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Brodifacoum, Brodifacoum manufacturer in China

BRODIFACOUM TC

  • Brodifacoum Technical Material 98% Min.
  • MOA’s Reg. No.: PD20070323 (✔)
  • China’s Hypertoxic Chemicals Permit (✔)
  • 2017 Restricted Pesticide License (✔)
  • UN3027, Class 6.1, PG: I. (Steel) (✔)
  • Legislated Tariff No.: 293220-9011 (✔)
  • The most potent ‘super-warfarin’ rodenticide, ideal for controlling larger pests, features a complex 8-step synthesis process.

BROMADIOLONE TC

  • Bromadiolone Technical Material 98% Min.
  • MOA’s Reg. No.: PD20070322 (✔)
  • China’s Hypertoxic Chemicals Permit (✔)
  • 2017 Restricted Pesticide License (✔)
  • UN3027, Class 6.1, PG: I. (Steel) (✔)
  • Legislated Tariff No.: 293220-9013 (✔)
  • The most widely used 2nd-generation anticoagulant rodenticide, a 4-step manufactured coumarin derivative.

DIFENACOUM STAGE 6

  • C22H20O, CAS#56181-66-9, Registration (✔)
  • Since the 2005 Industrial Policy Directory (now the 2024 edition), China has banned the production of new rodenticide active ingredients, including Difenacoum. We used to have an approved production line for producing some intermediates for export.
  • Synthesized in the same manner as Brodifacoum without the Bromine in initiation, ecologically safer for birds.

China’s Most Critical “Hypertoxic Chemicals” Permit

Mandatory licensing since 2002, in accordance with the “Work Safety Law of the People’s Republic of China” and the “Regulations on Safe Management of Hazardous Chemicals.”

(the Regulations on the Safe Management of Hazardous Chemicals underwent their second revision in 2011)
(the Catalogue of Hazardous Chemicals has now been
updated to 2015 edition)

(China’s Work Safety Law underwent its third revision in 2021)

In the 2015 Catalogue, #2413 corresponds to Brodifacoum (labeled as “Hypertoxic”)

In the 2015 Catalogue, #2414 corresponds to Bromadiolone (labeled as “Hypertoxic”)

The primary regulatory authorities for these two hazardous substances are the Ministry of Public Security (MPS ) and the Ministry of Emergency Management (MEM, formerly SAWS.)

  • “Technical Brodifacoum” and “Technical Bromadiolone” have both been classified by the WHO in Class Ia – “Extremely Hazardous,” based on acute oral LD50 of 0.3 mg/kg and 1.12 mg/kg for rats, respectively. In the European Union, they are classified as Class I (Very Toxic) under EU Directive 67/548/EEC (now the CLP Regulation, Regulation (EC) No 1272/2008).
  • The “China Directory of HyperToxic Chemicals (2015 edition)” was compiled based on the list of substances labeled as “Hypertoxic” (Chinese characters: 剧毒, Mandarin: Jù Dú, meaning Extremely Toxic) in the “China Catalogue of Hazardous Chemicals (2015 Edition)” (Current) formulated by the State Administration of Work Safety (SAWS) and other relevant ministries and commissions. Compared to the “China Directory of Hypertoxic Chemicals (2002 edition),” the criteria for determining “Hypertoxic” have changed – for example, in the 2002 edition of the Directory, the acute LD50 (rat oral) reference was ≤50 mg/kg, while in the 2015 edition, it has been revised to ≤5 mg/kg
    – the above from https://zh.wikipedia.org/zh-sg/剧毒化学品名录
  • Brodifacoum (2015 Hazard Identification #2413, labeled as “Hypertoxic”) and Bromadiolone (2015 Hazard Identification #2414, labeled as “Hypertoxic”) are the highest level hazardous chemicals controlled in China. The regulatory provisions for the Hypertoxic chemicals “Brodifacoum and Bromadiolone” in China are as follows:
    – Legal Provisions for Production and Operations: the “Work Safety Law” (typically referring to the “Law of the People’s Republic of China on Work Safety (2002 Edition)” (now the 2021 Edition); (https://www.mem.gov.cn/fw/flfgbz/fg/202107/t20210716_416558.shtml)
    – Regulations for Permits (Production, Storage, Use, Operation, and Transportation):
    the “Regulations on Safe Management of Hazardous Chemicals in China (2002 Edition)” (now the 2011 edition, State Council Order No. 591); and the “Catalogue of Hazardous Chemicals (2002 edtion)” (now updated 2015 edition); (https://www.gov.cn/zwgk/2011-03/11/content_1822783.htm)
     
    – Special Controls for Procurement and Road Transportation:
    the “Measures for the Administration of Permits for the Purchase and Transportation of Hypertoxic Chemicals” (Ministry of Public Security Order No. 77, 2005); (https://www.gov.cn/zhengce/2021-12/25/content_5712923.htm)

    – Targeted Storage Regulations: the “Public Safety Protection Requirements for Storage Facilities of Hypertoxic Chemicals and Radioactive Sources” (the standard “GA 1002-2012” promulgated by the Ministry of Public Security in 2012).
  • The two main authorities responsible for regulating industrial (technical material, pure) Brodifacoum and Bromadiolone are the Ministry of Public Security (MPS) and the the Ministry of Emergency Management (MEM) (formerly SAWS, the State Administration of Work Safety).
  • # Latest update:
    The SAWS General Office has issued the “Implementation Guidelines for the ‘List of Hazardous Chemicals’ (Trial) (2015)” and published the “Hazard Classification” section of the “List of Hazardous Chemicals” as an appendix. For example, Hazard Code 2413, “Brodifacoum”, has the following hazard classifications: “Acute Tox. 1; Acute Tox. 1; Acute Tox. 1; STOT RE 1; Aquatic Acute 1; Aquatic Chronic 1; Repr. 1A.”

  • “Hypertoxic Chemicals License” issued by MEM (formerly by SAWS)
    Since 2002, in accordance with the “China’s Work Safety Law” and the “Catalogue of Hazardous Chemicals,” the production and sale of technical Bromadiolone and Brodifacoum in China have been subject to mandatory hazardous chemical licensing management, reviewed and approved by SAWS. In 2018, this responsibility was assumed by the newly established MEM. In 2021, the relocation of our factory’s new site passed the inspection by the MEM department and obtained an updated hazardous chemical license.
    Official website for verifying Hazardous Chemical Permits:
    – https://whjy.mem.gov.cn/#/licenseSearch
    Please click to view the verification results for Siyang Rodenticide Factory.
  • # Latest update:
    Siyang Rodenticide Factory completed the renewal of its new MEM’s Hypertoxic Chemical Permit (Technical Brodifacoum and Technical Bromadiolone) on 24, June, 2024, which is valid until 23, June, 2027.
    Please click to view the MES’s extreme toxic chemical license.

The National Industrial Policy Directory
(updated from the 2005 to now the 2024 edition)

is based on the China National Industrial Guidelines promulgated by the State Council in 2005.

China has banned NEW rodenticide manufacturers and NEW active ingredients since 2005

  • On December 2, 2005, China’s “National Industrial Guidelines” officially came into effect. That is, the “Decision of the State Council on Promulgating the ‘Interim Provisions on Promoting Industrial Structure Adjustment’ for Implementation” (GuoFa [2005] No. 40 of the State Council), which remains a current directive.
    – Official link:
    https://www.gov.cn/zwgk/2005-12/21/content_133214.htm
  • In 2005, the National Development and Reform Commission (NDRC) issued the first edition of “Directory for Guiding Industry Restructuring.” This document is a detailed regulatory document based on the 2005 “National Industrial Guidelines” and is commonly referred to as “National Industrial Policies” in China. Since then, the content of the directory has been adjusted several times in accordance with actual circumstances, with the latest version being the 2024 edition. The directory is divided into three categories: “encouraged,” “restricted,” and “eliminated.” The “Restricted Category” primarily refers to prohibitions on new production capacity, aiming to prevent blind expansion and redundant construction within industries.
  • Since the directory’s inaugural publication in 2005 through the current 2024 edition, “highly toxic pesticides” have consistently been classified under the “Restricted Category.” Furthermore, all editions explicitly designate the rodenticides “Warfarin, Coumatetralyl, Bromadiolone, and Brodifacoum,” as restricted industry, meaning any new production projects involving these active ingredients within China are prohibited.
  • # Latest update: China’s restrictions on the rodenticide manufacturing industry (between 2005 and 2025, a span of 20 years):
    2005 edition, (Category II: Restricted, Paragraph 4, Section 37)
    https://www.ndrc.gov.cn/xxgk/zcfb/fzggwl/200512/t20051222_960679.html
    2011 edition (Category II: Restricted, Page 66 and 67)
    https://www.gov.cn/gzdt/att/att/site1/20110426/001e3741a2cc0f20bacd01.pdf
    2021 edition (Category II: Restricted, Paragraph 4, Section 8)
    https://www.gov.cn/zhengce/2021-12/27/content_5713262.htm
    2024 edition (Category II: Restricted, Page 88)
    https://www.ndrc.gov.cn/xxgk/zcfb/fzggwl/202312/P020231229700886191069.pdf

China Issues “Catalogue of Projects Prohibited from Land Use”

Based on the National Industrial Policy Directory

(the Measures has now been updated to 2024 edition)

(In short, since 2006, manufacturers of technical-rodenticides in China have been prohibited from relocating their facilities.)

Since 2006, China bans technical-rodenticide production from occupying new land.

  • On December 12, 2006, based on the National Industrial Policy Catalog (2005 Edition), the Ministry of Land and Resources and the National Development and Reform Commission jointly formulated the “Catalogue of Projects Restrictions from Land Use (2006 Edition)” and the “Catalogue of Projects Prohibited from Land Use (2006 Edition).” Among these, highly toxic pesticide active ingredients such as “Warfarin, Coumatetralyl, Bromadiolone, and Brodifacoum” were included in the “Catalogue of Prohibited Land Use Projects.” It stipulates that construction projects involving these substances or employing the listed processes, technologies, or equipment shall not be approved by land and resources management departments or investment management departments at any level.
    https://www.gov.cn/zwgk/2006-12/18/content_471717.htm
  • On May 23, 2012, the Ministry of Land and Resources and the National Development and Reform Commission issued and implemented the “Catalogue of Projects Restrictions from Land Use (2012 Edition)” and the “Catalogue of Projects Prohibited from Land Use (2012 Edition).” Its promulgation was primarily based on the updated 2011 edition of the national industrial policy.
  • On December 2, 2024, the Ministry of Natural Resources (formerly MLR), the National Development and Reform Commission (NDRC), and the National Forestry and Grassland Administration (Administered by the Ministry of Natural Resources, it primarily oversees China’s remote forest, grassland, wetland, and desert regions, such as those in Inner Mongolia, Jilin, and Heilongjiang) jointly issued the “Guidance Catalog for Natural Resource Elements Supporting High-Quality Industrial Development (2024 Edition),” replacing the 2012 editions of the “Catalogue of Projects Restrictions from Land Use” and “Catalogue of Projects Prohibited from Land Use.” Its promulgation was primarily based on the updated 2024 edition of the national industrial policy. It stipulates that new projects listed in the “Restricted Category” and projects listed in the “Elimination Category” of the “Industrial Structure Adjustment Guidance Catalogue (2024 Edition) ” (the national industrial policy) shall be directly included in the “Prohibited Catalogue” of this catalogue. The competent departments of natural resources, investment management, and forestry and grassland administration shall not process any related procedures whatsoever.
    https://www.gov.cn/zhengce/zhengceku/202412/content_6994373.htm

Production License for Rodenticides (Pesticide Category) in China from 2007 to 2017.

– base on the “Pesticide Law” and “National Industrial Policies”

(China’s Pesticide Law updated to 2017 edition)

(Directory of National Industrial Policy update to 2024 edition)

When Bromadiolone and Brodifacoum were officially designated as National pesticides in China in 2007, their production required a Production License issued by the “General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ).”

Since the implementation of the new Pesticide Law in 2017, AQSIQ has transferred the responsibility for renewing these production licenses to the Ministry of Agriculture (now renamed the Ministry of Agriculture and Rural Affairs, MARA).

  • Siyang Rodenticide Factory is a “nationally designated rodenticide” production unit. The term “nationally designated rodenticide” refers to rodenticides that are legally produced, i.e., a technical pesticide rodenticide production enterprise. The production of technical rodenticides in China requires approval from all relevant national ministries and commissions (MOA, MEP, SWAS, NDRC, MIIT, AQSIQ). In addition to obtaining the basic “Hazardous Chemicals Production License,” manufacturers must also secure a “Pesticide Production License” before commencing production. The basic procedure is as follows:
    ✔ (1) Since the implementation of the “Pesticide Management Regulations” in China in 1997, rodenticide products, as one category of pesticides, must be registered with the Ministry of Agriculture (MOA).
    ✔ (2) The production of technical rodenticides as a chemical industry project requires approval from three ministries. First, the National Development and Reform Commission (NDRC) must approve the “project initiation.” Next, the Ministry of Environmental Protection (MEP, now the Ministry of Ecology and Environment (MEE)) must conduct a safety and environmental assessment of the production site’s discharge of “three wastes” (wastewater, waste gas, and solid waste). Finally, in accordance with the 2002 Work Safety Law and the Regulations on the Management of Hazardous Chemicals, the production site’s safety facilities must obtain a statutory “Hazardous Chemical Permit” issued by the State Administration of Work Safety (SAWS, now MEM).
    ✔ (3) Since the establishment of the Ministry of Industry and Information Technology (MIIT) in 2008, it has taken over some of the functions previously handled by NDRC. Based on the “2005 National Industrial Guidelines” issued by the State Council and the “National Industrial Policy Directory” of the NDRC, the MIIT conducts inspections to verify the legality of technical pesticide production facilities and issues an announcement approving production. This process is referred to as the “State-designated Pesticide Production Site.”
    ✔ (4) Finally, enterprise apply for pesticide production licenses from two different departments based on the production approval announcement issued by the MIIT. (i) For General pesticides, enterprise must apply for a pesticide production license from the MIIT; which is the “Pesticide Production Approval Certificate;” (ii) For National standard pesticides, enterprises must apply to the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) for a pesticide production license (the literal Chinese translation being: “National Industrial Product Production License”).
  • The Final Outcome of China’s Rodenticide Industry:
    Since “National Industrial Policy” in 2005, the Catalogue of Projects Prohibited from Land Use in 2006, the implementation of the national production license by AQSIQ in 2007 and the establishment of MIIT in 2008, China’s rodenticide industry has undergone a series of stringent safety production review systems. This system encompasses comprehensive data requirements for pesticide registration, while production facilities must comply with safety production standards and environmental discharge regulations. Consequently, the number of qualified rodenticide active ingredient manufacturers in China has decreased from five to two (Siyang and Tianjin). It is worth noting that two of the three eliminated enterprises were state-owned companies, located in Shanghai and Zhangjiakou, Hebei Province.
  • With the promulgation of the new Pesticide Law in 2017, the two production license-issuing departments (AQSIQ and MIIT) were fully taken over by the MOA. This marks the completion of the industrial revolution in China’s Pesticide Industry after more than two decades of development and reform.
  • # Latest update:
    In 2024, the State Administration for Market Regulation (SAMR, former AQSIQ) and the Standardization Administration of China (SAC) released the first part of the GB 30000 series, titled “Classification of Chemical Labels Part 1: General Rules” (GB 30000.1-2024). This standard is technically consistent with the United Nations “Globally Harmonized System of Classification and Labelling of Chemicals” (GHS) (Eighth Edition) and will officially take effect on August 1, 2025.

China’s New Pesticide Law of 2017

(Qualification Certification for “State Designated Restricted-Pesticides Sales Sites” Under the New Regulations)

  • New China’s Pesticide Law
    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.
    (https://www.gov.cn/gongbao/content/2017/content_5186961.htm)
  • “List of Restricted Pesticides (2017 Edition)”
    On August 31, 2017, the Ministry of Agriculture (MOA) of China issued Announcement No. 2567, the “List of Restricted Pesticides,” which included a total of 32 pesticides. Among these, 22 pesticides are restricted to being sold only at sites designated by the state, including four coumarin-based rodenticides: “Warfarin (Restricted List#19), Coumatetralyl (Restricted List#20), Bromadiolone (Restricted List#21), and Brodifacoum (Restricted List#22).”
    (http://www.moa.gov.cn/nybgb/2017/dsq/201802/t20180201_6136189.htm)
  • In 2018, the MOA was officially renamed the Ministry of Agriculture and Rural Affairs (MARA).
  • February 1, 2019: Siyang Rodenticide Factory passed the new “State designated restricted-pesticide sales sites” review by the MARA.
  • # Latest update: In September 2021, Siyang Rodenticide Factory completed its relocation and obtained a new MARA Restricted Pesticide License Number at its new location: (Su) 32000013199. This license is valid until September 14, 2026.
    (http://nynct.jiangsu.gov.cn/art/2025/3/19/art_80243_11352.html)
  • Please click to view the MARA’s Restricted Pesticides License.

Mandatory Inspection of Bromadiolone and Brodifacoum exports

under the “2015 Directory of Hazardous Chemicals” and the “2017 Pesticides Law”

The General Administration of Customs (GAC) & the Ministry of Agriculture and Rural Affairs (MARA).

The export of pesticides from China is jointly regulated by the MOA and Customs. In China, the statutory tariff number for the pesticide “Brodifacoum” is “2932209011,” and the statutory tariff number for “Bromadiolone” is “2932209013.”

  • In 2018, AQSIQ merged with the newly established “State Administration for Market Regulation” (SAMR). 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).
    –  http://www.customs.gov.cn/customs/ztzl86/302414/302415/zl70zn_fdxsd/2566516/2585161/index.html
  • December 18, 2020: The General Administration of Customs of China issued GAC Announcement No. 129 of 2020, the “Announcement on Issues Concerning the Inspection and Supervision of the Import and Export of Hazardous Chemicals and Their Packaging” in accordance with the “Regulations on the Management of Hazardous Chemicals (2011)” promulgated by the State Council Order No. 591 and the latest edition of the “Catalogue of Hazardous Chemicals (2015).” This announcement supersedes Announcement No. 30 issued by the former AQSIQ in 2012.
    Mandatory inspections are required for the import and export of hazardous chemicals listed in the “Catalogue of Hazardous Chemicals (2015).” Relevant measures include: reporting the hazard category, UN hazard number, and UN packaging mark; providing the “Certification of Hazardous Classification and Identification,” “Performance Inspection Results of Packages for Transportation of Exported Goods,” and the “Certificate of Inspection for the Use of Packaging for the Transport of Dangerous Goods for Export”; and complying with UN TDG hazard classification and hazardous packaging requirements, as well as UN GHS labeling requirements.
    There are 28 pesticides in the new “Catalogue of Hazardous Chemicals (2015)”, including three coumarin-based rodenticides as “Warfarin, Brodifacoum and Bromadiolone“.
    (http://www.customs.gov.cn/customs/302249/302266/302267/3476363/index.html)
  • Dec 31, 2021, In order to implement the obligations of the “Rotterdam Convention”, the GAC and the MARA jointly issued “Announcement the No. 416” in accordance with the “Chinese Customs Law” and the “Regulation on Pesticide Administration”.
    (https://www.gov.cn/zhengce/zhengceku/2021-12/31/content_5665804.htm)
    The latest version of the “Catalogue of the People’s Republic of China for the Administration of the Import and Export of Pesticides (2022 edition)” was published as an annex to the “Joint Announcement No. 416 of GAC and MARA.” 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.” Both of these codes remain unchanged from the previous version.
    (https://www.gov.cn/zhengce/zhengceku/2021-12/31/5665804/files/a690fececdf44b9aba505e6e40bb19ae.doc)

Siyang Rodenticide Factory

(1985 – 2025) – 40th Anniversary

Siyang Rodenticide Factory was established in March 1985, as the name implies, it is a professional rodenticide manufacturer located in Siyang County, China.

A leader in the development of rodenticides in China, the facotry has successfully challenged the industrial production of six anticoagulant rodenticides over the past few decades, including “Chlorophacinone, Warfarin, Coumatetralyl, Bromadiolone, Brodifacoum and Difenacoum.”

Two national rodenticides in China since 2006

Brodifacoum TC (GB 20690-2006), Statutory purity: 95% Min.

Bromadiolone TC (GB 20678-2006), Statutory purity: 97% Min.

In 2005, Siyang Rodenticide Factory participated in the Chinese Rodenticide Standards Review Meeting held by ICAMA (Institute for the Control of Agrochemicals, Ministry of Agriculture): all indicators for Bromadiolone and Brodifacoum were unanimously approved at the meeting, meaning that national standards will be further released.

In 2006, China SAC and AQSIQ (now SAMR) jointly enacted national standards (GB) for Brodifacoum and Bromadiolone, which came into effect in 2007.

The Revolution in Rodenticide Regulation in China (1985 -2025)

Currently, the production and sale of technical rodenticides in China, such as Brodifacoum TC and Bromadiolone TC, will be mainly regulated by three national ministries: MPS, MEM and MARA.

In 1985, Siyang Rodenticide Factory was established with the approval of the former Ministry of Chemical Industry.

In 1997, China promulgated its first “Pesticide Management Regulations.”
Regulated by: ICAMA (the “Institute for the Control of Agrochemicals, MOA“).

In 1998, the State Council abolished the Ministry of Chemical Industry. (After the NDRC established in 2003 and introduced industrial policies in 2005, its final work was taken over by the MIIT established in 2008.)

In 2002, China promulgated its first “Law of the People’s Republic of China on Work Safety” (Work Safety Law),” the”Regulations on the Safety Management of Hazardous Chemicals,” and the“Catalogue of Hazardous Chemicals.”  (Regulated by: SAWS, now MEM)

  • In 2005, China State Council promulgated the “2005 National Industrial Directive”, along with detailed “Industrial Policy Directory” issued by NDRC. (New rodenticide players and new rodenticide active ingredient are prohibited in China.)

  • In 2005, the Ministry of Public Security (MPS) promulgated the “Measures for the Administration of Permits for the Purchase and Road Transportation of Hypertoxic Chemicals.” (the effective regulations in force)

  • In 2007, the AQSIQ and the Standardization Administration of China (SAC) jointly promulgated the China national standards (GB) for Bromadiolone and Brodifacoum. (GB Production licensed by AQSIQ.)

  • In 2008, the MIIT was established, taking over some of the responsibilities of the NDRC. The ministry is primarily responsible for assessing and certifying technical-pesticide production sites by “national industrial policy” and issuing “qualified production site” announcements so that companies can further apply for pesticide production licenses from the MIIT (for general pesticides) or the AQSIQ (for GB pesticides.)

  • In 2012, the Ministry of Public Security (MPS) promulgated the GA 1002-2012 standard, namely the “Public Safety Protection Requirements for Storage Facilities of Hypertoxic Chemicals and Radioactive Sources.” (the effective regulations in force)

  • In 2015, a new “Catalogue of Hazardous Chemicals” was published, which included a “2015 list of Hypertoxic Chemicals.” (Regulated by: MPS and SAWS.)

  • In 2017, a new Pesticide Law was introduced, along with a new “2017 List of Restricted Pesticides.” The MOA took over the work of the MIIT and the AQSIQ. (MOA renamed the “Ministry of Agriculture and Rural Affairs” (MARA) in 2018)

  • In 2021, the China’s Work Safety Law which came into effect in 2002, underwent its third revision (the first revision was in 2009, and the second was in 2014). (Regulated by: the Ministry of Emergency Management, MEM, formerly SAWS)