Overview
On November 19, 2025, the Ministry of Ecology and Environment (MEE), in collaboration with the National Administration of Disease Prevention and Control (NADPC), released the "List of Priority Controlled Chemicals (Third Batch) (Draft)" (hereinafter referred to as the "List Three (Draft)"). The deadline for submitting public comments is December 2, 2025.
This initiative represents a critical step in implementing the "Action Plan for New Pollutants Control" (State Council General Office Document No. 15 [2022]). It aims to further strengthen the management of chemical substances that pose unacceptable risks to the ecological environment and human health, thereby safeguarding the environment and public health.
Background
In accordance with the "Action Plan for New Pollutants Control," the periodic updates of the Priority Control Chemicals List are a key task in China's efforts to address new pollutants.
The "List of Priority Controlled Chemicals (First Batch)" was issued on December 28, 2017, and included 12 categories of chemical substances. The "List of Priority Controlled Chemicals (Second Batch)" was issued on November 2, 2020, and included 40 categories of chemical substances.
The MEE, in collaboration with the NADPC, organized the drafting of the "List Three (Draft)" based on recent screening and evaluation results. The screening and evaluation process prioritized highly hazardous chemical substances, focusing on factors such as persistence and bioaccumulation, chronic aquatic toxicity (Category 1), carcinogenicity (Category 1 or 2), mutagenicity (Category 1 or 2), reproductive toxicity (Category 1 or 2), specific target organ toxicity (repeated exposure, Category 1), and endocrine disruption. Special consideration was given to chemicals already subject to strict domestic industrial and trade policies or international environmental conventions.
Strengthening the management of these substances is expected to effectively reduce their potential harm to the environment and human health.
Key Contents of the List
The draft includes 24 categories of chemical substances, encompassing a wide range of high-risk chemicals:
Bisphenol A (CAS No.: 80-05-7): Commonly used in the production of plastics and resins, known for its endocrine-disrupting properties.
Phthalates (e.g., Di(2-ethylhexyl) phthalate, CAS No.: 117-81-7): Widely used as plasticizers, potentially harmful to the reproductive system.
1,2-Dichloroethane (CAS No.: 107-06-2): An industrial solvent with carcinogenic properties.
Per- and Polyfluoroalkyl Substances (PFASs): These compounds, characterized by their unique carbon-fluorine bonds, are known for their exceptional stability and are widely used in textiles, electronics, firefighting, and food-contact materials.
However, this stability has earned them the label of "forever chemicals" (commonly referred to as such due to their persistence in the environment). Their persistence, long-range transport potential, bioaccumulation, and toxicity pose long-term risks to the environment and human health.
In the "List Three (Draft)," PFASs are included under item PC064 as "Per- and Polyfluoroalkyl Substances (PFASs), including long-chain perfluorocarboxylic acids and their salts and related compounds (PFCAs) and other PFASs."
This entry not only mentions long-chain perfluorocarboxylic acids, their salts, and related compounds (PFCAs) but also explicitly lists 29 specific PFASs, including various perfluoroalkyl sulfonates, perfluoroalkyl carboxylates, and their derivatives.
The inclusion of PFASs, particularly with the detailed listing of numerous specific substances, demonstrates China's regulatory expansion from the limited scope of PFOS substances in the "List of Priority Controlled Chemicals (First Batch)" and PFOA substances in the "List of Priority Controlled Chemicals (Second Batch)" to the broader PFAS family. This reflects a substantial increase in the scope and stringency of regulations, aligning closely with international trends.
The complete list also includes other chemical substances with carcinogenicity, mutagenicity, reproductive toxicity, or specific target organ toxicity.
Regulatory Obligations for Listed Chemicals
Under current regulations, substances included in List of Priority Controlled Chemicals are subject to the following key management requirements:
Environmental Impact Assessment (EIA): Construction projects involving substances listed in List of Priority Controlled Chemicals must include detailed information on production and usage in EIA documentation and calculate the generation and discharge of new pollutants at each stage.
Pollutant Discharge Permit Administration: Enterprises must report the proportion of listed substances in raw and auxiliary materials in their pollutant discharge permit applications, based on design values or actual production data from the previous year.
Soil and Groundwater Protection: Key entities must adopt anti-corrosion and leakage prevention measures to prevent substances listed in the List of Priority Controlled Chemicals from contaminating soil and groundwater.
Facility Dismantling Management: Key entities involved in dismantling facilities containing substances listed in the List of Priority Controlled Chemicals must prepare a pollution prevention plan in advance and file it with the competent authorities.
Cross-Industry Impacts and Compliance Challenges
The production and use of chemical substances in this batch of the list involve multiple industries, including the petrochemical, plastics, rubber, pharmaceutical, textile, dye, coatings, pesticide, leather, and electroplating industries.
Relevant enterprises must reassess the chemical substances involved in their production and supply chains to ensure compliance with the new management requirements. Export-oriented enterprises, in particular, must meet both domestic and international compliance standards, as some substances in the list are already subject to strict international regulations.
Additionally, the implementation of the list may drive technological upgrades in related industries. For example, enterprises may need to identify substitute materials or improve production processes to reduce the use and discharge of highly hazardous chemical substances.
Strategies for Enterprises
In response to the potential regulatory upgrades brought by the "List Three (Draft)," REACH24H Consulting Group recommends that relevant enterprises take the following actions immediately:
Thorough Supply Chain Screening
Conduct a comprehensive chemical screening of raw materials, intermediates, and final products against the "List Three (Draft)" (particularly the PFASs under item PC064) to identify potential compliance risks.
Development of Technical Substitution Roadmaps
For applications involving substances listed in the "List Three (Draft)," develop clear technical substitution roadmaps for non-priority control chemicals, specifying performance indicators, R&D investments, and substitution timelines.
Risk Assessment and Disclosure
Establish internal environmental risk assessment mechanisms to evaluate the environmental and health risks of chemicals listed in the "List Three (Draft)" and prepare communication and disclosure materials for regulatory authorities and supply chain partners.
Preventing Substitution Pitfalls
When seeking substitutes for pollutants, conduct comprehensive toxicological and environmental safety assessments to prevent substituting one hazardous substance with another.
Final Remarks
The release of the "List of Priority Controlled Chemicals (Third Batch) (Draft)" marks a deepening phase in China's new pollutants control efforts and signals China's commitment to fulfilling international environmental conventions and advancing new pollutants control.
The expanded inclusion of PFASs requires enterprises to elevate chemical risk management and green substitution to a strategic level. Enterprises should accelerate technological innovation and industrial transformation, actively taking measures to meet the new regulatory requirements and achieve a balanced outcome for environmental protection and economic growth.
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