC); the Ministry of Public Security (MPS); the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ); the Ministry of Industry and Information Technology (MIIT); and the State Administration of Work Safety (SAWS) – into three primary departments: the Ministry of Public Security (MPS); the Ministry of Emergency Management (MEM); and the Ministry of Agriculture and Rural Affairs (MARA).

Therefore, the factory has invested significant resources over the past decades to address these challenges. Starting in 2025, we will no longer accept orders from new customers or respond to related inquiries. This decision stems primarily from two factors: First, new customers will inevitably require only minimal quantities of hypertoxic chemicals (bromadiolone technical material and brodifacoum technical material.) The compliant export procedures such as statutory packaging, transportation, commodity inspection, and declaration are practically impossible to implement in real-world operations. Second, due to factory relocation and withdrawal from the pesticide manufacturing industry, export clearance now requires specialized approval from the ICAMA and the establishment of dedicated channels, making the procedures relatively cumbersome. Therefore, we can only wait for qualified domestic or international enterprises to place bulk orders at this time.

Over the past decade or so, the main changes in the factory have been as follows:

In 2013, considering that the factory had not produced rodenticide baits for over a decade, the “Pesticide Production License for rodenticide 0.005% RB” issued by the MIIT was formally relinquished to reduce administrative expenses for this project.
In 2019, due to the safety distance between the factory and newly constructed residential areas no longer meeting the latest safety regulations and policies, we were compelled to cease production at the original site and began investing in the construction of a new factory. Concurrently, the old plant underwent a series of upgrades in compliance with the new Pesticide Law enacted in 2017, successfully obtaining a “Restricted-Pesticide License” issued by the MARA.
In 2021, the factory ultimately completed its relocation by treating it as a non-production project (Upgrading Storage Facilities for HyperToxic Chemicals Brodifacoum and Bromadiolone), obtaining a “Hazardous Chemicals Permit” issued by MEM and a updated “Restricted Pesticide Permit” issued by MARA.
From 2022 to 2023, due to relocation, our factory withdrew from the pesticide manufacturing industry and only sold inventory products (brodifacoum TC and bromadiolone TC). Therefore, the seven pesticide registration certificates issued by the Ministry of Agriculture listed below will not be renewed upon expiration.
– PD2007323 (Brodifacoum 98% TC), – Valid until September 17, 2022,
– PD20071101 (Brodifacoum 0.5% TK), – Valid until August 18, 2023,
– PD20071102 (Brodifacoum 0.005% RB), – Valid until August 18, 2023,
– PD20070322 (Bromadiolone 98% TC), – Valid until September 17, 2022,
– PD20081024 (Bromadiolone 0.5% TK), – Valid until August 6, 2022,
– PD20081154 (Warfarin 98% TC), – Valid until September 2, 2023,
– PD20083600 (Coumatetralyl 97% TC), – Valid until December 12, 2023.
Currently held valid licenses:
– “Restricted Pesticide License” by MARA (for “state-designated sales” – restricted Bromadiolone Active Ingredient and Brodifacoum Active Ingredient), ours will expire on September 14, 2026.
– “Hazardous Chemicals License” by MEM, (for “hypertoxic substances” – controlled Brodifacoum TC and Bromadiolone TC), ours will expire on June 23, 2027.
In June 2025, the storage facility for hypertoxic chemicals (brodifacoum and bromadiolone) at the new plant site, which had already been approved and licensed by MEM, underwent further upgrades. For example: Hiring qualified security personnel, installing additional cameras to achieve comprehensive, blind-spot-free surveillance, and replacing existing security measures with denser security grilles. It was ultimately accepted by a joint inspection team from the public security departments of Suqian City and Siyang County, in accordance with the Ministry of Public Security’s GA 1002-2012 standard. It must be noted that the factory warehouse, currently used for storing hypertoxic chemicals (technical brodifacoum and bromadiolone), has surveillance cameras connected to the county police department for real-time monitoring. In fact, this also signifies that the Ministry of Public Security’s 2005 regulations on hypertoxic chemicals have now been fully digitized.

shipment of brodifacoum and bromadiolone

Compliant transportation and export shipment of Hypertoxic chemicals (Brodifacoum TC and Bromadiolone TC):
Road transport with hazardous materials transport qualifications, in compliance with Ministry of Public Security Regulation No. 77 of 2005;
Compliant Packaging Group I steel drum packaging, UN3027, class 6.1, full container load (FCL) shipment in a 20-foot hazardous materials container.

Copyright © Siyang Rodenticide Factory

The Most Professional Answers in China’s Rodenticide Industry

(1) How many anticoagulant rodenticides are currently available in China?
If referring to the “Pesticide Registration Certificate” issued by the MARA, there are currently five active ingredients with valid registration status: “Warfarin, Coumatetralyl, Brodifacoum, Bromadiolone, and Flocoumafen.” However, it should be noted that obtaining MARA registration in China does not automatically grant authorization for production, sale and storage. The production and operation of these technical rodenticides require obtaining two mandatory permits: the “Hazardous Chemicals Permit” and the “Pesticide Production Permit.” Since the implementation of the new pesticide law in 2017, the sale of rodenticides requires an additional “License for Restricted Pesticides.”
(2) Since MARA registration in China is not equivalent to a production qualification, how many rodenticide active ingredients are currently permitted for production, and how many manufacturing companies are there?
Over the past 40 years, there were six active ingredients permitted for rodenticide production in China: “Chlorophacinone, Warfarin, Coumatetralyl, Brodifacoum, Bromadiolone and Difenacoum (incomplete pesticide registration)” with a total of five licensed manufacturing companies were located in: “Siyang county (Jiangsu province), Tianjin Municipality, Shanghai Municipality, Zhangjiakou city (Hebei province), and Xiaolin town, Cixi city (Zhejiang province).” However, with China’s industrial upgrading (2005 National Industrial Policy, the rodenticide project prohibited new land use in 2006, the formal implementation of the rodenticide national standard (GB) in 2007) and regulatory reforms (the establishment of the MIIT in 2008), only two rodenticide active ingredients (Bromadiolone and Brodifacoum) retained production permits, and only two companies retained production qualifications, namely “Siyang” and “Tianjin.” All other active ingredients and manufacturers have been completely phased out. It should be noted that among the three companies whose active ingredient production qualifications were revoked, two are state-owned enterprises, namely “Shanghai Gaolun Modern Agrochemical Co., Ltd. (under Shanghai Pesticide Research Institute)” and “Zhangjiakou Jinsai Pharmaceutical Co., Ltd.” (formerly Zhangjiakou Rodenticide Plant, the developer of first generation of anticoagulant rodenticides, Warfarin and Coumatetralyl in China).
(3) Which Chinese authority is responsible for approving the production qualification of rodenticides and issuing production licenses?
Prior to 2017, the production and sale of pesticides were not under the jurisdiction of the Ministry of Agriculture. In China, the production of technical-grade rodenticides requires obtaining two mandatory production licenses (for chemicals and pesticides) simultaneously; otherwise, it is considered illegal production. (i) “Industrial Chemicals Production License” (now the “Hazardous Chemicals License”): From our establishment in 1985 to 1998, the competent authority was the former Ministry of Chemical Industry; from 2002 to the present, the competent authority is the SAWS (now MEM) in accordance with the “Work Safety Law” and the “Regulations on the Safe Management of Hazardous Chemicals”; (ii) For “Pesticide Production Licenses”: From 2003 to 2008, the competent authority was the NDRC; from 2008 to 2017, the competent authority was the AQSIQ ( for national standard pesticides only) and the MIIT (for non-standard pesticides) in accordance with the National Industrial Policy by NDRC; since the implementation of the new pesticide law in 2017, the competent authority has been the Ministry of Agriculture (MOA, renamed the Ministry of Agriculture and Rural Affairs, MARA in 2018), which assumed the production licensing responsibilities previously handled by the MIIT and the AQSIQ.
(4) So, if we are interested in other rodenticide active ingredients, such as Difenacoum, will China be able to supply these products in the future?
This has not been possible since 2005. According to the “National Industrial Guidelines” issued by the State Council in 2005 with its supporting regulations, namely the “Industrial Policy Directory” of the NDRC, China has banned the production of new highly toxic pesticide including hypertoxic rodenticide active ingredients and new production enterprises since 2005. The “National Industrial Policy Directory” has now been updated to the 2024 edition.
(5) What is the current regulatory authority responsible for “Technical Bromadiolone” and “Technical Brodifacoum” in China?
It is primarily managed by three national ministries. The most important of these is the Ministry of Emergency Management (MEM), established in 2018, which absorbed the former State Administration of Work Safety (SAWS). This department holds nearly the broadest regulatory authority in China, including the ability to directly mobilize military and police forces in emergency situations. Therefore, it is crucial for practitioners in China to obtain a valid “Hazardous Chemicals Permit,” which is also the most fundamental license. Without it, according to regulations, it is fundamentally impossible to proceed with other licensing approvals, such as hazardous warehouse acceptance inspections and also pesticide production approvals. The second is the Ministry of Public Security (MPS), which primarily oversees the procurement, transportation and storage of hypertoxic chemicals within the country. (In fact, since the Ministry of Public Security’s regulations took effect in 2005, it has been stipulated that every sale and transport of highly toxic chemicals (such as bromadiolone TC and brodifacoum TC) must be reported to the county-level or higher public security authorities.) Lastly, the Ministry of Agriculture and Rural Affairs (MARA, formerly the Ministry of Agriculture) manages pesticide regulations.
(6) What are the primary laws and regulations governing the production and operation of “Bromadiolone TC” and “Brodifacoum TC” in China?
Primarily regulations from three regulatory agencies and one national law: First, the MEE issued the “Regulations on the Safety Management of Hazardous Chemicals” and the “Catalogue of Hazardous Chemicals,” which legally require obtaining a Hazardous Chemicals Permit. Second, the MPS enacted two regulations: the “Measures for the Administration of Permits for the Purchase and Transportation of Hypertoxic Chemicals” and the “Public Security Protection Requirements for Hypertoxic Chemicals and Radioactive Sources Storage Site.” These regulations implement a sales reporting system and an on-site assessment system respectively, without issuing permits. Finally, the three primary management regulations under the Pesticide Law: the “Measures for the Administration of Pesticide Registration,” the “Measures for the Administration of Pesticide Operations,” and the “Measures for the Administration of Pesticide Production Licensing.” These respectively require obtaining a Pesticide Registration Certificate, a Pesticide Operation Permit, and a Pesticide Production License. Additionally, it is important to note that violations related to hazardous chemicals have been incorporated into the “Criminal Law of the People’s Republic of China.” Under Article 125, “Illegal Manufacturing, Trading, Transporting, or Storing Hazardous Substances,” offenders face imprisonment of not less than three years but not more than ten years. For serious offenses, the punishment may be imprisonment of not less than ten years, life imprisonment, or death. In fact, as recently as early 2025, China saw its first case where relevant enterprises and individuals were sentenced under Article 125 of the Criminal Law for illegally engaging in activities involving technical Bromadiolone and technical Brodifacoum.
(7) Given that China has only two holders of production qualification (Siyang and Tianjin), and they are only authorized to produce two active ingredients – “Bromadiolone and Brodifacoum”- why have we learned that other few companies hold MARA registration certificates?
Yes, four provinces in China have MARA registration certificates for technical rodenticides (Brodifacoum, Bromadiolone) without production qualification: “Liaoning Province, Inner Mongolia Autonomous Region, Henan Province, and Shaanxi Province.” In fact, pesticide registration dossiers can be freely traded in China. Theoretically, this means an existing MARA registration certificate can be transferred multiple times to different enterprises. In reality, some currently held registration certificates without production qualifications were purchased from enterprises long since phased out by the state – for example, the four technical rodenticide registration certificates currently held by Inner Mongolia all originated from Zhangjiakou’s “Jinsai” company (whose active ingredient production was banned after the 2005 national industrial policy was introduced). Additionally, note that China’s “production qualifications” are strictly non-transferable. Any transfer would be treated as a new rodenticide construction project, which is explicitly prohibited under “national industrial policy.”
(8) Since China banned new rodenticide production projects starting in 2005, why have more companies applied for and obtained approvals for technical rodenticide as pesticide registrations since then, and why have new active ingredients for rodenticides registration even been added?
In fact, “having registration without production qualification” holds immense value for “opportunistic Chinese entities.” Prior to China’s new pesticide law enacted in 2017, pesticide production and sales fell entirely outside the jurisdiction of the MARA. Only its subordinate agency, ICAMA, handled registration and export operations. Under previous regulations, the production of bromadiolone and brodifacoum technical grade was overseen by multiple departments including the Ministry of Ecology and Environment (MEE), the SAWS (now MEM), the NDRC, the MIIT, and the AQSIQ. Storage, procurement, and transportation were primarily managed by the MPS. Therefore, illegally produced industrial-grade rodenticides in China were often traded through these “pesticide registration certificates without production permits,” ultimately flowing smoothly into domestic and international markets. Regarding exports: when applying for a “Pesticide Export Release Certificate” in China, one only needs to submit a stamped copy of the registration certificate to the ICAMA to obtain the release certificate. No need to review the origin of the pesticide or the legality of its production, as it falls outside the scope of responsibility. This regulatory loophole may explain why, over the past two decades, illegally produced rodenticide active ingredients accounted for over 90% of China’s domestic market and were exported in large quantities globally. Since the implementation of the Pesticide Management Regulations (Pesticide Law) in 2017, the MARA has assumed full responsibility for the unified registration (by ICAMA), production, and sales management of pesticides (administered by the newly established Pesticide Management Department). Through the continuous introduction of regulations, it is anticipated that non-compliant operations will be comprehensively curbed in the near future.
(9) If two existing enterprises holding production licenses (Siyang and Tianjin) withdraw from the market, will new production enterprises be approved to enter the market and fill the vacancies?
This is not possible, due to constraints imposed by multiple laws, regulations, and policies. This is because the NDRC is the competent authority responsible for “Project Initiation,” and its “National Industrial Policy” explicitly prohibits such activities since 2005, and since 2006, the Ministry of Land and Resources (now the Ministry of Natural Resources) has prohibited any new land use for the production of industrial-grade rodenticides, with the current updated regulations being the 2024 version. And all new licenses are prohibited by law and regulations as follows: first, the MEM no longer accepts safety assessments for “Hypertoxic” chemicals and new “Hazardous Chemicals Permit,” the MEE (Ministry of Ecology and Environment) also no longer accepts environmental impact assessments for “Hypertoxic” chemicals, and new “pollution discharge permits” are absolutely prohibited from being issued. Second, under the “Measures for the Administration of Pesticide Production” stipulated by the 2017 new Pesticide Law, the prerequisite for applying for a “Pesticide Production License” is compliance with “National Industrial Policy.” Finally, from a political standpoint, Chinese officials have implemented a system of lifelong accountability, absolutely no public security bureau within China would be willing to assume new legal oversight responsibilities, namely conducting acceptance inspections for newly constructed storage facilities for hypertoxic chemicals (brodifacoum TC and bromadiolone TC) as mandated by the MPS’s 2012 regulations.
(10) Why do you claim that you are the only legal exporter of “Bromadiolone technical material” and “Brodifacoum technical material” since obtaining export qualifications in 2006?
The legally precise statement should be: “Siyang Rodenticide Factory is the sole legally authorized enterprise in China for exporting hypertoxic “Bromadiolone TC and Brodifacoum TC” holds a Hazardous Chemicals Permit issued by MEM.” This is primarily based on the Work Safety Law, the Regulations on the Management of Hazardous Chemicals, and the Catalogue of Hazardous Chemicals, all of which have been in effect since 2002. Any entity engaged in the sale of “Bromadiolone TC and Brodifacoum TC” within China, including export activities, must obtain a mandatory license – the “Hypertoxic Chemical License.” Since the implementation of the new Pesticide Law in 2017, entities must also hold a “Restricted Pesticide License.” Another qualified manufacturer in Tianjin primarily produces bait formulations and has not yet obtained export qualifications for related business operations.
(11) Why did you give up your pesticide production qualifications for “0.005% RB” in 2013?
Following its second relocation in 2004, the factory never resumed bait production at the new site. Consequently, by 2013, nearly a decade after production ceased, we surrendered the production license to reduce administrative costs. Furthermore, another licensed enterprise in Tianjin had consistently served as the core entity for this project and had already captured a significant market share. Meanwhile, we remained focused exclusively on the production and export of active ingredients.
(12) Why did you cease production in 2019 and plan to relocate to a new facility?
The relocation is being carried out in accordance with the “Guiding Opinions on Promoting the Relocation and Transformation of Hazardous Chemical Production Enterprises in Urban Population-Dense Areas” (State Council General Office Document [2017] No. 77) issued by the General Office of the State Council on September 4, 2017. According to its requirements, by 2025, hazardous chemical production enterprises in densely populated urban areas that fail to meet safety and sanitary protection distance requirements must either undergo on-site upgrades to meet standards, relocate into standardized chemical industrial parks, or cease operations and exit the market. As a major producer and large-scale storage facility for technical-grade rodenticides (hypertoxic chemicals – brodifacoum technical material and brodifacoum technical material), our plant no longer meets current safety distance requirements relative to the residential communities developed in the surrounding area.
(13) After relocating to the new facility in 2021, did your company cease production of 98% technical-grade materials (TC) and 0.5% concentrates (TK)?
Yes. First, for technical rodenticides production, any relocation of manufacturers in China, even within the same industrial park in a city, currently results in the loss of production qualifications. This is determined by the 2006 “Catalogue of Projects Prohibited from Land Use” regulation issued by the Ministry of Land and Resources (now the Ministry of Natural Resources). The regulation prohibits production projects involving technical-grade rodenticides from occupying new land since 2006. The latest version of the regulation has been updated to the 2024 edition. Also as stated in response to Question 9 (MEE no longer accepts environmental impact assessments for hypertoxic chemicals, and MEM no longer accepts safety assessments.) In fact, we have produced and maintain sufficient inventory of technical-grade raw materials at our original facility to meet domestic and international market demand for years to come. Regarding discontinuing concentrates production, this decision was driven both by simplifying legal procedures for relocation and by market considerations. In the domestic market, illegal underground producers have dominated nearly 90% of the market share over the past 20 years, leaving our company with virtually no orders. The export market is equally unfeasible – China implemented national standards (GB) for brodifacoum and bromadiolone in 2006, stipulating that the only legal concentration for Chinese concentrates is 0.5%. This conflicts with the 0.25% concentration adopted by most countries internationally.
(14) Do you still hold the necessary qualifications to sell Bromadiolone TC and Brodifacoum TC? We have noted that you discontinued the registration extension of these pesticides in 2022-2023. What was the reason for this?
Unlike final pesticide products marketed to consumers, technical-grade brodifacoum and bromadiolone are classified as industrial raw materials, and the diluted concentrates are actually used as pesticide materials for finished products (rodenticides RB). Even though their pesticide registrations have been terminated, they remain legally produced substances in accordance with the law (MOA registration, AQSIQ and SAWS (now MEM) permits). As we hold the relevant licenses, we are authorized to sell them both domestically and internationally. Regarding exports: ICAMA is the authority responsible for pesticide registration certificate renewals and export. Under the new rules, if an enterprise ceases production and exits the pesticide manufacturing industry, its pesticide registration certificate will not be renewed. This stems from the 2017 revised “Pesticide Law” and its derivative “Pesticide Registration Management Measures,” which stipulate that pesticide registration must be held by manufacturing enterprises (production categories need not comply with the registration certificate, provided they are pesticide manufacturers), while non-manufacturers are not permitted. But our expired pesticide registration certificates leads to another consequence: the inability to apply for export release permits on the national export platform. Currently, exports require special processing by ICAMA. Regarding the legal requirements for operating within the country: since relocating in 2021, the new facility has obtained full certification from all three regulatory bodies (MEM, MARA, MPS), with inventory levels jointly documented and archived by these three departments. This establishes it as a fully compliant facility for the lawful “storage and sale” of technical-grade bromadiolone and brodifacoum within China. The MEM’s Hazardous Chemicals License and MARA’s Restricted Pesticide License currently held by the factory are the two legally mandated permits required for domestic operations.
(15) Why did you obtain the MARA’s “Restricted Pesticide License” yet still lose your MARA’s “pesticide registration certificate”? Aren’t they the same department?
Unlike Western countries, China’s regulatory framework is highly complex and cumbersome. Historically, China’s regulation of technical-grade rodenticides involved multi-departmental oversight. Only after the new Pesticide Law took effect in 2017 did the MARA reclaim pesticide production licensing authority from the MIIT and the AQSIQ. This responsibility was transferred to its newly established “Pesticide Management Department.” Provincial, municipal, and county agricultural commissions under the Pesticide Management Department have established enforcement departments responsible for nationwide pesticide production and sales oversight. In practice, although both ICAMA and the newly established Pesticide Management Department fall under the MARA, they are distinct and independent entities with different histories: ICAMA was founded in 1963 and is primarily responsible for registration and also export, while the Pesticide Management Department was newly established in 2017 and is primarily responsible for production and operations. Consequently, although we obtained the “Restricted Pesticide License” issued by the Pesticide Management Department, ICAMA could not renewed our pesticide registration certificate anymore by rules due to our relocation and cessation of production. This has resulted in obstacles to our exports.
(16) Is there still an opportunity for us to cooperate? Can you currently export and deliver Brodifacoum TC and Bromadiolone TC to us?
Yes, but we firmly believe that no new customer can currently meet the minimum order quantity. Previously, we typically only accepted orders exceeding 500 kilograms (MOQ: 20-25 customized UN standard “PG: I” steel drums), with a full container load for ocean shipping. However, the current requirement is significantly higher. This is because, as hypertoxic chemicals (bromadiolone technical material and brodifacoum technical material), the legal import and export of small quantities is fundamentally impractical in real-world operations. This is because we must strictly adhere to all legal procedures, such as: UN-certified steel drums with a 12-month shelf life, which must be custom-made per order; Road transport requires specialized vehicles certified for hazardous materials; packaging must comply with mandatory commodity inspection policies; out of warehouse must be submitted declaration to county-level public security bureaus as required; shipping owners only accept full container loads (FCL) for maritime hazardous goods transport, etc. However, due to factory relocations and the withdrawal of factories from the pesticide production industry, export clearance now requires special approval from ICAMA. This necessitates specialized channels, involves cumbersome procedures, and operates under time constraints. Consequently, the previous practice of annual procurement partnerships is no longer feasible, limiting transactions to single-order purchases with delivery in installments within the period approved by ICAMA (potentially 12 months). Currently, we are awaiting qualified domestic and international enterprises to conduct a single bulk purchase.
(17) Are Chinese export trade agencies qualified to export technical-grade rodenticides?
Currently, although only few exporters in China have obtained a “Restricted Pesticide License,” no other company besides ours has been approved for an “Hypertoxic Chemical License.” Therefore, except for our factory, all export activities involving “Brodifacoum TC” and “Bromadiolone TC” in China are illegal. However, as overseas buyers, there is no obligation to understand Chinese laws and regulations regarding hazardous chemicals, and it is natural to be able to purchase freely from any Chinese exporter. However, import and export transportation is a global rule, and safety is of paramount importance, especially for hypertoxic chemicals. Therefore, in any cases, packaging must comply with international regulatory requirements. In other words, legal UN Proper Shipping Name: “Coumarin derivative Pesticides, Solid, Toxic.,” the packing group “I” steel drums for UN3027, Class 6.1.
(18) What compliant packaging do you use when exporting Bromadiolone TC and Brodifacoum TC?
We require specially customized steel drums that comply with UN Packaging Group “I” standards. In the past, we often customized UN steel drums with capacities of 73 and 78 liters, suitable for loading 20 kg of Bromadiolone technical material or 25 kg of Brodifacoum technical material. The performance of UN Group “I” steel drums must comply with the requirements of China’s mandatory standard GB-3796 “General Rules for Pesticide Packaging”: stacking test ≥ 3 meters, air-tightness test ≥ 30 k Pa, and hydraulic test ≥ 250 k Pa. Additionally, custom-made UN steel drums have an export validity period of only 12 months from the date of production. An example of the compliant United Nations specification packaging mark we have used in the past: “UN 1A2/X32/S/19/CN/C230409/PI:010.”
(19) What are the compliance export procedures and transportation requirements for Brodifacoum TC and Bromadiolone TC?
First, the “Measures for the Purchase and Road Transportation Management of Hypertoxic Chemicals” promulgated by the MPS in 2005 are currently the effective regulations in force. Secondly, in 2020, the General Administration of Customs of China (GAC) issued the “Announcement on Issues Concerning the Inspection and Supervision of the Import and Export of Hazardous Chemicals and Their Packaging,” implementing mandatory inspections for the export of Brodifacoum and Bromadiolone, four certificates are required: (i) the “Certification of Hazardous Classification and Identification;” (ii) the “Performance Inspection Results of Packages for Transportation of Exported Goods;” (iii) the “Inspection Certificate for Export of Dangerous Goods Packaging;” and (iv)the “Pesticide Export Release Certificate.” Additionally, in China, airlines absolutely do not accept air transport of hypertoxic chemicals (technical Brodifacoum and technical Bromadiolone); for sea transport, almost all shipping companies do not accept less-than-container load (LCL) shipments and only accept full-container load (FCL) shipments.
(20) What is the correct tariff code for technical rodenticide? (HS Codes: “380899” or “293220”?)
There is no doubt that China’s import and export commodity codes match the “Harmonized System” (HS) codes established by the “World Customs Organization” (WCO), but China has further subdivided the internationally accepted 6-digit codes into 10-digit codes. The export tariff codes for pesticides in China are legally mandated, based on the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides (latest 2022 edition).” This directory is commonly referred to as the “Chinese Export Pesticide Customs Code.” The tariff code for pesticide export code #640 Brodifacoum, “2932209011,” and the tariff code for pesticide export code #645 Bromadiolone, “2932209013.” In addition, the code #1235 in the export pesticide directory refers to “Retail-packaged Rodenticides (Ready-to-use Bait),” with a tariff number of 3808991090; code #1237 refers to “Non-retail-packaged Rodenticides (Ready-to-use Bait),” with a tariff number of 3808999090. In any case, technical rodenticides (Brodifacoum TC and Bromadiolone TC) are definitely not classified under the same tariff code as rodenticide baits.
(21) What is the current reality of the rodenticide industry in China?
In fact, since the “2015 Tianjin explosion” and the “2019 Xiangshui Chemical Plant explosion,” China’s chemical production policies have been significantly tightened, forcing private small and medium enterprises to close or be reorganized by state-owned enterprises, while relocating related industries to remote desert regions such as Ningxia and Inner Mongolia. However, for the rodenticide industry, under current laws, regulations, and policies, the production of hypertoxic technical-rodenticides is absolutely prohibited from being relocated to any region within China (Please refer to the answer to Question 9.) Secondly, production activities at existing manufacturing sites (such as our facility in Siyang) have gradually become unable to meet new regulatory and policy requirements, facing outright closure or relocation with losing production qualifications. Therefore, in China, even with a production license (now only Tianjin remains), manufacturing a new batch of technical rodenticides (such as Bromadiolone TC and Brodifacoum TC) currently faces major challenges. As for the impact on the end market, we believe it is negligible because the concentration of the active ingredient used is extremely low, at only 0.0025% or 0.005%.
(22) What are your views on the future development of this industry?
First, we believe that with the tightening of China’s regulatory policies, the domestic illegal clandestine producers are about to disappear, and related cases have been exposed one after another. In addition, we have already withdrawn from the market, so China will no longer sell or export Brodifacoum TC and Bromadiolone TC. Moving forward, only concentrated formulations will be sold as technical pesticide raw materials in China, aligning with current practices in other countries worldwide. Meanwhile, both domestic and international markets will gradually transition from disorder to regulation. Furthermore, we believe that the market will ultimately return to the EU, and participants in the EU Biocidal Products Regulation (BPR) (EU Regulation No. 528/2012) will become global leaders and be included in the “Article 95 list.” Perhaps in ten years, China’s rodenticide industry will come to a complete end, and China will turn to Europe for baits procurement.

Latest updated:

On November 22, 2022, Ministry of Agriculture and Rural Affairs Order No. 9 of 2022 (Administrative Measures for Comprehensive Agricultural Law Enforcement) was promulgated, and shall come into effect on January 1, 2023.
– Regarding this interpretation: Since the enactment of the new Pesticide Law in 2017, the Ministry of Agriculture and Rural Affairs (specifically the Department of Crop Production, which concurrently established the Pesticide Management Department) has assumed the responsibilities previously held by the Ministry of Industry and Information Technology (MIIT) and the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) for reviewing and issuing pesticide production licenses. The regulation grants new enforcement authority to subordinate units of the Pesticide Management Department – namely provincial pesticide management stations and municipal and county-level local agricultural commissions – to comprehensively oversee pesticide production and sales activities within China. Additionally, ICAMA remains responsible for pesticide registration and export affairs in China, with no changes.
On June 29, 2025, the Ministry of Agriculture and Rural Affairs of the People’s Republic of China issued Announcement No. 925, effective January 1, 2026. The regulation stipulates that pesticide formulation products shall indicate the registration certificate number and manufacturer name of the active ingredient (concentrates) used. Relevant information may be incorporated into traceable electronic information codes, with the holder of the formulation product registration certificate bearing responsibility for its authenticity.
– Ministry of Agriculture and Rural Affairs of the People’s Republic of China Announcement No. 925.
(Official Link: https://www.moa.gov.cn/govpublic/ZZYGLS/202507/t20250731_6476189.htm)
– Responsible Officials from the Department of Crop Production Management (Pesticide Management Department) and the Department of Legal Affairs of the Ministry of Agriculture and Rural Affairs Respond to Journalists’ Questions Regarding Announcement No. 925 of the Ministry of Agriculture and Rural Affairs.
(https://www.moa.gov.cn/gk/zcjd/202507/t20250731_6476209.htm)
– Regarding this interpretation: This announcement, known domestically as the “one certificate, one product” system, is currently the hottest topic in the pesticide industry. It signifies the end of the era where pesticide companies authorized others to use their certificates or used a single certificate for multiple products. Since pesticides previously produced under authorized letters will no longer be permitted, a large number of distributors will have no choice but to purchase pesticide formulations directly from the manufacturers of technical-grade. Consequently, industry experts predict that after the “One Certificate, One Product” policy takes effect in 2026, at least 80% of pesticide products will vanish from the market overnight. Agricultural supply distributors will transition from the previous “product surplus” to “supply shortages,” potentially facing the predicament of having “nothing to sell.” We believe this Chinese measure closely resembles the BPR Regulation (EU 528/2012) in 2013, which requires all active substances sold in the EU market to be included in the Authorized Supplier List (Article 95 List) by September 1, 2015. Additionally, it parallels No. 3 and 6 of Article 58 (Placing on the market of treated articles) within the BPR Regulation.

# Last updated on 11 Sept., 2025.

We supply Brodifacoum TC, Bromadiolone TC and Difenacoum intermediate 6

State designated rodenticide manufacturer (China)

International Representative (Singapore)

“Bromadiolone” and “Brodifacoum” have been included in the “2015 List of Hypertoxic Chemicals,” classified as the highest-level controlled hazardous substances in China.

Siyang Rodenticide Factory is the sole legally authorized enterprise in China for exporting hypertoxic “Bromadiolone TC and Brodifacoum TC” holds a Hazardous Chemicals Permit issued by the Ministry of Emergency Management (MEM).

2025 marks the 40th anniversary of our factory’s establishment

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