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

At a Glance: Two Comment Processes for the Same Draft

The domestic consultation conducted by China's Ministry of Ecology and Environment (MEE) and the WTO/TBT review concern the same revision draft, but they are separate procedures. The MEE consultation closed on July 12, while the international review remains open. For a detailed breakdown of the proposed substantive changes, see REACH24H's earlier analysis of the China new chemical substance registration revision.

Where Does the Revision Process Stand?

The Measures on the Environmental Management Registration of New Chemical Substances are departmental rules. The MEE public consultation notice confirms that the revision was prepared to implement relevant provisions of China’s Ecological and Environmental Code and improve the new chemical substance registration system.

The draft remains subject to possible adjustment. Comments submitted through the WTO/TBT process may be considered by the notifying member, but consideration does not mean that every comment will be accepted or that the measure will necessarily be delayed or withdrawn. Companies should confirm the final requirements and implementation timeline only after the official rules are published.

Why the WTO/TBT Review Matters for Chemical Companies

The WTO Technical Barriers to Trade framework is designed to improve regulatory transparency and help prevent technical regulations, standards and conformity assessment procedures from creating unnecessary obstacles to trade. At this stage, companies can provide evidence on how proposed data, testing, registration, disclosure or transition requirements may operate in real cross-border supply chains.

For businesses, the review can help identify differences between the draft requirements and international standards, regulatory systems in major trading partners, and established global compliance practices. It also provides an opportunity to highlight practical concerns relating to duplicate testing, acceptance of overseas data, confidential business information, importer responsibilities, transition periods and supply-chain information sharing.

Even where a company does not submit formal comments, the review window is a useful trigger for an early impact assessment. Companies can begin planning changes to data ownership, contracts, testing strategies, applicant arrangements and downstream communication before the final rules are issued.

Who May Submit Comments and What Should They Address?

Under the WTO/TBT framework, businesses generally coordinate comments through the relevant national or regional TBT enquiry point rather than submitting domestic legislative comments directly to the WTO Secretariat. Overseas companies and associations should first check the procedures and internal deadlines set by their own enquiry points. Multinational groups may also need coordination between headquarters, Chinese entities, importers and industry associations.

Effective comments should be technical, trade-related and actionable. They should identify the relevant draft provision, explain the operational impact, provide supporting evidence, compare the proposal with international standards or established practice, and suggest a workable alternative where possible.

Recommended Actions Before August 30, 2026

1. Review Substance Portfolios

Screen relevant substances by legal entity, substance identity, intended use, annual volume and supply-chain role. Confirm whether each substance is listed in the Inventory of Existing Chemical Substances in China (IECSC), whether it is subject to new-use environmental management, and whether the current business relies on a registration certificate or record-notification receipt.

2. Assess Registration and Transition Impacts

Review existing registrations and notifications, available data, contracts and internal systems. Companies should evaluate possible changes to registration categories, applicant arrangements, testing needs, compliance costs and transition workloads, while recognizing that the final requirements may differ from the draft.

3. Prepare Evidence-Based Regulatory Feedback

Avoid relying on general statements such as “the proposal increases costs.” A stronger submission connects the draft provision to a specific business impact, quantifies time or cost where possible, explains the trade relevance, provides technical or regulatory evidence, and proposes practical wording or an alternative approach.

4. Review Supply-Chain and Confidentiality Arrangements

Clarify who owns and may use regulatory data, who will hold registration responsibilities, and who must communicate risk-control and registration information downstream. Purchasing, toll-manufacturing, agency, distribution and confidentiality agreements may need to distinguish legally required information from information protected as confidential business information.

How REACH24H Can Help

REACH24H supports overseas manufacturers, exporters, importers and multinational groups in assessing the impact of China's new chemical substance requirements and preparing practical compliance strategies. Support can be aligned with the company's substance portfolio, supply-chain model and existing data rights.

• Regulatory impact assessment: Screen substances, uses, annual volumes and supply-chain roles against the draft and current China REACH framework.

• Registration and transition strategy: Evaluate possible registration pathways, conversion workloads and applicant arrangements.

• Data and CBI review: Assess data availability, ownership, testing gaps, overseas-data use and confidentiality risks.

• Supply-chain compliance planning: Review contracts, information-transfer responsibilities and post-registration controls.

Recommended Reading

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

• China REACH: New Chemical Substance Registration under MEE Order No. 12

• China Adopts Ecological and Environmental Code: What Companies Need to Know

Official Resources

• MEE Public Consultation on the Revision Draft

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

• WTO Technical Barriers to Trade Overview

• WTO ePing SPS&TBT Platform — search Notification No. G/TBT/N/CHN/1351/Rev.1

• WTO Handbook on TBT Notification Requirements