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On 20 August 2025, China’s Solid Waste and Chemicals Management Center (SCC) under the Ministry of Ecology and Environment (MEE) issued a notice regarding the application for extension of the non-disclosure of chemical identification information.
According to Article 13 of MEE Order No.12, applicants can apply for information protection if they consider that there is confidential business information (CBI) involved in the submitted registration application or record notification materials. The non-disclosure period for identification information, such as chemical name, shall not exceed 5 years from the date of the first-time registration or record notification.
The Guidance on Environmental Management Registration of New Chemical Substances also specifies that the CBI protection for the following chemical substances will expire by 31 December 2025:
New chemical substances that obtained their environmental management registration certificate and CBI protection approval under MEP Order No. 7 by 31 December 2020; or
Chemical substances that have been listed in the Inventory of Existing Chemical Substances of China (IECSC) and obtained CBI protection approval before the effectiveness of MEE Order No. 12 (took effect on 1 January 2021, replacing MEP Order No. 7), excluding:
Chemical substances that have obtained CBI protection approval and have been registered under SEPA Order No. 17 (replaced by MEP Order No. 7).
Chemical substances that have completed record notification/simplified registration rather than regular registration.
Chemical substances manufactured in or imported into China before 15 October 2003, which fulfilled the supplementation criteria and have been added in the IECSC.
However, by the recently issued SCC-MEE notice, stakeholders of the aforementioned chemical substances are entitled to apply for an extension of the non-disclosure of chemical identification information, with a maximum extension period not exceeding five years. Holders of registration certificates must submit their application materials for the extension of CBI protection at least six months before the expiration of the current protection period.
Notably, the deadline for submitting extension application materials has been extended to 15 September 2025. Registration certificate holders who require an extension should prepare the necessary justifications and submit the applications through the new chemical substance online registration system.
Expert’s Insights
Based on consultation with the official, it’s worth noting that holders of new chemical substances obtained the Regular Registration Certificate under the MEP Order No. 7 during the transition period (1 January 2021 to 30 June 2021) should also take the chance if needed. If such registered chemical substances are still within the CBI protection period and require an extension, the certificate holders shall submit an extension application six months before the expiration date.
For example, Holder A obtained the Regular Registration Certificate and the CBI protection approval for a new chemical substance under MEP Order No. 7 on 1 May 2021. Its current CBI protection period will expire on 1 May 2026. Holder A shall submit the extension application materials before 1 November 2025.
Certificate holders for such substances registered during the transitional period, who require an extension for CBI non-disclosure, should be aware of the deadlines for submitting extension applications and submit them promptly.
