June 30, 2026
By Lily Hou, PhD., CHMM, Regulatory Affairs Lead, Software, UL Solutions
On June 11, 2026, China’s Ministry of Ecology and Environment (MEE) released a draft revision of the Measures for the Environmental Management Registration of New Chemical Substances (China REACH) for public comment. The draft is intended to implement relevant provisions of China’s newly adopted Ecological and Environmental Code and strengthen the registration framework for new chemical substances. Once finalized, the revised measures would replace MEE Order No. 12 of 2020. The draft proposes broad revisions to the Measures, with three key changes summarized below.
Registration applicants
Under MEE Order No. 12, manufacturers and importers may register new chemical substances, while foreign companies exporting them to China may register through an appointed Chinese agent. The draft narrows registrant eligibility by allowing only manufacturers or importers of new chemical substances located in China to register. As a result, foreign suppliers could no longer act as registrants and would need to rely on the Chinese importer as the registration holder.
Registration categories
MEE Order No. 12 currently sets out three registration categories:
- Regular registration for substances manufactured or imported at 10 tonnes or more per year;
- Simplified registration for volumes from 1 tonne to less than 10 tonnes per year; and
- Record filing for volumes below 1 tonne per year and for polymers that meet specified conditions.
The draft would reduce these to two registration categories:
- Regular registration for volumes of 1 tonne per year or more; and
- Simplified registration for volumes below 1 tonne per year.
Once the revised measures take effect, substances below 1 tonne per year that currently qualify for record filing would be subject to an approval-based registration process. For substances that have already completed record filing under MEE Order No. 12, the filing applicant would need to apply for a registration certificate by December 31, 2026.
Exemptions
MEE Order No. 12 currently excludes certain product categories that are already regulated under other laws and regulations, including pharmaceuticals, pesticides, veterinary drugs, cosmetics, food and food additives, feed and feed additives, radioactive substances, military industry products, and tobacco.
The draft removes these product-category exclusions, except for radioactive chemical substances. It instead adds exemptions for substances used in scientific research and technical services, such as testing, inspection, measurement, and monitoring.
For new applications, the amended Measures are expected to take effect on August 15, 2026. Applications already accepted by MEE may continue to be evaluated under MEE Order No. 12, and registration certificates issued under MEE Order No. 12 will remain valid after the amended Measures come into force.
The consultation period closes on July 12. Enterprises, organizations, and individuals may submit comments and suggestions by email to liuxiaojian@meescc.cn.
References
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