China Notifies WTO of Draft Revision to Measures for New Chemical Registration

China has notified a draft revision of its new chemical substance environmental management registration rules that would bar foreign enterprises from being registration applicants, expand the regulated scope, and replace the current record-notification system with a two-tier registration regime.

On July 1, 2026, China notified the World Trade Organization (WTO) of the Measures on the Environmental Management Registration of New Chemical Substances (Draft for Comments), originally published by the Ministry of Ecology and Environment (MEE) on June 11, 2026. The proposed revision introduces significant changes to China's new chemical management framework, including the revocation of applicant eligibility for foreign enterprises, the expansion of the regulatory scope to include previously exempt product categories, and the restructuring of registration types.

The draft revision aligns the regulatory framework with the Ecological and Environmental Code, significantly increasing the penalties for illegal activities related to new chemical substances. The overarching objective of the regulation remains the prevention and control of environmental and health risks posed by new chemical substances, with a focus on those that are persistent, bioaccumulative, or highly hazardous.

The draft revision introduces several critical changes that will impact chemical manufacturers, importers, and the broader cross-border supply chain:

Applicant Eligibility: Foreign enterprises will no longer be eligible to act as registration applicants. Under the new rules, applicants must be enterprises or institutions legally registered within the territory of the People's Republic of China capable of independently bearing legal liability.
Expanded Scope: Products already managed under other specific regulations, such as pharmaceuticals, pesticides, and cosmetics, will now be incorporated into the scope of new chemical substance environmental management registration.
Restructured Registration Types: The current record notification system will be entirely canceled. Registrations will be strictly divided into two categories based on volume: Regular Registration for new chemical substances with an annual production or import volume of 1 ton or more, and Simplified Registration for volumes under 1 ton.
Exemptions: New exemption scenarios have been introduced for specific uses, including scientific research.
Post-Registration Management: The draft adjusts post-registration tracking requirements, including data sharing and downward supply chain communication obligations.

Regarding compliance timelines, the WTO notification sets a 60-day international comment period ending on August 30, 2026. While the WTO document lists the proposed date of entry into force as "To be determined," Article 47 of the draft revision proposes an implementation date of August 15, 2026, at which point the current MEE Order No. 12 would be simultaneously repealed. For transitional compliance, enterprises that have previously completed record notification under the existing MEE Order No. 12 must submit applications to obtain a new registration certificate in accordance with the revised Measures by December 31, 2026.

#English Translations

Measures for the Environmental Management Registration of New Chemical Substances (Draft for Comments)On June 11, 2026, the Ministry of Ecology and Environment of China issued a notice soliciting public comments on the Measures for the Environmental Management Registration of New Chemical Substances (Draft for Comments). The draft revises China's existing new chemical registration framework by abolishing the record notification category, lowering regular registration thresholds, tightening confidentiality exceptions, and increasing penalties for false reporting. Once the revision is adopted, it will take effect on 15 August 2026 to replace the MEE Order No. 12.

Further Reading