On 11 June 2026, China’s Ministry released a draft revision of its Measures for the Environmental Management Registration of New Chemical Substances for public consultation.
The updated framework is expected to take effect on 15 August 2026, replacing MEE Order No. 12 (issued in 2020), and aligning with the implementation of China’s Ecological and Environmental Code.
The draft introduces several significant changes to the current regulatory system:
1. Updated Scope and Definitions
New chemical substances continue to include those not listed on the Inventory of Existing Chemical Substances in China (IECSC), as well as substances with new use requirements.
The scope of new chemical substances has been expanded to include substances that were exempted from MEE Order 12 such as pharmaceuticals, pesticides and food.
However, the draft clarifies that substances used solely for technical service purposes, including scientific research, are exempt from registration.
2. Revised Registration Categories and Thresholds
The current three-tier system (Record Notification, Simplified Registration, and Typical Registration) will be reduced to two categories: Simplified and Typical Registration. The record notification category will be abolished.
It is important to note that all record notifications submitted under MEE Order No. 12 must be re-registered by the end of 2026, while existing Simplified and Typical Registration certificates will remain valid.
A summary of the registration requirements is shown below:
- Substances below 1 tonne per year (t/y) will now require Simplified Registration
- Substances in the 1–10 t/y range will move from Simplified to Typical Registration, though with reduced data requirements (e.g. no chemical safety report or socio-economic analysis).
- Substances ≥10 t/y remain subject to Typical Registration
- Eligible polymers ≥1 t/y will also fall under Typical Registration
3. Strengthened Post-Registration Obligations
The draft significantly expands post-registration requirements, including the following:
- All registrations will require annual reporting.
- First-time manufacture or import reporting will apply to all Typical registrations in specific categories.
- Information sharing with downstream users must now be formally included in sales contracts.
- Substances approved with new use requirements under Typical Registration will not be added to the IECSC.
- Any changes to previously approved registrations will require a new registration under the updated rules.
4. Changes to Notifier Eligibility
Under the new draft, only Chinese manufacturers or importers can act as notifiers. This represents a shift from the current system, which allows foreign companies to register via a nominated Chinese agent.
5. Confidential Business Information (CBI) and Additional Requirements
The draft removes the current five-year limit on approved CBI protection, allowing indefinite protection once granted. It also introduces potential new data requirements for highly hazardous substances, including information on emission quantities or concentrations.
If you are importing or manufacturing chemical substances in China and would like support in understanding or complying with these upcoming regulatory changes, please feel free to get in touch with our team.
Published June 23rd, 2026
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