WORLD TRADE  
ORGANIZATION  G/LIC/N/3/KHM/1 
23 November 2010 
 (10-6254) 
Committee on Import Licensing Original:   English 
  
 
RESPONSES TO QUESTIONNAIRE ON IMPORT LICENSING PROCEDURES  
 
Notification pursuant to Article 7.3 of the 
 
Agreement on Import Licensing Procedures  
 
CAMBODIA 
 
 
 The following communication, dated 16 November 2010, is being circulated at the request of 
the delegation of Cambodia. 
 
_______________ 
 
CHEMICALS, PHARMACEUTICALS AND NARCOTIC DRUGS  
 
Outline of System  
 
1. The import licensing regime for chemicals is ad ministered by the Institute of Standards of 
Cambodia, an organ of the Ministry of Industry, Mines and Energy. The system is designed to help maintain the orderly marketing of chemicals in Cambodia. For some products, the system may result 
in limitations on imports. The intent is to reduce the presence in Cambodia of dangerous chemical 
substances for which proper controls are difficult,  and storage facilities are limited. For these 
products, the system operates by assessing current le gitimate import needs of Cambodian firms using 
chemicals or chemical products, and ensuring that those needs are met.    The import licensing (or permit) regime for pharmaceuticals, medical materials and narcotic and related substances is administered by the Ministry of Health. Its purpose is to protect human 
health.  
  The import licensing of pharmaceuticals and medical materials does not restrict the quantity or value of imports. Separate sy stems manage imports for retail sale and imports for hospital/clinic 
use. Importation for retail sale is governed by the import licensing system described in this 
questionnaire. Importing for retail sale requires pack aging suitable for purchase and/or consumption 
by individuals. Importation of registered pharmaceu ticals packaged in bulk and designed for hospital 
use is undertaken by tender and does not require an import licence. The Ministry of Health and 
medical NGOs import under this regime, and the imports are duty-free. NGOs need a special authorization from the ministry of Health to requ est a tender. The resulting imports must not be put 
into commercial retail channels.  
  The import licensing of narcotics, psychotropic substances and precursors is designed to allow Cambodia to meet accepted interna tional standards for trade in such goods. 
 G/LIC/N/3/KHM/1 
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  Purposes and coverage of licensing
 
 
2.  For licences administered by  the Institute of Standards of Cambodia: chemical substances 
and products, except when the importer declares th at the substance or product is for medical or 
medicinally-related purposes. The substances and pr oducts are found in HS 2605, 2612, 2707, 2801 
through 2837, 2839 through 2850, 2852, 2853, 2901 through 2942, 3212, 3215, 3501, 3503, 3505, 
3606, 3824, 8401.    For licences administered by the Ministry of  Health: pharmaceuticals, medical materials and 
traditional medicines (products are in HS 3001, 3002, 3003, 3004, 3005, and 3006) and narcotics, 
psychotropic substances and their precursors, when th e importer declares that the  precursors are to be 
used for medical purposes.(Products are in HS 121 1, 1301, 1302, 2921, 292 2, 2924, 2925, 2926, 
2927, 2932, 2933, 2934, and 2939.)  3. The systems apply to products covered originating from all countries. There is no 
discrimination by country of origin. 
 4. Pharmaceuticals, medical ma terials and traditional medicines
 (Hereafter referred to as 
List A ):  the system does not restrict the importation of legitimate medicines. Its purpose is to protect 
human health, in particular by controlling and reducing illegal imports of pharmaceuticals, and to 
ensure the quality of the products based on WHO standards. No alternative methods have been 
developed due to insufficient technological and human capacities. 
  Narcotics, psychotropic substances and their pr ecursors, when the importer declares that the 
precursors are to be used for medical purposes  (hereafter referred to as List B ): the quantity of 
imports may be restricted. The system is designe d and administered so as to allow Cambodia to 
comply with various internationa l conventions on narcotics and psyc hotropic substances and with its 
responsibilities as a member of the Inte rnational Narcotics Control Board. 
  Dangerous chemicals
 (hereafter referred to as List C ): for a relatively small number of 
products for which import licences are administered by the Institute of Standards of Cambodia the 
quantity of imports may be restricted. The list of such products is found in Annex I. The system is 
designed to ensure that the quantity of danger ous chemical products imported does not exceed the 
current legitimate needs of Cambodia. Stockpiling of dangerous chemicals is not feasible at present in 
Cambodia, and their control is difficult. 
 
 Other chemicals  (hereafter referred to as List D ): for all products not in List C but requiring 
licences administered by the Institute of Standard s of Cambodia, licensing is automatic, with no 
restraints on the quantity of imports.  
 
5. Lists A and B:  Import licensing is maintained and statutorily required under the Law on 
Amending the Law on Drug Manage ment, dated 28 December 2007, and Prakas 1031 amending  
Prakas No 82 on Drug Import-Export Procedures of 3 November 2008. 
 
 Lists C and D:  The licensing is required by Sub-Decree 209 ANK.BK of 31 December 2007. 
The system could be abolished by a Sub-Decree issued by the Government. The respective roles of the Ministry of Health and the Ministry of Industry, Mines and Energy are spelled out in Inter-Ministerial Regulation 1121 dated 19 November 2009. 
  G/LIC/N/3/KHM/1 
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  Procedures  
 
6.I. List B : The relatively small number of authorized impor ters is fully inform ed of the necessary 
procedures. Information on quotas and imports is not made public. 
 
 List C : Information on procedures for obtaining an import licence may be found on the 
website of the Institute of Standards of Ca mbodia. There is no pre-determined overall 
limitation of imports. The current needs of Cambodian enterprises are fully met, but requests that go beyond those needs will be approved only  in the amounts that are consistent with 
needs. 
 
II. List B : The size of the quota is determined by Cambodia’s annual submission to the 
International Narcotics Control Board. 
  List C : The size of the quota for each importing firm is determined by its standard of use, 
which is established by an ISC inspector. Q uotas for traders are determined by the valid 
orders received from firms that are final consumer s, provided that those orders fall within the 
standard of use of those firms. Licences for traders are issued on a shipment-by-shipment 
basis. Licences for final consumers are issued for a period of six months, during which more 
than one transaction is possible. 
  
III. List B : Licences are issued to those registered fi rms approved by a Ministry of Health   
Committee chaired by the Minister.  
  List C : Licences are available to any firm using the chemical products covered, or to a trader 
supplying such firms.  
 
IV. Lists B and C : Licences may be applied for at any time. 
 V. List B : three working days if the application and supporting documents are complete.  
        List C : Four to ten working days. 
 
VI. List B and C : Importation may take place immediately after the issuance of a licence. 
 VII. List B : All licence procedures are executed by the Ministry of Health. 
 
List C : All licence procedures are executed by th e Institute of Standards of Cambodia. 
 VIII. List B : allocations among approved fi rms is determined by past allocations, adjusted in the             
light of utilization of previous imports. 
        List C : Please see answers to II. and III. 
 
IX. Lists B and C:  Not applicable. 
 X. Lists B and C:   Not applicable. 
 
XI. Lists B and C:   No. 
 G/LIC/N/3/KHM/1 
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  7.(a) List A : No advance application is required. Li cences are often issued for landed goods.  
Licences can be obtained in 3 days, if the appli cation and supporting documents are complete.   
  List D : A licence can be applied for after the good s have arrived at port. A licence will be 
issued in 4-10 working days.  
 
(b) List A : Yes. 
  List D : No. 
 
(c) Lists A and D:  No. 
 (d) List A : The licence application is considered and the licence granted by a single organ, the 
Department of Drugs and Food, Ministry of Health.   
 
 List D : The licence application is considered and the licence granted by a single organ, the 
Institute of Standards of Cambodia. 
 8. List A : A licence may be refused only if it fails to meet  the ordinary criteria, i.e., if the drug is 
not registered with the Ministry of Health. In such  a case, the Ministry of Health will suggest to the 
importer to register the drug and submit full docum entation supporting the registration. Applicants 
who are refused a licence may appeal to the Minister  of Health. They may also appeal to a court of 
first instance (usually the Municipal Court of Phnom Penh). The decision of this court may be appealed to the Appellate Court.      List B : A licence application may be refused if it fails to meet the ordinary criteria, or if 
granting the licence is inconsistent with Cambodi a's commitments to the International Narcotics 
Control Board.   Lists C and D : The application can be refused only for failure to meet ordinary criteria. The 
applicant is informed of any refusal in writing. Deci sions may be appealed to the Minister of Industry, 
Mines and Energy. 
 
Eligibility of Importers to Apply for Licence
 
 
9. Lists A and B:  No. Only companies registered by the Ministry of Health may import 
pharmaceuticals and narcotics. All Cambodian firms ar e eligible to be so registered, provided that 
they have at least one employee who is a licensed  pharmacist. In accordance with the Prakas of the 
Ministry of Health, No. 254 dated 13 June 1996,  there is a registration fee of US$200(for each 
product registered) to be paid by the company to the Ministry of Health. A list of authorized importers 
is available at the Department of Drugs and Food,  Ministry of Health. At present, 164 companies are 
authorized to import pharmaceuticals and narcotics.  
 Lists C and D: Any firm registered to do business in Cambodia may be the importer of 
record.   
Documentation and Other Requiremen ts for Application for Licence 
 
 10. Lists A and B: Applicants must submit the usual import documents. Please see the sample 
application form in Annex II.    Lists C and D:   Applicants must submit the usual import documentation. Please see the 
sample application forms in Annex III.  G/LIC/N/3/KHM/1 
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  11. Lists A, B, C and D : The import licence and the usual import documentation. 
 12. Lists A, B, C and D : There are no fees or charges. 
 13. Lists A, B, C and D : No deposits or advance payments are required. 
 
Conditions of Licensing
 
 
14. Lists A and B : A licence is valid for one month and can be extended upon request. 
 
 Lists C and D : Normally six months.  The validity of the licence cannot be extended. 
 15. List A : No. Licences are usually issued for lande d goods and require presentation of invoices 
and packing lists. In principle, non-utilization or under-utilization cannot occur.  
 Lists B, C and D : There is no penalty for non-utilization or under-utilization. 
 16. List A, C and D : No.  
  List B : The importer must present a report on the utilization and/or distribution of drugs 
previously imported. 
 
17. List A, C and D : No.  
  List B : The importer must present a report on the utilization and/or distribution of drugs 
previously imported. 
 
Other Procedural Requirements
 
 
18. No.  19. Foreign exchange is freely available to all importers. G/LIC/N/3/KHM/1 
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  ANNEX I 
 
List of Chemical Substances Subject to Non-Automatic Licensing
 
 
A. Chemical substance 
No. 1.  Precursors used in production of illicit drugs 
1 N-acetylanthranilic Acid  
2 Isosafrole  
3 Lysergic Acid 
4 3,4-methylenedioxy-phenyl-2-propanone 
5 1-phenyl-2-propanone 
6 Piperonal 
7 Safrole 
8 Acetic Anhydride 
9 Acetone 
10 Anthranilic Acid 
11 Ethyl Ether 
12 Hydrochloric Acid 
13 Methyl Ethyl Kethone 
14 Phenylacetic Acid 
15 Piperidine 
16 Potassium Permanganate 
17 Sulfuric Acid 
18 Toluene 
19 Acetic Acid (Glacial) 
20 Chloroform 
21 Thionyl Chloride 
22 Phosphorus Trichloride 
23 Phosphorus Pentachloride 
24 Palladium 
25 Acetyl Chloride 
26 Ethylidene Diacetate 
27 Formic Acid 
28 Barium Sulphate 
29 Methylene Chloride 
30 Xylene 
31 Ethyl Acetate 
32 Caustic Soda 
33 Soda Ash 
34 Solvents 
35 Thinner  G/LIC/N/3/KHM/1 
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   2.  Chemical Terrorism  
 2.1 Chemical weapon 
 Schedule 1 CAS Registry Number Other 
 A. Toxic Chemicals   
1 O-Alkyl (< C10, incl. cycloalkyl) alkyl (Me, Et, n-Pr or i-Pr)-
phosphonofluoridates  
e.g. Sarin: O-Isopropyl methylphosphonofluoridate Soman: 
O-Pinacolyl methylphosphonofluoridate (107-44-8) (96-64-0)  
2 O-Alkyl ~CIO, incl. cycloalkyl) N,N-dialkyl (Me, Et, n-Pr or 
i-Pr) phosphorarnidocyanidates  
e.g.Tabun:O-Ethyl N,N-dimethyl hosphorarnidocyanidate (77-81-6)  
3 O-Alkyl (H or :sCIO, incl. cycloalkyl) S-2-dialkyl (Me, Et, n-
Pr or i-Pr)-aminoethyl alkyl (Me, Et, n-Pr or i-Pr) 
phosphonothiolates and corresponding alkylated or protonated 
salts 
e.g. VX: O-Ethyl S-2-diisopropylarninoethyl methyl 
phosphonothiolate (50782-69-9)  
4 Sulfur mustards: 2-Chloroethylchloromethylsulfide Mustard 
gas: Bis(2-chloroethyl)sulfide Bis(2-chloroethylthio)methane 
Sesquimustard: 1,2-Bis(2-chloroethylthio)ethane 1,3-Bis(2-
chloroethylthio)-n-propane 1,4-Bis(2-chloroethylthio)-n-
butane 1,5-Bis(2-chloroethylthio)-n-pentane  
Bis(2-chloroethylthiomethyl)ether 0-Mustard: Bis(2-
chloroethylthioethyl)ether (2625-76-5) (505-60-2) 
(63869-13-6) (3563-36-8) 
(63905-10-2) (142868-93-7) (142868-94-8) 
(63918-90-1) (63918-89-8)  
5 Lewisites: Lewisite I: 2-Chlorovinyldichloroar Lewisite 2: 
Bis(2-chlorovinyl)chloroarsine Lewisite 3: Tris(2-
chlorovinyl)arsine (541-25-3) (40334-69-8) 
(40334-70-1)  
6 Nitrogen mustards: HN I: Bis(2-chloroethyl)ethylamine HN2: 
Bis(2-chloroethyl)methylamine(51-75-2) HN3: Tris(2-
chloroethyl)amine(555-77-1) (538-07-8)  
7 Saxi toxin (35523-89-8)  
8 Ricin (9009-86-3)  
 B. Precursors   
9 Alkyl (Me, Et, n-Pr or i-Pr) phosphonyldifluorides e.g. DF:       
Methylphosphonyldifluoride (676-99-3)  
10 O-Alkyl (H or SClo, incl. cyc1oalkyl) 0-2-dialkyl (Me, Et, n-
Pr or i-Pr)-aminoethyl alkyl (Me, Et, n-Pr or i-Pr) 
phosphonites and corresponding alkylated or protonated salts 
e.g QL: O-Ethyl 0-2-diisopropylaminoethyl 
methylphosphonite (57856-11-8)  
11 Chlorosarin:    O-Isopropyl methylphosphonochloridate (1445-76-7)  
12 Chlorosoman: O-Pinacolyl methylphosphonochloridate (7040-57-5)  
 Schedule 2   
 A. Toxic Chemicals   
1 Amiton: O,O-Diethyl S-[2-(diethylamino)ethyl] 
phosphorothiolate 
and corresponding alkylated or protonated salts (78-53-5)  
2 PFIB: 1,1 ,3,3,3-Pentafluoro- 2-(trifluoromethyl)-I-propene (382-21-8)  
3 BZ: 3-Quinuclidinyl benzilate (*) (6581-06-2)  
 B. Precursors    
4 Chemicals, except for those listed in Schedule 1, containing a 
phosphorus atom to which is bonded one methyl,ethyl or propyl 
(normal or iso) group but not further carbon atoms, 
e.g. Methylphosphonyl dichloride Dimethyl methylphosphonate
Exemption: Fonofos: O-Ethyl S-phenyl 
ethylphosphonothiolothionate (676-97-1) (756-79-6) 
(944-22-9)  
5 N,N-Dialkyl (Me, Et, n-Pr or i-Pr)phosphorarnidic dihalides   G/LIC/N/3/KHM/1 
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  6 Dialkyl (Me, Et, n-Pr or i-Pr) N,N-dialkyl (Me, Et, n-Pr or i-Pr)-
phosphorarnidates   
7 Arsenic trichloride (7784-34-1)  
8 2,2-Diphenyl-2-hydroxyacetic acid (76-93-7)  
9 Quinuclidin-3-o1 (1619-34-7)  
10 N,N-Dialkyl (Me, Et, n-Pr or i-Pr) aminoethyl-2-chlorides and 
corresponding protonated salts   
11 N,N-Dialkyl (Me, Et, n-Pr or i-Pr) aminoethane-2-ols and 
corresponding protonated salts 
Exemptions:   N,N-Dimethylaminoethanol and corresponding 
protonated salts N,N-Diethylaminoethanol and corresponding 
protonated salts (108-01-0)(100-37-8)  
12 N,N-Dialkyl (Me, Et, n-Pr or i-Pr) aminoethane-2-thiols and 
corresponding protonated salts   
13 Thiodiglycol:Bis(2-hydroxyethyl)sulfide (111-48-8)  
14 Pinacolyl alcohol: 3,3-Dimethylbutan-2-o1 (464-07-3)  
 Schedule 3    
 A. Toxic chemicals:   
1 Phosgene: Carbonyl dichloride (75-44-5)  
2 Cyanogen chloride (506-77-4)  
3 Hydrogen cyanide (74-90-8)  
4 Chloropicrin: Trichloronitromethane (76-06-2)  
 B. Precursors:   
5 Phosphorus oxychloride (10025-87-3)  
6 Phosphorus trichloride (7719-12-2)  
7 Phosphorus pentachloride (10026-13-8)  
8 Trimethyl phosphate (121-45-9)  
9 Triethyl phosphate (122-52-1)  
10 Dimethyl phosphate (868-85-9)  
11 Diethyl phosphate (762-04-9)  
12 Sulfur monochloride (10025-67-9)  
13 Sulfur dichloride (1O545-99-0)  
14 Thionyl chloride (7719-09-7)  
15 Ethyldiethanolamine (139-87-7)  
16 Methyldiethanolamine (105-59-9)  
17 Triethanolamine (102-71-6)  
  G/LIC/N/3/KHM/1 
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  ANNEX II  
 
Application for an import licence for medicines  
 
Kingdom of Cambodia 
Nation – Religion – King 
 
Company : ....................... Address  : ....................... Tel.   : ....................... 
Fax.   : ....................... 
No.   : .......................  Date:  
Subject:  Request for importing permission of modern  medicine with the quantity of ............ 
items (........ CTNS), weight: ............ Kg, cost ...........USD, From country ............... through border check point ......................... 
 Dear High Excellency Mr. Minister of Health,  
As mentioned in the subject and enclosure the above , I would like to inform your Excellency Minister 
that my Company have request to import the m odern medicine with quantity of ........ items (CTNS), 
weight ..........Kg, from country ........... through border check point ................  Therefore, please permit my company to import those products as requested. 
 
Please accept, dear your Excellency, the assurances of my high consideration.  Most sincerely yours,  Company Managing Director 
 
 Enclosure:  - Ocean Bill of lading or Airw ay Bill No. ..............  dated: ............... 
 - Commercial Invoice No.: ..................................... dated: ............... 
 - Packing List No.:................................................... dated: ............... 
 - List of import order item code: ............................. dated: ............... G/LIC/N/3/KHM/1 
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  ANNEX III 
 
Application for an import licence for chemicals
 
 
 
Kingdom of Cambodia 
Nation- Religion- King 
 
******* 
Application for the Certificate of verification a nd /or Standard of use for Chemical Substances 
 
Name…………………………………….Nationality……………………ID or Passport No… Company/Factory/Enterprise…………………………..Address:……………………………………………………………………………………… …………………………………………... 
 Your  Excellency, Minister of Industry , Mines and Energy 
 
 Subject: request for the certificate of verification   Standard of use of  chemical  
substances     Quantity    Purpose of Use       permit to use the chemical substances    as the attachment list. 
 
Reference to:  -………………………………………………………………………………….. 
  -………………………………………………………………………………….  With regard to  the references, I would like to in form your Excellency that  our company/ factory/ 
enterprise needs the said chemi cal substances for use in the 
production/supply…………………………… …………………………………………………. 
 It would be very much appreciated if you could authorize the certificate to my company/factory/ enterprise.  Please accept, dear your  Excellency, the assurances of my highest consideration. 
 
 
Enclose:
 
1- List of  the chemical substances to be imported 
2- Table of annual production plan a nd standard of  use of the chemical substances or materials 
3- report on Previous imports of chemical substances 
4- Importer’s Declaration 
5- The Prakas of the Ministry of Industry Mines and Energy  
6- Registration Certificate on VAT or other . 
7- Cambodian ID or Valid Passport 
8- Material Safety Data Sheet ( MSDS/SDS) 
9- Certificate of analysis of the chemical substances to be imported ( if necessary ) 
10- Sample of  chemical substances to be imported for making analysis. ( if necessary ) 
    G/LIC/N/3/KHM/1 
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  List of chemical substances or raw materials  
 Name of the Company…………………………………………………………………………. Address………………………………………………………………………………………….  
 
 
No. Name of the chemical 
substances or raw materialsPurpose of Use Import quantity Kg/ton
 
  
 
    
 
    
 
     
 
 
 
Phnom Penh, dated  ……………………..2010 
 
Company  Director 
   
 
 
 
 
 G/LIC/N/3/KHM/1 
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  Annual Production Plan and Standard of Use for Chemical Substances
 
 Name of Company/ Factory/ Enterprise:………………………………………………… Address:…………………………………………………………………………………….  
Annual production plan for products: 
 4. ……………………………quantity…………………   from dated       ….   2000                                             
5. …………………………………quantity……………   to dated             ….  2000                                  
6. ………………………………… quantity……………   
 
No. List of chemical 
substances or materials Purpose of use Quantity of use  
(06 months or 01 year) Standard of use 
     
  
 
     
 
    
 
Phnom Penh, dated  …………………..2010 
 
Company  Director 
 
 
 
  G/LIC/N/3/KHM/1 
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  Report on the previously imported chemical substances  
 
Name of Company/ Factory/ Enterprise:……………………………………………… Address:…………………………………………………………………………………  
Letter of certification No………………………..Dated………….. of the Ministry of Industry, 
Mines  and Energy.  
No. List of chemical substances 
or materials Purpose of use Quantity of 
imports 
    
 
 
    
 
    
 
 
Phnom Penh, dated  ……………………..2010 
 
Company Director 
  
 G/LIC/N/3/KHM/1 
Page 14  
 
  Buyer, Importer or Consumer Declaration
 
  
I would like to purchase, import or use the followi ng  chemical substances related to narcotic 
drugs. 
I would like to make the following  declaration: 
 
 Expected use :  production         for sale              research and development    
analysis  
 
I am ……………………………………………occupation …… on behalf of (the company or 
agency). Address……………………………………………………………………………………...  Telephone No………………………………….  Fax No…………………………………... 
E- mail:……………………………… ……………………………………………………... 
 After the Ministry issues the letter of permission , I  promise: - to report on the previously imported chemical substances or materials as  provided in table  
form A. 
- to report on the  monthly use of chemical substances or materials as provided in table form B 
- to report on Annual Production Plans and  the Standard of Use of Chemical Substances in 
table C 
- to report on inspection when the goods arrive  as provided in table form D - to list the names of Companies /factories/enterprises  supplied as provided in table form E - to notify to the Ministry of Industry, Mines and Energy when there are changes in technology 
or when production ceases 
- not to sell or distribute chemical substances to others  without permission from the Ministry 
of Industry, Mines and Energy. 
- not to use the chemical substances in a way that  is detrimental to the health environment or 
for producing illegal drugs. 
 
Actions contrary to the above declaration are punishable by law. 
 
 
Phnom Penh, dated  …………………..2010 
 
Company Director 
 
__________