China Ends New Chemical Record Notifications: Interim Registration Application Route Now Live

Key Dates for Companies

MEE published Huanban Guti Han [2026] No. 301 on August 4, 2026. Dated July 31, the notice took effect on August 15, the same day as the Ecological and Environmental Code of the People's Republic of China.

Which New Chemical Substances Are Affected?

The notice refers to substances that meet the current record-notification conditions in Article 10, Paragraph 3 of MEE Order No. 12. These include:

• new chemical substances with an annual production or import volume of less than 1 metric ton;

• polymers in which the content of monomers or reactants that are new chemical substances does not exceed 2%; and

• polymers of low concern that meet the applicable criteria.

Before August 15, an applicant could begin the notified activity after submitting complete record-notification materials and receiving the system-generated receipt. From August 15, these categories no longer proceed through that record-based mechanism. The application is instead reviewed under the interim arrangement established by the new notice.

What Must Be Submitted Under the Interim Route?

For substances that would previously have qualified for record notification, the applicant must submit:

1. a new chemical substance environmental management registration application form;

2. evidence showing that the substance meets the relevant condition in Article 10, Paragraph 3 of MEE Order No. 12; and

3. any other information already held on the substance's environmental and health hazard characteristics and environmental risks.

The formal submission list remains based on the August 4 notice. The updated system adds operational fields and attachments, including intended-use information and confidential-information protection inputs. MEE reviews these applications by reference to simplified registration procedures and time limits, so submission alone does not complete the approval process and companies must be prepared to respond to correction or supplementary-information requests.

Under the current simplified registration framework, the technical review period may take up to 30 days. MEE must generally make its decision within 20 working days, with a possible extension of 10 working days; the technical review period is not counted in that decision period, and time used by the applicant to supplement materials is not counted in the technical review period. These statutory time frames are planning references rather than a guaranteed overall completion time.

Companies should also follow any updated system instructions or implementation guidance issued for the interim route.

What Does the Updated Government Service System Confirm?

The following observations are based on REACH24H's review of the current online application system as of August 17, 2026. They describe the system configuration currently available and should be read together with Huanban Guti Han [2026] No. 301, MEE Order No. 12 and any later official guidance or system instructions.

1. A Separate “Registration Application” Entry Is Now Available

The system homepage now displays three parallel entries: Regular Registration, Simplified Registration and Registration Application. The new Registration Application entry is not shown as a sub-type of regular or simplified registration; it is the dedicated entry for substances that previously met the record-notification conditions.

Figure 1. The updated system lists Regular Registration, Simplified Registration and the new Registration Application entry.

2. Applicants Must Be China-Based Enterprises or Public Institutions

The Registration Application form currently restricts the applicant to an enterprise or public institution legally registered in China, and the former agent section has been removed. The same applicant-field adjustment is visible in the current Regular Registration and Simplified Registration forms. Overseas manufacturers and exporters should therefore not assume that they can continue to apply directly. For imported substances, the relevant China-based importer should be confirmed as the applicant, with responsibilities and confidential-information arrangements agreed in advance.

3. Each Registration Application Covers One Substance

Unlike the former record-notification form, which could accommodate multiple substances in one filing, the current Registration Application form follows a one-application, one-substance structure. Companies with multiple substances should separate the projects and allow sufficient time for system entry, supporting-document checks and internal approval.

4. Intended-Use Information Is Required

The updated form requires information on the proposed use of the substance, including use classification, use code, the specific intended use and the function under that use. Companies should verify the actual use with business, R&D and downstream customers before submission so that the online form, internal records and supply-chain communications remain consistent.

Figure 2. The current form contains required fields for use classification, intended use and function.

5. Confidential Substance Identity Protection Requires Supporting Information

Where protection is requested for identifiers such as the Chinese or English chemical name, CAS number, molecular formula or structural formula, the system requires a proposed protection period, a summary of the reasons and an attachment. Under Article 13 of MEE Order No. 12, a statement explaining the necessity of commercial-secret protection must be submitted, and the protection period for substance-name and other identity information may not exceed five years from the first registration or record notification.

Figure 3. The current system requests a protection period, reason summary and supporting attachment.

6. Third-Party Submission Remains Available

Although the applicant must be a China-based enterprise or public institution, the system continues to provide a third-party submission channel. Where substance identity, reports or other sensitive technical information should not be transferred directly to the China-based applicant, an independent third party may submit the relevant information so that it can be combined with the applicant’s remaining materials, subject to the applicable official requirements.

Figure 4. The updated system retains a separate third-party submission entry.

7. Applications Remain Subject to Review and Supplement Requests

After submission, companies should monitor the progress of formality review and technical review and check whether a correction or supplementary-information request has been issued. REACH24H recommends assigning a responsible person to check the system notification icon regularly and respond within the stated period to avoid delaying acceptance or approval.

8. Existing Record Notifications

The August 4 notice does not require holders of existing record notifications to convert them into registration certificates by a specified date. The June revision draft proposed that applicants with existing record notifications apply for and obtain the applicable registration certificate by December 31, 2026. This proposed date should not be described as the expiry date of a record-notification receipt or treated as a final obligation unless it appears in the formally issued rules.

9. Final Pathways and Supporting Guidance

The notice states that it will automatically cease to apply when MEE issues new provisions on new chemical substance environmental management registration. Companies should therefore treat the August 4 notice as the interim basis and monitor the final Measures, supporting guidance, further online-system updates and transition instructions.

For a detailed comparison of the June proposal and the current Order No. 12, see REACH24H's analysis of the 2026 China new chemical substance registration revision draft.

What Should Companies Do Now?

Companies manufacturing, importing or supplying new chemical substances to China should prioritize the following actions:

1. Confirm the status of former record-notification projects. Verify whether a complete filing and system-generated receipt were obtained before the cut-off. Projects not completed under the former route should be reorganized for the Registration Application pathway.

2. Confirm the China-based applicant. For imports, agree which importer or affiliated China entity will act as applicant and document the allocation of regulatory responsibilities.

3. Separate multi-substance projects. Plan one application and one supporting-document set for each substance rather than carrying over the former multi-substance filing approach.

4. Validate intended-use information. Confirm the use classification, use code, specific intended use and function with the relevant business and downstream teams.

5. Prepare confidential-information arrangements. Complete the protection-necessity statement and attachments where identity protection is requested, and decide whether third-party submission is needed.

6. Monitor the online system. Check system notifications regularly and respond promptly to correction or supplementary-information requests during formality or technical review.

How REACH24H Can Support China REACH Compliance

REACH24H supports overseas manufacturers, exporters and China importers in assessing and implementing the current interim registration arrangement under China's new chemical substance environmental management framework. Our support includes:

• IECSC status checks and screening of affected substance portfolios;

• pathway, polymer-eligibility, applicant and supply-chain assessments;

• application material review, including intended-use and confidential-information inputs, data-gap analysis and testing strategy development where needed;

• registration dossier preparation, third-party submission coordination, supplementary-response support and follow-up compliance planning.

Companies preparing low-volume or polymer submissions can contact REACH24H to assess how the operational Registration Application route affects planned production, import or shipment schedules.

Recommended Reading

• China MEE Proposes Major Revisions to New Chemical Substance Registration Measures

• MEE Order No. 12 Draft Revision: How Existing Certificates and Record Notifications Would Transition

• China Notifies WTO of Revised New Chemical Substance Registration Measures: What Global Companies Need to Know

• MEE Order No. 12 Revision FAQ: Practical Questions from Overseas Companies

Official References

• MEE Notice on Matters Concerning the Environmental Management Registration of New Chemical Substances (unofficial English title; Huanban Guti Han [2026] No. 301)

• MEE Order No. 12: Measures for the Environmental Management Registration of New Chemical Substances

• MEE Public Consultation on the 2026 Revision Draft