Introduction

On August 20, 2025, the Solid Waste and Chemicals Management Technology Center of the Ministry of Ecology and Environment (MEE) issued an important notice titled "Guidance on Extension Application for Chemical Substance Identification Information Disclosure". This marks the first extension application process for identification information disclosure since the implementation of Order No. 12, drawing significant attention from the industry following the notice's release. 

The guidance specifies that, in accordance with the Measures for the Environmental Management Registration of New Chemical Substances (Ministry of Ecology and Environment Order No. 12, hereinafter referred to as the Measures) and the Guidelines for the Environmental Management Registration of New Chemical Substances: 

• For chemical substances that obtained a Registration Certificate under the Measures on Environmental Management of New Chemical Substances (State Environmental Protection Administration Order No. 7) before December 31, 2020, and for chemical substances listed in the Inventory of Existing Chemical Substances in China (IECSC) with identification information protection prior to the Measures taking effect, the identification information protection period is valid until December 31, 2025;

• Applicants may apply for an extension of disclosure, with a maximum extension of up to 5 years;

• Certificate holders must submit extension application materials at least six months before the expiration of the identification information protection period.

The submission deadline has now been extended to September 15, 2025. Registration Certificate holders requiring an extension are advised to prepare the necessary statement materials and submit their applications via the Online Registration System for New Chemical Substances.

REACH24H has confirmed with the authorities that, based on the Guidelines and the provisions regarding the disclosure and extension of disclosure application of chemical substance identification information in the Inventory, the applicable substances and material submission requirements for this extension application are clarified as follows:

Applicable Scope

Based on the notice, the relevant provisions in the Measures and the Guidelines, and further communication with the authorities, the scope of this extension application is defined as follows:

Applicable Substances

This applies exclusively to chemical substances that obtained a Regular Notification Certificate under Order No. 7 before the Measures took effect on January 1, 2021, and were granted identification information protection (including substances listed and not listed in the Inventory).

Note: Even if the applicant later cancels the Notification Certificate, the substance may still be listed in the Inventory under the Measures and remains eligible for this extension application.

Unapplicable Substances

- Confidential substances registered under the former Order No. 17 (State Environmental Protection Administration Order No. 17);  

- Chemical substances registered under Simplified Notification/Registration or Record;  

- Chemical substances added to the Inventory due to actual activity in China before October 15, 2003.

It is worth noting that, based on REACH24H's past experience, if multiple applicants exist for the same substance and one or more applicants did not apply for identification information protection during registration, the substance will be included in the Inventory with publicly disclosed identification information.

Special Reminder for Transition Period Substances

It should be emphasized that for chemical substances that obtained a Regular Notification Certificate under Order No. 7 and applied for identification information protection during the transition period (January 1, 2021, to June 30, 2021) after the Measures took effect, the extension application materials must be submitted at least six months before the expiration of the identification information protection period.

For example, if a confidential substance obtained a Regular Notification Certificate under Order No. 7 on May 1, 2021, its identification information protection period would expire on May 1, 2026. The Certificate holder must submit the extension application before November 1, 2025.

REACH24H advises Certificate holders with such substances to pay attention to the submission deadline for extension applications and submit their applications promptly.

Extension Application Submission Process

According to the notice, Certificate holders requiring an extension must follow the steps below to submit their applications:

Submission Method

Applicants must log in to the Online Registration System for New Chemical Substances via the Ministry of Ecology and Environment's Government Services Hall to complete the extension application and material submission online.

Required Materials

• Registration Certificate number, 

• Applicant name, 

• Agent name (if applicable), 

• Basic information of the substance, 

• Statement on Identification Information Protection, 

• Necessity Statement Materials, 

• Contact information

• Application commitment

Approval Progress

After submission, companies can check the approval status and outcome in the system and view Requests for Supplementary Information or Approval Outcome notifications in the "Certificates and Notifications" section.

Extension Application Review Criteria

According to the Guidelines, the review procedure and considerations for deferred disclosure applications are as follows:

• Approval for Extension

All Certificate holders for the proposed substance must ALL submit their applications on time, provide sufficient and reasonable justification, and ensure the substance is not classified as a high-hazard chemical substance or one with significant potential environmental/health risks.

• Rejection of Application

Applications will be rejected under the following circumstances:  

- One or more Certificate holders for the proposed substance fail to submit their applications on time;  

- The Necessity Statement is sufficient;  

- The substance is classified as a high-hazard chemical substance or poses significant potential environmental/health risks, and extension of disclosure may significantly impact public interest.

To ensure successful approval, companies should:  

- Ensure all applicants for the same substance (e.g., Joint Notification) submit their applications on time;  

- Provide sufficient justification in the Necessity Statement;  

- Avoid submitting applications for substances classified as high-hazard chemical substances under the Guidelines;  

- Monitor the approval process and outcome in the registration system and address any Requests for Supplementary Information promptly.

Necessity Statement for Extension Application

The sufficiency of the Necessity Statement largely determines whether the extension application will be approved. According to the Guidelines, the Necessity Statement should include, but is not limited to:

• Specific identification information columns and corresponding periods for the proposed deferred disclosure substance;  

• Explanation of whether the identification information for the substance proposed for deferred disclosure is publicly accessible, including but not limited to:  

- Whether the identification information appears in advertisements/promotional materials, publications, public patents/literature, databases, the internet, or other publicly available materials or media, and whether it is associated with the applicant's corporate information, enabling the public or competitors to access this information;  

- Whether the identification information has been disclosed or published by the Ministry of Ecology and Environment or other domestic/foreign competent authorities. If so, provide details of the disclosure.  

• Explanation of whether the identification information retains commercial value, including evidence or reasonable expectations that disclosure would cause substantial harm to the applicant's market competitive position, and the causal relationship between disclosure and harm;  

•  Measures taken and to be implemented by the applicant to prevent the disclosure of the identification information, along with specific details of these measures.

These requirements align with the Necessity Statement for Identification Information Protection Applications under Order No. 12. Companies can prepare the Necessity Statement accordingly.

Concluding Remarks

According to the notice, this extension application provides an additional opportunity for substances listed in the Inventory under Order No. 7. Considering the large number of substances involved and the submission window of less than one month, REACH24H recommends that companies immediately take the following actions:

• Immediate Review: Immediately review the registration status of new chemical substances under Order No. 7 to confirm whether any substances fall within the scope of this extension application.  

• Timely Response: For substances requiring an extension, complete material preparation and system submission by September 15, 2025, to avoid disclosure due to missed deadlines.  

• Professional Compliance Support: Leveraging extensive experience in information protection applications and successful cases, REACH24H can provide full-process assistance, including drafting the Statement of Necessity and system operations. For inquiries, please contact us anytime.