China MEE to End New Chemical Record Notifications on August 15

Key Dates for Companies

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.

Under the current Order No. 12, an applicant may begin the notified activity after submitting complete record-notification materials and receiving the system-generated receipt. From August 15, these categories will no longer proceed through that record-based mechanism. The application will instead be reviewed under the interim arrangement established by the new notice.

What Must Be Submitted from August 15?

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.

Based on the materials listed in the notice, the required submission materials are expected to remain broadly consistent with those under the current record-notification process. MEE will, however, review applications by reference to simplified registration procedures and time limits. Companies should therefore be prepared to respond to requests for supplementary information during the review.

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 after accepting the application, with a possible extension of 10 working days. Time used by the applicant to supplement materials is not counted in the technical review period. These statutory time frames should be treated as planning references; companies should also follow any system instructions or implementation guidance issued for the interim route.

What Does the Notice Leave Unresolved?

The August 4 notice establishes an interim process but does not finalize every issue raised by MEE's June 2026 revision draft.

Applicant Eligibility May Be Restricted

The June revision draft proposed limiting applicants to enterprises or public institutions legally registered in China and engaged in manufacturing or importing the substance. If this approach is carried into the final rules, overseas manufacturers and exporters may no longer be able to apply directly under the current foreign applicant and domestic agent model.

It is not clear from the wording of the August 4 notice whether this applicant restriction already applies to the interim registration route. It therefore remains uncertain whether an overseas enterprise may submit the application directly or whether a China-based manufacturer or importer must act as the applicant. Further clarification from MEE or the registration system is needed. Pending such clarification, overseas suppliers should identify a potential domestic applicant and plan how confidential business information would be protected and transferred if a China-based applicant is required.

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 existing notification applicants obtain registration certificates by December 31, 2026, but this deadline should not be presented as a final obligation unless it appears in the formally issued rules.

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 monitor the final measures, supporting registration guidance, online system updates, and any transition instructions before relying on a long-term compliance strategy.

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 or supplying new chemical substances to China should prioritize five actions:

1. Review submissions already in preparation. Determine whether any complete record notification can be submitted before August 15 and confirm the latest system arrangements.

2. Map the affected portfolio. Identify substances below 1 metric ton per year, polymers relying on the 2% rule, and polymers of low concern.

3. Prepare for authority review. Assemble substance identity information, volume and use data, polymer eligibility evidence, and all available environmental and health hazard information.

4. Assess possible applicant and supply-chain arrangements. Pending official clarification, overseas suppliers should identify a potential China-based manufacturer or importer that could act as the applicant and plan controls for confidential substance and composition information.

5. Monitor the final rules. Recheck applicant eligibility, data requirements, processing periods, existing-notification transition duties, and post-registration obligations once MEE publishes the final regulatory text.

How REACH24H Can Support China REACH Compliance

REACH24H supports overseas manufacturers, exporters, and China importers in responding to changes 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, data-gap analysis, and testing strategy development where needed; and

• registration dossier preparation, submission support, and follow-up compliance planning.

Companies preparing low-volume or polymer submissions can contact REACH24H to assess whether the August 15 change 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

• Record Notification | China New Chemical Substance Registration (China REACH)

Official Sources

• MEE Notice on Matters Concerning the Environmental Management Registration of New Chemical Substances (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