China expanded its export control list for precursor chemicals by adding two fentanyl-related substances, requiring export permits for shipments to the United States, Mexico, and Canada starting September 22, 2026.
China’s Ministry of Commerce and four other agencies added two fentanyl-related chemicals to a list of goods that need an export licence when shipped to the United States, Mexico and Canada, starting Sept. 22, 20261.
The two chemicals are methyl 1-phenethyl-4-oxo-3-piperidinecarboxylate and ethyl 1-phenethyl-4-oxo-3-piperidinecarboxylate1. They are precursor chemicals, meaning raw materials that can be used to make drugs.
In short, a Chinese exporter can no longer ship these two chemicals to the United States, Mexico or Canada without first getting a licence. Shipments to most other countries do not need one.
What does Announcement No. 40 change?
The measure is Ministry of Commerce Announcement No. 40 of 2026, dated Sept. 22, 20261. It changes the Catalogue for the Administration of Precursor Chemicals Exported to Specific Countries (Regions). This is China’s list of drug-making chemicals that need a licence when shipped to certain countries.
The announcement adds the two chemicals to Part 1 of Annex 1 of the catalogue1. Part 1 covers exports to the United States, Mexico and Canada. Part 2 covers exports to Myanmar, Laos and Afghanistan1.
Which agencies signed the chemical export notice?
Five Chinese government bodies issued the announcement together1:
- the Ministry of Commerce
- the Ministry of Public Security, which runs the police
- the Ministry of Emergency Management
- the General Administration of Customs
- the National Medical Products Administration, China’s drug regulator
The Ministry of Commerce’s Security and Control Bureau published it1. The legal basis is China’s Interim Provisions on the Administration of Exports of Precursor Chemicals to Specific Countries (Regions)1.
When do the licences for US, Mexico and Canada shipments start?
The rule took effect on the day it was published, from Sept. 22, 20261. There was no waiting period. Any shipment of the two chemicals to the three countries leaving China from that date needs a licence.
From white paper to new licence rule
Exporters must apply under the Interim Provisions1. The announcement says exports of the listed chemicals to other countries and regions need no licence under this catalogue1. This means the licence depends on the country of destination, not only on the chemical.
How does China approve precursor export licences?
China already has a separate, wider licence system for precursor chemicals. A March 2025 statement from the Ministry of Commerce spokesperson describes how it works2.
How a precursor export licence is approved
Before the ministry approves an export licence, the Ministry of Public Security sends a check request to the importing country’s government2. It uses the Pre-Export Notification system (PEN), run by the International Narcotics Control Board, a United Nations body2. The ministry issues the licence only after the check confirms the trade is legal2.
At export, customs clears the goods based on the company’s declaration and the export licence2. A shipment without the licence cannot clear customs.
Which fentanyl precursors were already controlled?
China’s white paper, Controlling Fentanyl-Related Substances – China’s Contribution, was published by the State Council Information Office in March 20253. It lists five fentanyl precursors already under control: 4-ANPP, NPP, 4-AP, 1-boc-4-AP and norfentanyl3.
Fentanyl precursors already controlled, by class
The white paper says 4-ANPP and NPP are the two most direct raw materials for fentanyl-related drugs3. China lists them in Class I, its strictest group of precursor chemicals3. The other three are in Class II3.
The white paper also says China was working to control 4-piperidone and 1-boc-4-piperidone3. The United Nations added those two chemicals to its control list in 20243. The two chemicals added in September 2026 are different substances from these.
What does the new rule mean for chemical shipments?
The two new chemicals are now treated like the others on the list when they go to North America. Exporters must file for a licence and wait for the check with the buyer’s government before the goods leave. A shipment to the same buyers without a licence will be stopped at Chinese customs.
The full list of controlled chemicals is in Annex 1 of Announcement No. 40, with the list of countries in Annex 21. The Ministry of Commerce published both annexes with the announcement on Sept. 22, 20261.
Sources
- ↩ 商务部等5部门关于调整《向特定国家（地区）出口易制毒化学品管理目录》的公告 https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_7dad5aea5c7a40c992c99aedfa7d2ebd.html
- ↩ 商务部新闻发言人就《中国的芬太尼类物质管控》白皮书答记者问. http://www.mofcom.gov.cn/xwfb/xwfyrth/art/2025/art_7df201c3b3224fe9a56eafaebc725802.html
- ↩ Full text: Controlling Fentanyl-Related Substances – 驻莱索托大使馆 https://ls.china-embassy.gov.cn/eng/zytz_0/202607/t20260728_11993936.htm