Dilemma Under Strict Legal Regulations: Why Is It Difficult to Find Transportation Channels for Chemicals?

With the revision and implementation of a series of laws and regulations such as the Regulations on the Safety Management of Hazardous Chemicals and Provisions on the Administration of Road Transport of Dangerous Goods, China’s legal supervision over chemical transportation has entered an “era of strict regulation.” From the “substantive verification” of transportation qualifications, to the “rigid standards” for operational processes, and the “severe punishment” for accident accountability, every tightening of legal provisions has driven the chemical transportation industry toward “compliance-oriented” transformation. However, against the backdrop of strict legal regulations, chemical enterprises generally face the dilemma of “difficulty in finding transportation channels”—professional hazardous goods logistics capacity is tight, ordinary logistics companies dare not accept orders, cross-regional transportation is fraught with obstacles, and even the awkward situation of “having goods but no way to transport them” has emerged. Why have chemical transportation channels become increasingly scarce under strict legal regulations? This dilemma is not simply “excessive supervision,” but the combined result of logistics enterprises’ risk avoidance, industry structural imbalances, and mismatched demand from chemical enterprises under legal constraints. This article will start with the specific manifestations of strict legal regulations, deeply analyze the core reasons for the scarcity of transportation channels, and propose a multi-stakeholder collaborative solution path, providing references for the sustainable development of chemical enterprises and the logistics industry.

I. Core Manifestations of Strict Legal Regulations: Building a “Legal Red Line Network” for Chemical Transportation

In recent years, China’s laws and regulations on chemical transportation have been continuously improved, forming a full-chain legal constraint system covering “qualifications, operations, and accountability.” These strict regulations have directly raised the entry threshold for the transportation industry and indirectly led to the contraction of transportation channels.

(1) Qualification Supervision: From “Lenient Approval” to “Strict Entry and Exit”

In the early stages, qualification approval for chemical transportation mainly focused on “document review,” with enterprises able to obtain qualifications by submitting relevant documents. However, current laws have upgraded qualification supervision to a “strict entry and exit” model, significantly reducing the number of compliant transportation entities:

• Substantially Higher Entry Thresholds: According to the revised Provisions on the Administration of Road Transport of Dangerous Goods, enterprises applying for chemical transportation qualifications must meet rigid conditions such as “owning no fewer than 5 dedicated vehicles,” “having compliant parking lots and maintenance workshops,” and “equipping full-time safety managers.” Regulatory authorities also conduct on-site inspections of enterprises’ hardware facilities and management capabilities. Taking parking lots as an example, laws require sites to be far from residential areas and water sources, and equipped with fire prevention and leak-proof facilities—this single requirement alone has excluded numerous small and medium-sized logistics enterprises. Data shows that the number of logistics enterprises with chemical transportation qualifications nationwide in 2023 decreased by 38% compared to 2019, directly leading to insufficient supply of compliant transportation capacity;
• Regular Dynamic Qualification Verification: Laws stipulate that regulatory authorities must conduct quarterly dynamic verification of the qualifications of chemical transportation enterprises. If issues such as “vehicles not inspected on schedule,” “expired personnel qualifications,” or “excessive safety accidents” are found, qualifications are immediately suspended or revoked. In 2024, a province conducted a special verification of chemical transportation qualifications, revoking the transportation qualifications of 23 enterprises—accounting for 15% of the total number of qualified enterprises in the province—further exacerbating capacity shortages;
• Difficulties in Cross-Regional Qualification Mutual Recognition: Standards for reviewing chemical transportation qualifications vary across provinces. Some provinces require out-of-province logistics enterprises to establish local branches and reapply for qualifications, otherwise prohibiting them from undertaking local chemical transportation business. For example, Jiangsu Province requires out-of-province hazardous goods logistics enterprises to register branch companies within the province and equip at least 3 dedicated vehicles with local license plates to undertake in-province chemical transportation orders. This regulation has blocked numerous cross-provincial transportation channels.

(2) Operational Specifications: From “Advisory Requirements” to “Mandatory Provisions”

Current laws have upgraded chemical transportation operational processes from “advisory requirements” to “mandatory provisions,” with legal penalties for violations in any link. This has made logistics enterprises concerned about the operational and risk costs of chemical transportation, thereby reducing capacity supply:

• Legally Mandatory Standards for Packaging and Securing: General Technical Conditions for Dangerous Goods Transport Packaging (GB 12463) clearly stipulates that different categories of chemicals must use packaging of specific materials and strength. For example, Class 3 flammable liquids require anti-static metal drums with a wall thickness ≥ 2 mm, equipped with anti-theft sealing rings on drum lids; Class 8 corrosive substances require acid- and alkali-resistant fiberglass-reinforced plastic drums with anti-corrosive coatings on inner walls. Laws also require logistics enterprises to conduct tightness tests on packaging before loading, with non-compliant goods prohibited from transportation. In 2023, a logistics enterprise was fined 180,000 yuan by regulatory authorities in accordance with the Regulations on the Safety Management of Hazardous Chemicals for using ordinary plastic drums to transport ethanol (failing to meet anti-static standards);
• Legal Constraints on Transport Routes and Timing: Laws require chemical transportation routes to avoid sensitive areas such as “densely populated areas, schools, hospitals, and water sources,” and route plans must be reported to transportation authorities in advance—unreported routes are deemed “illegal transportation.” Additionally, laws prohibit the transportation of highly toxic and explosive chemicals during “morning and evening peak hours (7:00–9:00, 17:00–19:00)” and “severe weather (heavy rain, heavy snow, heavy fog).” These constraints have significantly compressed the transportation time window for logistics enterprises and increased the complexity of transportation planning. Some logistics enterprises have abandoned chemical transportation business due to “inability to meet route and timing requirements”;
• Legal Obligations for In-Transit Inspections: The Provisions on the Administration of Road Transport of Dangerous Goods clearly requires mandatory inspections every 2 hours during chemical transportation, covering items such as “packaging damage, valve leakage, and securing tightness.” A Dangerous Goods Transport In-Transit Inspection Form must be completed to record inspection times, identified issues, and disposal measures. Failure to conduct in-transit inspections as required results in fines of 50,000–100,000 yuan for logistics enterprises. In 2024, a logistics enterprise was fined 70,000 yuan by regulatory authorities for failing to record in-transit inspection information, and subsequently gradually reduced the proportion of its chemical transportation business.

(3) Accident Accountability: From “Enterprise Liability” to “Multi-Party Joint Liability”

One of the core changes in strict legal regulations is the upgrade of accident accountability from “single enterprise liability” to “joint liability of enterprises, individuals, and regulatory authorities,” with significantly increased penalties. This has made logistics enterprises “awe-struck” by the risks of chemical transportation, leading them to avoid such business:

• Enterprise Accountability: Fines Combined with Qualification Revocation: According to the Criminal Law and Regulations on the Safety Management of Hazardous Chemicals, if a logistics enterprise causes chemical leaks, explosions, or other accidents due to illegal transportation, it must not only bear cargo losses and environmental remediation costs but also face fines of 10–20 times the cargo value. In severe cases, business licenses may be revoked. In 2022, a logistics enterprise used non-specialized packaging to transport sulfuric acid, causing a leak that contaminated farmland. It was ultimately fined 2.3 million yuan (15 times the cargo value) and had its hazardous chemical transportation qualifications revoked;
• Individual Accountability: From “Administrative Sanctions” to “Criminal Liability”: Laws clearly stipulate that legal representatives, drivers, and escorts of logistics enterprises who cause accidents due to intent or gross negligence must bear criminal liability. For example, drivers failing to transport according to reported routes or escorts failing to promptly detect leak hazards may constitute “dangerous driving” or “major liability accidents,” facing imprisonment. In 2023, a driver of a chemical transport vehicle caused a rollover due to fatigue driving, leading to a chemical leak and fire. The driver was sentenced to 2 years in prison, and the escort to 1 year—this case made many logistics practitioners hesitant to take on chemical transportation roles;
• Shipper Accountability: Inescapable Joint Liability: The revised Regulations on the Safety Management of Hazardous Chemicals added a “shipper joint liability” clause, stipulating that shippers who entrust unqualified logistics enterprises to transport chemicals or fail to provide Material Safety Data Sheets (MSDS) must bear joint accident liability with the logistics enterprise. This clause has made shippers more cautious in selecting transportation channels, only daring to cooperate with fully qualified professional logistics enterprises—further compressing the living space of small and medium-sized logistics enterprises and leading to greater scarcity of compliant channels.

II. Core Reasons for Scarce Transportation Channels: Multi-Stakeholder Game and Dilemmas Under Strict Legal Regulations

Against the backdrop of strict legal regulations, the scarcity of chemical transportation channels is not caused by a single factor, but by the combined effects of logistics enterprises’ risk avoidance, industry structural imbalances, mismatched demand from chemical enterprises, and insufficient regulatory coordination—forming a vicious cycle of “channel contraction and unmet demand.”

(1) Logistics Enterprises: “Active Contraction” Under Legal Risks and Cost Pressures

Faced with strict legal constraints, logistics enterprises have reduced or abandoned chemical transportation business out of risk avoidance and cost control considerations, leading to a significant reduction in the number of compliant channels:

• Excessive Risk Costs: Daring Not to Accept Orders: The legal risks of chemical transportation are far higher than those of ordinary goods. In the event of an accident, logistics enterprises not only face heavy fines but also risk qualification revocation and criminal liability. It is estimated that the average handling cost (including fines, compensation, and remediation expenses) of chemical transportation accidents in China in 2023 reached 8.5 million yuan—far exceeding the 500,000 yuan average for ordinary cargo transportation accidents. Faced with high risks, most logistics enterprises choose to “stay away,” especially small and medium-sized enterprises with weak risk resistance, which tend to focus on ordinary cargo transportation and proactively withdraw from the chemical transportation market;
• Surge in Compliance Costs: Compressed Profit Margins: To meet legal requirements, logistics enterprises must invest heavily in “hardware transformation” and “software upgrades”—purchasing dedicated transport vehicles (costing approximately 500,000 yuan each, 2–3 times that of ordinary trucks), constructing compliant parking lots (investments of approximately 2 million yuan), and conducting specialized personnel training (costing approximately 5,000 yuan per person). Additionally, legal requirements for “real-time monitoring” and “regular inspections” increase operational costs. For a medium-sized hazardous goods logistics enterprise, compliance costs in 2023 increased by 62% compared to 2019, while profit margins for chemical transportation were only 8%–12%—far lower than the 15%–20% for ordinary cargo transportation. Compressed profit margins have led some logistics enterprises to reduce their chemical transportation business;
• Severe Personnel Shortages: Difficulty Maintaining Capacity: Stricter legal requirements for driver and escort qualifications and increased accountability have led to severe personnel shortages in chemical transportation. On one hand, practitioners face higher legal risks, with the possibility of imprisonment in the event of an accident; on the other hand, specialized training and qualification certification involve high time and economic costs, combined with high work intensity (requiring regular inspections and avoiding peak-hour transportation)—leading to a reduction in the number of practitioners. In 2024, the national shortage of chemical transportation drivers reached 120,000, and some logistics enterprises were forced to reduce capacity due to “inability to recruit qualified drivers,” further exacerbating the scarcity of transportation channels.

(2) Industry Structure: Imbalance Between “Small, Scattered, and Weak” and “Professional and Strong,” with Concentrated Compliant Capacity

China’s chemical transportation industry has long suffered from a structural issue of “small, scattered, and weak” enterprises—numerous small and medium-sized logistics enterprises with weak professional capabilities, while the number of large logistics enterprises with complete qualifications and professional capabilities is small. Under strict legal regulations, this structural imbalance has been amplified, leading to highly concentrated compliant capacity and making it difficult for small and medium-sized chemical enterprises to access channels:

• Mass Exit of “Small, Scattered, and Weak” Enterprises: Before the implementation of strict legal regulations, numerous small and medium-sized logistics enterprises undertook chemical transportation through “affiliated qualifications” and “simplified operations,” accounting for approximately 40% of the market share. However, under strict legal regulations, these enterprises—due to “incomplete qualifications,” “non-compliant operations,” and “weak risk resistance”—either had their qualifications revoked or proactively withdrew from the market, resulting in the complete loss of this segment of capacity;
• Tight Capacity of Professional Logistics Enterprises: Large hazardous goods logistics enterprises with complete qualifications and professional capabilities have become the “main players” under strict legal regulations. However, the number of such enterprises is small, accounting for only about 5% of total logistics enterprises. With the exit of “small, scattered, and weak” enterprises, a large volume of chemical transportation demand has concentrated on professional logistics enterprises, leading to tight capacity. These enterprises often prioritize long-term orders from large chemical enterprises, while scattered orders from small and medium-sized chemical enterprises are rarely fulfilled—resulting in the “difficulty in finding vehicles” for small and medium-sized enterprises;
• Uneven Regional Distribution and Multiple Cross-Regional Transportation Barriers: Professional hazardous goods logistics enterprises are mainly concentrated in eastern coastal areas with developed chemical industries, while professional capacity in central and western regions is relatively scarce. Additionally, differences in legal provisions for qualification mutual recognition and route reporting across provinces mean cross-regional transportation requires cumbersome procedures and faces higher regulatory risks, leading to poor cross-regional transportation channels. For example, transporting chemicals from Xinjiang to East China requires passing regulatory inspections in multiple provinces, with some provinces requiring local qualifications—resulting in long transportation cycles and high costs, low enthusiasm among logistics enterprises, and difficulty for chemical enterprises in finding suitable cross-regional transportation channels.

(3) Chemical Enterprises: Mismatch Between Diversified Demand and Monotonous Channels

The chemical transportation demand of chemical enterprises exhibits “diversified” characteristics, including different hazard categories of chemicals, varying transportation volumes (bulk and scattered transportation), and different timeliness requirements. However, under strict legal regulations, transportation channels show a “monotonous” characteristic—only large professional logistics enterprises can provide compliant services, and their services tend to be “large-scale and long-term,” leading to a mismatch between demand and channels:

• Unmet Scattered Demand of Small and Medium-Sized Chemical Enterprises: The chemical transportation demand of small and medium-sized chemical enterprises is mostly “small-batch, frequent” scattered orders, such as 1–2 shipments per month with 5–10 tons per shipment. The transportation cost of such orders is high (unit transportation cost is 1.5–2 times that of bulk transportation), and operations are cumbersome (requiring separate route planning and reporting procedures). Professional logistics enterprises are more inclined to undertake “large-batch, long-term” orders (e.g., over 10 shipments per month with over 50 tons per shipment), and have low acceptance of scattered orders from small and medium-sized chemical enterprises—leading to “difficulty in finding vehicles” for these enterprises;
• Scarce Channels for Special Chemicals: For special chemicals such as highly toxic, explosive-precursor, and ultra-high-pressure substances, laws require higher transportation qualifications and stricter operational processes, and the number of logistics enterprises with such capabilities is extremely limited. For example, transporting liquid chlorine (a highly toxic chemical) requires specialized leak-proof tank vehicles and 2 certified escorts—fewer than 20 logistics enterprises nationwide have such capabilities. This has led to an extreme scarcity of transportation channels for special chemicals, with some chemical enterprises forced to suspend production due to “inability to find compliant channels”;
• Conflict Between Timeliness Demand and Legal Constraints: Some chemical enterprises have “urgent timeliness requirements” for chemical transportation, such as emergency restocking for raw material shortages or on-time delivery of customer orders. However, legal constraints such as “avoiding peak hours” and “fixed route reporting” extend transportation time. Professional logistics enterprises, to avoid violations, often cannot meet urgent timeliness requirements—leaving chemical enterprises facing the dilemma of “either illegal transportation or production delays.”

(4) Regulatory Level: Insufficient Coordination and Lack of Flexibility, Exacerbating Channel Tensions

Although the original intention of strict legal regulations is “safety assurance,” issues such as “insufficient cross-regional coordination” and “lack of flexibility” in regulatory implementation have further exacerbated transportation channel tensions:

• Inconsistent Regional Regulatory Standards and Multiple Cross-Regional Barriers: Regulatory standards for chemical transportation vary across provinces, such as requirements for packaging inspection, route reporting procedures, and scope of qualification mutual recognition. This means cross-regional transportation requires dealing with “multi-level supervision,” with logistics enterprises needing to repeatedly complete procedures and undergo inspections—resulting in low transportation efficiency and high costs. For example, a logistics enterprise transporting chemicals from Shandong to Henan must complete “cross-provincial transportation reporting” in Shandong, undergo in-transit inspections in Hebei, and complete “entry registration” in Henan. The entire process takes 3–5 days, far exceeding normal transportation time, and dampening the enthusiasm of logistics enterprises;
• Lack of Regulatory Flexibility and “Tiered Supervision”: Current legal supervision of chemical transportation mostly adopts a “one-size-fits-all” model, applying the same regulatory standards regardless of the hazard level of chemicals or transportation scale. For example, transporting 1 ton of ethanol (a low-risk flammable liquid) and 1 ton of sodium cyanide (a high-risk toxic chemical) requires complying with the same qualification requirements and operational processes. This leads to excessively high compliance costs for low-risk chemical