Chemical Solvents: What issues should be noted when purchasing?

As a global B-end buyer purchasing solvents, the core risks cover flammability, toxicity, precursor chemical control, environmental regulations, cross-border SDS requirements, local hazardous chemical licenses, as well as VOC and residue limit standards. The details are explained as follows.

1) First Step: Classify the Global Regulatory Category of the Purchased Solvent

Solvents are not ordinary chemical products and many fall under strict regulatory restrictions:

• Flammable Liquids (Most Common): Flash point ≤ 60℃ (Acetone, Ethanol, Ethyl Acetate, Toluene, Xylene, NMP, DMF, etc.), classified as UN Class 3 Hazardous Goods. UN number, packaging certificate and hazard labels are mandatory for sea, land and air transportation.

• Precursor Chemicals / Explosive Precursors: Acetone, Toluene, Sulfuric Acid, Hydrochloric Acid, Methyl Ethyl Ketone, etc. Almost all countries require public security / drug regulatory approval, purchasing licenses, real-name registration, purchase quotas and account record-keeping; purchase is not available by payment alone.

• Highly Toxic / Carcinogenic Substances / REACH SVHC: Benzene, Trichloroethylene, Methylene Chloride and some chlorinated hydrocarbons are included in the EU REACH SVHC List (251 items). Disclosure is mandatory for content over 0.1%, and notification is required for annual volume over 1 ton; many countries impose direct restrictions or bans.

• VOC & Environmental Restrictions: Strict controls are enforced by the EU, US EPA and China. For example, the EU 2025 new regulation limits aromatic hydrocarbons ≤ 0.1%; US government procurement requires VOC ≤ 1g/L; benzene is prohibited from detection in food printing applications.

Procurement Principle: Require suppliers to provide CAS Number, GHS Classification, UN Number, and confirmation on precursor chemical/SVHC attributes. Reject suppliers that fail to provide these documents.

2) Global Mandatory Documents: SDS/MSDS + GHS Labeling (Indispensable)

For solvents sourced from any country, non-compliant SDS will result in customs clearance failure, warehousing prohibition and usage restriction.

• 16-section Mandatory SDS: Must include physical and chemical properties (flash point, boiling point, explosion limit), toxicology, ecological hazards, transportation regulations, legal provisions and emergency disposal guidelines. Bilingual versions in English and the destination country's language (German/French/Spanish for the EU) are required.

• GHS Labeling: Must display hazard pictograms (flame / skull and crossbones / corrosion), signal words, hazard statements, precautionary statements, supplier information and batch number. Labels must be firmly attached to outer packaging with waterproof and sun-resistant performance.

• Global Mutual Recognition with Regional Differences: EU REACH/CLP, US OSHA/HCS, China GB 30000 and Japanese GHS adopt different standards. SDS must be compiled per the destination country's template; simple literal translation is not acceptable.

3) EU REACH: The Hard Threshold for Solvent Procurement

The EU implements the world's strictest chemical regulations. Any solvent sold to or used in EU products must comply with the following rules:

• Registration: Suppliers must register pure solvents or mixtures with ECHA for annual volume ≥ 1 ton, providing registration number and CSR (Chemical Safety Report).

• SVHC Notification: Notification is mandatory if SVHC content exceeds 0.1% (w/w) with annual volume ≥ 1 ton; disclosure in SDS and supply chain is required for content over 0.1% but annual volume below 1 ton.

• Restrictions (Annex XVII): Trichloroethylene, benzene, formaldehyde and other substances are subject to content limits or bans; e.g. benzene content ≤ 0.1%.

• CLP Classification & Labeling: Classification must follow EU GHS standards with multi-language labeling.

Procurement Action: Request suppliers to provide REACH registration number, SVHC compliance declaration and test reports; avoid EU market access without complete documents.

4) The United States: Triple Regulation of OSHA + EPA + State-level VOC Standards

• OSHA: SDS must be in English; workplace exposure limits (PEL) must be specified in SDS. Warehousing and usage must comply with 29 CFR 1910.

• EPA: Regulates VOC emissions, hazardous waste (RCRA) and Clean Water Act (CWA). Solvents containing heavy metals/halogenated hydrocarbons may be classified as hazardous waste requiring qualified disposal.

• Stricter State Regulations: California CARB, New York, Illinois and other states impose stricter VOC limits, packaging recycling and reporting requirements.

5) Asia & Other Regions: China, Japan, South Korea, Southeast Asia, South America

• China: Mandatory hazardous chemical business license, precursor chemical purchase permit, hazardous chemical registration, GB 30000 labeling and SDS (GB/T 16483). The 2026 new regulation imposes production suspension and fines for unregistered products.

• Japan: Controlled by METI Chemical Review Law, MHLW Industrial Safety and Health Law and VOC Law. Bilingual SDS (Japanese & English) and GHS labeling are required; specific solvents such as benzene series are restricted or banned.

• South Korea: Governed by K-REACH, OSHA and VOC regulations, adopting rules similar to the EU including registration, SVHC notification and substance restrictions.

• Southeast Asia & South America: Most regions reference EU REACH or US EPA standards with inconsistent enforcement. SDS, GHS labeling and hazardous chemical licenses are universally required.

6) Transportation & Packaging Compliance: Global Sea, Land & Air Restrictions

• Maritime Transport (IMDG): UN Class 3 flammable liquids require UN number, packaging category (I/II/III), packaging performance certificate, hazard label and MSDS. Solvents with flash point < 23℃ are mostly Category II packaging.

• Air Transport (IATA): More stringent restrictions on volume, packaging, labeling and documentation; many high-flash-point solvents are restricted by air freight.

• Land Transport (ADR/RID): EU/European inland transport requires ADR compliance, qualified drivers, explosion-proof vehicles and escort personnel.

• Packaging Requirements: UN-certified drums, leak-proof, anti-static and light-shielding design; wooden packaging requires IPPC fumigation certificate.

7) Impurity & Residue Control: Strictest Standards for Food / Pharmaceutical / Electronic Industries

• ICH Q3C / USP <467>: Pharmaceutical solvents are divided into 3 categories: Class 1 (Benzene, Carbon Tetrachloride) prohibited; Class 2 with usage limits; Class 3 low-toxicity permitted.

• Food Contact Materials: Regulated by EU 1935/2004 & 2023/2006, US FDA 21 CFR and China GB 9685. Benzene must be undetectable; Toluene/Xylene are subject to strict limits.

• Electronics / Lithium Battery Industry: High purity, low moisture, low heavy metal and low ion content required; e.g. NMP moisture content < 100ppm.

8) Supplier Qualification Verification (Global Universal)

Verify and retain stamped copies of the following documents:

• Business License (with hazardous chemical business scope)

• Hazardous chemical production / operation license (covering purchased categories)

• SDS + GHS Labeling + UN Number

• Precursor chemicals: Public security filing + purchasing license

• REACH: Registration number + SVHC declaration + test reports

• Quality Documents: COA (Certificate of Analysis), purity report, impurity report and batch records

Summary of Solvent Procurement Compliance (Concise Version)

For global B-end solvent buyers, the core compliance principle is Classification First → Document Completion → Local License Approval → Transportation & Impurity Control:

1. Classification: Confirm flammability (Class 3), precursor chemical attribute, high-toxicity/SVHC inclusion and VOC restrictions;

2. Documents: Mandatory provision of 16-section multi-language SDS, GHS labeling, UN number and COA;

3. EU Market: REACH registration, SVHC notification, CLP labeling and restricted substance compliance;

4. US Market: OSHA-compliant SDS, EPA VOC/hazardous waste regulation and state-level compliance;

5. Asia & Other Regions: Local hazardous chemical license, precursor chemical approval and GHS labeling;

6. Transportation: IMDG/IATA/ADR compliance, UN-certified packaging, hazard labels and complete documentation;

7. Impurity Control: Comply with ICH Q3C for pharmaceuticals, food contact limits and high-purity standards for electronics;

8. Supplier Management: Complete qualifications, traceability system and available test reports.