On August 15, China’s environmental management regime for new chemical substances will undergo an important change.
On August 4, 2026, the Ministry of Ecology and Environment (MEE) issued the Notice on Matters Concerning Environmental Management Registration of New Chemical Substances (Huan Ban Gu Ti Han [2026] No. 301), making it clear that:
From August 15, 2026, the filing procedure for environmental management of new chemical substances will no longer be accepted.
In other words, companies that are still planning to manufacture or import new chemical substances under the current filing mechanism have only a few days left to use the existing filing channel.
This change is closely related to the Environmental Code of the People’s Republic of China, which will also take effect on August 15, 2026.
For chemical manufacturers, importers and companies introducing new raw materials, the key issue is not simply the termination of the filing procedure. More importantly, the compliance pathway for placing new chemical substances on the market is changing.
1. What Happens to Substances Previously Eligible for Filing?
Under the current Measures for the Environmental Management Registration of New Chemical Substances, new chemical substances are managed according to their annual manufacturing or import volume:
- 10 tonnes or more per year: Regular registration
- 1 tonne or more but less than 10 tonnes per year: Simplified registration
- Less than 1 tonne per year: Filing
Once the new notice takes effect, the filing channel will be discontinued.
New chemical substances that previously qualified for filing will no longer be able to complete compliance procedures through filing after August 15. Instead, companies will need to submit an application for environmental management registration before manufacturing or importing the substance.
The Ministry of Ecology and Environment has stated that these applications will be accepted and reviewed with reference to the procedures and timelines currently applicable to simplified registration.
It is important to note that simplified registration is not an automatic approval process.
Under the current rules, the procedure generally involves:
- A formal review, typically five working days per review round
- A technical review, typically 30 days per review round
If supplementary information or revisions are required during the review process, the overall timeline may be extended further.
From a practical compliance perspective, companies are advised to allow at least one to two months for the registration process and to take into account possible delays caused by supplementary documentation, system updates or other uncertainties.
Under the previous filing mechanism, companies could generally obtain a filing receipt once compliant materials had been submitted, making the process relatively fast.
After the transition to a registration and approval procedure, companies will need to incorporate both formal and technical review periods into their business planning.
This is particularly important for projects where purchase contracts, shipping schedules, port arrival dates or customer delivery deadlines have already been confirmed.
2. The Online Application System Will Also Be Updated
August 15 is not only the date when the policy changes. The government service system used for applications is also expected to be updated.
At present, the application forms for simplified and regular registration are mainly designed around the existing registration framework and do not fully correspond to the requirements for substances that will transition from filing to registration.
According to currently available information, the government service system is expected to complete the relevant updates around August 15.
Companies planning to submit applications after August 15 should therefore avoid relying on previously saved versions of application forms.
A more prudent approach is to log back into the official government service system and verify:
- The latest application portal
- The current form version
- Updated documentation requirements
Companies that have already prepared their application materials should pay particular attention to whether fields or information requirements have changed in the updated system, so that outdated forms do not delay acceptance of the application.
3. Which Companies Should Pay Particular Attention?
The first group that should pay close attention is companies planning to manufacture or import less than one tonne per year of a new chemical substance in the near term.
If the substance is not listed in the Inventory of Existing Chemical Substances in China (IECSC) and the company originally intended to meet compliance requirements through filing, the application timeline should now be reassessed.
The second group includes companies dealing with polymers of low concern or other polymers that currently qualify for filing.
Under the existing regime, certain polymers may be handled through the filing procedure. However, from August 15, the filing channel will be discontinued across the board.
The specific registration pathway applicable to these polymers after the policy change will need to be determined based on the latest requirements of the Ministry of Ecology and Environment and the updated application system.
Importers of new chemical substances should also pay particular attention to supply chain planning.
Where raw materials are supplied by an overseas manufacturer, companies should not focus solely on when the goods will arrive at the port.
They should also confirm in advance:
1. Whether the substance qualifies as a new chemical substance in China;
2. Whether filing or registration has already been completed;
3. Which entity will act as the applicant for future registration; and
4. Whether the necessary compliance procedures can be completed before manufacturing or import begins.
This change is particularly relevant to companies dealing with:
- Electronic chemicals
- Fine chemical raw materials
- Coatings
- Adhesives
- New energy materials
- Other low-volume, high-value-added chemical products
4. Why Is This Change So Significant?
One important reason is that the environmental management of new chemical substances is moving from a framework primarily established by departmental regulations toward a stronger legal foundation.
The Environmental Code of the People’s Republic of China will take effect on August 15, 2026.
The Code establishes an environmental management registration system for new chemical substances and requires enterprises and public institutions that manufacture or import new chemical substances to apply for registration in accordance with the law before manufacturing or importing them.
This means that the principle of “environmental management approval before manufacturing or import” will become an even clearer legal requirement.
For companies, compliance with new chemical substance requirements can no longer be treated merely as a temporary procedure completed shortly before customs clearance or the launch of a new product.
A more appropriate approach going forward is to assess whether a substance qualifies as a new chemical substance during:
- New product development
- Raw material procurement
- Supplier qualification and onboarding
Companies should also reserve sufficient time for registration before commercial activities begin.
5. What Should Companies Do Before August 15?
Companies with new raw materials, new products or upcoming import plans should begin by reviewing the chemical substances they expect to manufacture or import over the next several months.
Three questions should be prioritized.
First: Is the substance a new chemical substance?
Companies should first check whether the substance is already included in the Inventory of Existing Chemical Substances in China (IECSC).
If a substance is already listed in the Inventory, it is generally not the primary subject of this particular adjustment to the new chemical substance registration regime.
Second: Was the substance originally intended for filing?
Companies should pay particular attention to substances manufactured or imported at less than one tonne per year, as well as polymers that currently meet the applicable filing conditions.
Where there is a genuine need to complete filing and the necessary documentation is already available, companies should closely monitor the existing filing window before August 14.
Third: Does the manufacturing or import schedule need to be adjusted after August 15?
Projects that cannot complete the required procedures before filing is discontinued should be replanned in accordance with the new registration requirements.
This is especially important for companies that have already confirmed:
- Procurement arrangements
- Shipping schedules
- Import dates
- Customer delivery deadlines
The registration review period should be incorporated into the project schedule to avoid situations in which goods have already been arranged for import while the required pre-import compliance procedures remain incomplete.
Important Compliance Reminder
Another issue requires particular attention.
Current revisions and policy discussions concerning the Measures for the Environmental Management Registration of New Chemical Substances also involve possible changes to applicant eligibility, registration classifications and the management of polymers.
However, some of these provisions are still in a transitional stage or were previously released only for public consultation.
Companies should therefore clearly distinguish between rules that have formally taken effect and proposals that have not yet been officially adopted.
Requirements that have been formally issued and implemented should be followed as binding rules.
Proposed systems or consultation drafts may be used for advance preparation, but should not be treated as the final legal basis for submitting an application until they are formally adopted.
Regulatory References
- Notice of the General Office of the Ministry of Ecology and Environment on Matters Concerning Environmental Management Registration of New Chemical Substances(Huan Ban Gu Ti Han [2026] No. 301)
- Environmental Code of the People’s Republic of China
- Measures for the Environmental Management Registration of New Chemical Substances(Order No. 12 of the Ministry of Ecology and Environment)
