CHINA CHEMICAL REGULATORY UPDATE
On March 12, 2026, China adopted the Ecological and Environmental Code of the People's Republic of China, which will come into effect on August 15, 2026. For chemical companies manufacturing, importing, selling, or using substances in China, the Code reinforces source-level environmental risk control, new pollutant management, and China REACH new chemical substance registration under MEE Order No. 12.
Quick Navigation
Jump to the key sections of this article.
Key Takeaways for Chemical Companies
The Ecological and Environmental Code does not only consolidate environmental legislation. For chemical businesses, it strengthens the legal foundation for source-level environmental risk control, chemical substance information reporting, new pollutant management, and new chemical substance registration.
China REACH remains central. Companies producing or importing new chemical substances should continue to assess whether China REACH registration or notification is required before manufacture or import.
New pollutant controls become more prominent. The Code provides a stronger legal basis for managing key controlled new pollutants, including prohibition, restriction, or other risk control measures. Companies may also need to monitor China new pollutant regulatory compliance.
Supply chain responsibility increases. Downstream users may face compliance pressure when using unregistered, restricted, or inadequately documented chemical substances.
Penalties become more severe. Violations involving new chemical substances or key controlled new pollutants may lead to higher fines, production restriction, suspension, or shutdown in serious cases.
What Is China's Ecological and Environmental Code?
The Ecological and Environmental Code is China's first unified legal framework dedicated to ecological and environmental protection. It consolidates multiple environmental laws into a codified structure and is designed to provide a more systematic basis for pollution prevention, ecological protection, green and low-carbon development, and legal liability.
The Code contains five sections and 1,242 articles, covering general provisions, pollution prevention and control, ecological protection, green and low-carbon development, and legal liability and supplementary provisions. For chemical companies, the most relevant parts are those related to chemical substance pollution risk control, new pollutants, and new chemical substance registration under MEE Order No. 12.
| Dimension | What Changes | Compliance Meaning |
|---|---|---|
| Systematic legal framework | Environmental requirements are consolidated into a clearer codified framework. | Chemical companies should review compliance obligations across product development, manufacture, import, use, storage, and disposal. |
| Source-level prevention | The Code emphasizes risk prevention at the source rather than only end-of-pipe treatment. | Companies should build China compliance checks into R&D, procurement, formula design, and raw material onboarding. |
| New pollutant management | Chemical pollution risk assessment and key controlled new pollutant management receive stronger legal support. | Substances should be checked against China’s new pollutant control requirements and relevant restriction or prohibition measures. |
| Legal liability | The Code strengthens the liability framework for violations involving new chemicals and controlled pollutants. | Companies should not rely only on shipment-stage checks; ongoing certificate-condition management and supply chain traceability become more important. |
Key Provisions for Chemical Substance Management
For chemical enterprises, the most consequential changes lie in Chapter 34 of Section II, which establishes a framework for chemical substance pollution risk control. Companies should read these provisions together with the current Measures for the Environmental Management Registration of New Chemical Substances and the 2026 MEE public consultation on the draft revision.
| Provision | Core Requirement | Practical Compliance Action |
|---|---|---|
| Article 645 | Establishes a coordinated control and environmental risk management system for new pollutants. | Monitor China's new pollutant control list and assess whether substances in your portfolio are subject to restriction, prohibition, or risk control measures. |
| Article 647 | Supports periodic chemical pollution surveys by MEE. | Maintain accurate records of substance identity, physicochemical properties, quantities, uses, hazard characteristics, emissions, and supply chain flows. |
| Article 649 | Provides a legal basis for assessing chemical pollution risks and establishing a Key Control New Pollutant List. | Check whether substances are banned, restricted, or subject to additional environmental risk control requirements. Consider reviewing China new pollutant compliance requirements. |
| Article 650 | Requires companies producing or importing new chemical substances to apply for environmental management registration with MEE before production or import. | Conduct IECSC screening, determine whether the substance is “new,” and select the appropriate China REACH pathway, such as record notification, simplified registration, regular registration, or new usage management registration. |
Stricter Penalties for Chemical Compliance Violations
The Code significantly raises the compliance stakes for chemical companies. Violations involving key controlled new pollutants, non-compliance with registration certificate conditions, or production/import without new chemical substance registration may trigger higher fines and administrative measures.
| Violation Type | Potential Fine | Additional Measures |
|---|---|---|
| Non-compliance with prohibition or restriction measures for key controlled new pollutants | RMB 100,000–500,000; if not corrected, RMB 500,000–1,000,000 | Production restriction, suspension for rectification, suspension of business, or facility shutdown in serious cases |
| Violation of requirements under a new chemical substance registration certificate | RMB 200,000–1,000,000; if not corrected, RMB 1,000,000–2,000,000 | Production restriction, suspension, certificate revocation, business suspension, or shutdown in serious cases |
| Production, import, or use of unregistered new chemical substances | Fines may reach up to RMB 2,000,000, depending on the violation and correction status | Production restriction, suspension, shutdown, and possible downstream supply chain liability |
What Does the Code Mean for China REACH Compliance?
The Code should be read together with China's existing new chemical substance registration system. Under the Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No. 12), a chemical substance not listed in the Inventory of Existing Chemical Substances in China (IECSC) may be considered a new chemical substance and may require registration or notification before manufacture or import.
MEE also released a draft revision to MEE Order No. 12 for public consultation on June 11, 2026, together with the Revision Draft for Public Comment. Companies should monitor the final text because the revision may affect scope interpretation, registration thresholds, applicants, timelines, and IECSC inclusion rules.
In practical terms, the Code reinforces the importance of China REACH compliance in three areas:
Pre-market control: companies should not manufacture or import a new chemical substance in China before confirming the required registration pathway.
Certificate-condition management: approved quantity, use, activity type, environmental risk control measures, and post-registration obligations should be monitored continuously.
Supply chain verification: downstream users should verify whether raw materials, intermediates, and formulated substances are properly registered, exempted, or listed in IECSC. Where supplier documentation is incomplete, companies may need a structured Chinese supplier chain compliance review.
Practical implication: companies planning to introduce new substances, polymers, intermediates, functional preparations, or substances subject to new usage environmental management into China should confirm their IECSC status and China REACH pathway before product development, sample shipment, import, or commercial supply.
Compliance Checklist Before the Code Takes Effect
Before August 15, 2026, chemical companies should review their China-related substance portfolio and supply chain exposure. The following checklist can help regulatory, EHS, R&D, procurement, and supply chain teams prioritize actions.
| Action | Purpose | Recommended Output |
|---|---|---|
| Check IECSC status | Determine whether a substance is existing or new under China REACH. | Public or confidential IECSC screening result and registration pathway assessment |
| Confirm registration pathway | Identify whether record notification, simplified registration, regular registration, or new usage management registration applies. | China REACH pathway memo with volume, use, polymer status, and hazard considerations |
| Review new pollutant exposure | Assess whether substances are subject to new pollutant control or future listing risk. | New pollutant screening result and risk mitigation plan |
| Check SDS, labels, and hazard communication | Ensure hazard information is consistent with China GHS and chemical safety requirements. | Reviewed China GHS SDS and label documents |
| Audit supplier documentation | Avoid using raw materials with unclear China REACH, IECSC, or restriction status. | Supplier declaration, substance identity data, registration evidence, and portfolio risk ranking |
How REACH24H Can Support Chemical Companies
REACH24H supports overseas manufacturers, exporters, formulators, distributors, importers, and downstream users in assessing how the Ecological and Environmental Code, MEE Order No. 12, and new pollutant management requirements may affect China market access and ongoing chemical compliance.
China REACH applicability assessment: determine whether a substance triggers new chemical substance registration under MEE Order No. 12.
IECSC screening: support public and confidential IECSC searches and interpret substance identity, CAS number, polymer, UVCB, and new usage management questions.
Registration pathway strategy: assess record notification, simplified registration, regular registration, and new usage management registration options.
Dossier and data gap review: evaluate physicochemical, toxicological, ecotoxicological, PBT, QSAR, read-across, and testing strategy requirements.
New pollutant compliance review: screen substance portfolios against China’s new pollutant control direction and recommend risk mitigation actions.
Supply chain compliance: review supplier declarations, registration evidence, SDS, labels, and downstream communication responsibilities.
Post-registration management: support first activity reports, annual reports, certificate amendments, information disclosure, and ongoing risk control obligations via the MEE government service portal.
FAQ
Does the Ecological and Environmental Code replace MEE Order No. 12?
No. The Code provides a higher-level legal framework for ecological and environmental protection. MEE Order No. 12 remains the core implementing regulation for environmental management registration of new chemical substances, while MEE’s 2026 revision draft may further adjust the detailed registration system.
Who should pay attention to this Code?
Chemical manufacturers, overseas exporters, China importers, formulators, downstream users, distributors, and supply chain compliance teams should review how the Code affects new chemical substance registration, new pollutant control, supplier management, and hazard communication obligations.
What is the first step for a company planning to import a chemical into China?
The first step is to confirm whether the substance is listed in IECSC. If the substance is not listed or is subject to new usage environmental management, companies should assess the applicable China REACH pathway before shipment, testing, sample import, or commercial supply.
Does China REACH only affect hazardous chemicals?
No. China REACH focuses on whether a chemical substance is “new” under the MEE framework and whether it triggers registration or notification. Hazardous properties, persistence, bioaccumulation, toxicity, and exposure may affect data requirements and risk control measures, but a substance does not need to be classified as a hazardous chemical to require assessment.
Recommended Reading
Revisions to Management of New Chemical Substances: What Overseas Cosmetic Brands Should Know
China MEE Proposes Major Revisions to New Chemical Substance Registration Measures
China REACH: New Chemical Substance Registration under MEE Order No. 12
Managing New Pollutants in China: Pollutant Regulations and Enterprise Compliance Strategies
Related Services
Official Resources
MEE Order No. 12: Measures for the Environmental Management Registration of New Chemical Substances
MEE: Public Consultation Letter on the Draft Revision of the Measures
Need to confirm whether your substance triggers China REACH registration?
REACH24H can help you check IECSC status, determine the applicable registration pathway, review data gaps, and build a practical China chemical compliance strategy before shipment or market entry.
浙公网安备 33011002014301号