Introduction
Recently, the 17th Global Chemical Regulations Annual Forum (CRAC China 2025) successfully concluded. At the forum, Ms. Liu Hongying, Director of the Research Office of the Solid Waste and Chemicals Management Technology Center of the Ministry of Ecology and Environment, delivered an insightful speech focusing on the new trends and requirements of chemicals environmental management, and the latest progress and future directions in the regulation of new chemical substances.
New Requirements for China's Chemical Environmental Management
Currently, global chemical management is undergoing a critical transformation. In response to increasingly complex chemical challenges, the international community is striving to establish a more robust, sustainable, and intelligent management system by building new global frameworks, enhancing international cooperation, and promoting regulatory updates and technological innovation.
In China, chemical environmental management has entered the new pollutant governance phase. To meet these new requirements, the country is deepening systemic reforms and gradually building a modern governance system centered on risk prevention and control, covering the entire lifecycle of chemicals.
According to Ms. Liu, since the concept of new pollutant governance was first proposed at the National Conference on Ecological and Environmental Protection in 2018, General Secretary Xi Jinping has repeatedly emphasized the importance of new pollutant governance in various meetings.
The CPC Central Committee and the State Council have issued multiple documents on new pollutant governance, culminating in the official release of the Action Plan for New Pollutant Control in May 2022, which has progressively advanced the implementation of related work.
Furthermore, in July 2024, the Third Plenary Session of the 20th Central Committee of CPC adopted the Decision of the CPC Central Committee on Further Comprehensively Deepening Reform and Promoting Chinese-Style Modernization, which explicitly proposed the establishment of a synergistic management, new pollutant governance and environmental risk control system, providing strategic guidance for governance in this new phase.
5 Key Shifts of China's Ecological and Environmental Governance
Under these new circumstances and requirements, China's ecological and environmental governance has undergone five key shifts:
Shifting from total quantity and quality management to environmental risk management;
Shifting from end-of-pipe treatment to full life-cycle management;
Shifting from extensive decision-making to refined priority management;
Shifting from single governance to collaborative governance;
Shifting from pollution prevention to building a life community.
These shifts highlight the increasing emphasis on scientific, precise, coordinated, and sustainable chemical environmental management in China.
Progress and Trends in New Chemical Substance Management
Establishment of a Sound Environmental Risk Management System for New Chemical Substances
The Measures for the Environmental Management Registration of New Chemical Substances (hereinafter referred to as the "Measures") is a key component of China's chemical environmental management legislation. With the implementation of the Measures, the regulatory, policy, and technical systems for new chemical substance management have matured, steadily advancing toward the goal of establishing of a Sound Environmental Risk Management System for New Chemical Substances.
The MEE has issued multiple regulations, policies, and technical documents based on the Measures, forming a management system supported by the Registration Guidelines and a series of technical guidelines for environmental risk assessment. This system provides strong technical support for six key stakeholders: applicants, technical review organization, local regulatory authorities, testing institutions, consulting firms, and others involved in the registration and regulation of new chemical substances.
Incorporated into the New Pollutants Treatment System
On May 24, 2022, the General Office of the State Council issued the Action Plan for New Pollutant Control, formally integrating new chemical substance management into the control of new pollutants system. The plan mandates the full implementation of the New Chemical Substance Registration System.
Through this system, the environmental risks of new chemical substances are assessed and managed throughout their lifecycle, with strict enforcement of source entry control and categorized management to prevent the emergence of new pollutants.
Additionally, by combining the "screening", "evaluation", and "control" management methods for existing chemicals, the system promotes coordinated environmental risk prevention and control, creating a closed-loop governance framework for new pollutant control that integrates the management of new and existing chemical substances.
Incorporation into the Ecological Environment Code and Other Key Regulatory Frameworks
On April 30, 2025, the draft Ecological Environment Code (hereinafter referred to as the "Code") was released for public consultation. During the consultation period, 3,154 individuals submitted 11,179 pieces of feedback, demonstrating significant public interest in the Code.
Articles 644 and 645 of the draft Code explicitly stipulate the implementation of the New Chemical Substance Registration System, stating that the production, import, or use of substances without registration constitutes a violation.
Additionally, Article 1173 increases the maximum fine amount for such violations to 2 million yuan.
The incorporation of the New Chemical Substance Registration System in the Code not only elevates its legal status but also underscores China's commitment to advancing the management of new chemical substances, marking another milestone in the development of the regulatory framework.
Carry out Synergistic Management of Policies
To implement the requirements of the Action Plan for New Pollutant Control, the MEE issued the Opinions on Strengthen the Environmental Impact Assessment of Construction Projects Involving New Pollutants in Key Industries (hereinafter referred to as the "Opinions") on April 10, 2025.
Section 3, Article 6 of the Opinions specifies the requirements for new chemical substance registration: According to the IECSC, if the raw and auxiliary materials or products belong to new chemical substances, or if the existing chemical substances under environmental management of new use are used for industrial purposes other than the permitted uses, the requirements of environmental management registration for new chemical substances according to relevant regulations shall be put forward in the environmental impact assessment document.
This marks the first time the MEE has formally integrated the New Chemical Substance Registration System with other management policies. The Opinions require that EIA documents for construction projects in key industries such as petrochemicals, coatings, textile printing and dyeing, rubber, pesticides, and pharmaceuticals reflect the relevant new chemical substance registration requirements.
This initiative represents a significant step forward in enforcing the registration entry system for new chemical substances. By linking registration with EIA policies, it strengthens environmental entry management at the production and import stages, effectively controlling the increase of new pollutants.
Strict Registration Access and Environmental Risk Prevention
Ms. Liu also briefly reviewed the data on regular and simplified registrations processed, reviewed, and approved between 2022 and 2024.
The data shows that simplified registrations have consistently remained high, while regular registrations have steadily increased, indicating growing compliance awareness among enterprises and greater participation in the registration process.
To ensure the quality of registration data, SCC-MEE organized an expert review meeting last year to evaluate 15 ecotoxicological test reports with significant issues. Ten reports were deemed unsuitable for registration due to severe quality problems.
The quality of test data directly affects the accuracy of hazard identification and environmental risk assessment conclusions, as well as the scientific basis for registration decision-making. This work reflects SCC's commitment to data quality control, which will continue to support scientific decision-making and strengthen environmental risk mitigation.
Continuously Improve the Inventory of Existing Chemical Substances in China (IECSC)
The MEE has prioritized the management of the Inventory of Existing Chemical Substances in China (IECSC), which remains under ongoing updates. In 2025, the MEE issued one Supplementary Announcements, bringing the total number of substances in the Inventory to over 47,000.
Ms. Liu advised enterprises to monitor updates to the Inventory to accurately determine the status of their substances. She also reminded companies that substances produced, imported, sold, or used before October 15, 2003, can still be added to the Inventory through streamlined compliance pathways.
Additionally, as the protection period for chemical identification information for many registered substances is set to expire by the end of this year, the MEE issued a Work Reminder Regarding the Extension Application for Chemical Substance Identification Information Disclosure on August 20, extending the application deadline to September 15, 2025. Ms. Liu urged relevant enterprises to submit their applications promptly.
Continuously improve the level of digitalization and enterprise-friendly services
In addition to enforcing the registration system, SCC-MEE has implemented several enterprise-friendly services, including:
Launching a real-time query function for the Inventory on the MEE's official platform, integrating and updating supplementary data for easy access.
Enabling a one-net management online registration system for new chemical substances, allowing enterprises to complete the entire process online, including submission, status tracking, and receipt of electronic certificates.
Introducing a dedicated service page for new chemical substance registration on the Center's website, consolidating 12 functions such as policy queries, service guidelines, and FAQs into one platform for easy access.
Conclusion
Finally, in light of the evolving domestic and international chemical environmental management landscape and the deepening implementation of China's New Chemical Substance Registration System, Ms. Liu offered the following recommendations to relevant industries:
Understanding Policy and Trends: Closely monitor developments in domestic and international chemical management regulations to understand compliance obligations.
Assessing Enterprise Chemical Profiles: Assess the production, use, and emissions of your substances to determine compliance with environmental management requirements.
Standardizing Environmental Risk Control: Implement registration and record notification for new chemical substances, enforce environmental risk control measures, and manage the risk of existing substances in compliance with priority control chemical lists and key control pollutant lists.
Forward-looking R&D and Innovation: Develop sustainable alternative technologies for high-risk toxic substances, prepare risk prevention plans, and establish risk mitigation mechanisms to achieve compliance and sustainable development.
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