China Notifies WTO of Revised New Chemical Substance Registration Measures for Public Comment

China has submitted a TBT notification for the Measures for the Environmental Management Registration of New Chemical Substances (Revised Draft for Public Comment), incorporating it into the WTO Technical Barriers to Trade (TBT) notification procedure. Based on the comparison of public information, the content of the Measures submitted for WTO notification is consistent with that of the Measures (Revised Draft for Public Comment) released on June 11. From a compliance perspective, CIRS suggests that companies should prepare for the implementation of the Measures in advance, so as to reduce the uncertainty brought by the subsequent system transition.  

According to the latest WTO public documents, China has submitted a TBT notification for the Measures for the Environmental Management Registration of New Chemical Substances (Revised Draft for Public Comment) (hereinafter referred to as the "Measures (Revised Draft for Public Comment)"), incorporating it into the WTO Technical Barriers to Trade (TBT) notification procedure. The notification number is G/TBT/N/CHN/1351/Rev.1, and the document date is July 1, 2026. (WTO notification document) 

This means that this round of adjustments to the new chemical substance registration system is regarded as an important technical measure that may affect international trade and cross-border supply chains. Members are required to make transparency disclosures through the WTO mechanism and provide a comment window for other members.

According to the WTO notification, the deadline for comments is August 30, 2026, while the proposed dates for both adoption and entry into force remain to be determined. As the draft is still in the consultation and refinement stage, the final text still has room for adjustment.

Earlier on June 11, 2026, China's Ministry of Ecology and Environment (MEE) published the Measures (Revised Draft for Public Comment) for public comment. Based on the comparison of public information, the content of the Measures (Revised Draft for Public Comment) is consistent with that of the WTO notification. The main revisions in the Measures (Revised Draft for Public Comment) cover:

• Fully aligning with the Ecological Environment Code;
• Significantly increasing the penalties for violations related to new chemical substances;
• Overseas enterprises are no longer eligible to serve as registration applicants;
• Products already managed by other regulations, such as pharmaceuticals, pesticides, and cosmetics, are also being brought within the scope of new chemical substance registration management;
• Adding exemption circumstances for specific uses such as scientific research;
• Adjusting registration types and abolishing record-filing; adjusting post-registration tracking management requirements; and
• Requiring enterprises that have already completed record-filing under the current Measures to apply for and obtain a registration certificate in accordance with the relevant provisions of these Measures by December 31, 2026.

Please click here to view more details about the major changes. 

CIRS Insights

Overall, the Measures for the Environmental Management Registration of New Chemical Substances entering the WTO notification and public comment stage, marks the steady progress of China's reform of the new chemical substance environmental management system. From a compliance preparation perspective, it also means that enterprises need to shift from "following the revision draft" to "preparing for the implementation of the rules" as soon as possible. Before the final regulatory text is issued, relevant enterprises should focus on the international comment deadline, the subsequent official release date, and transitional policy arrangements, and carry out in advance tonnage structure review, registration pathway reassessment, supply chain responsibility allocation, and internal compliance system upgrades, so as to reduce the uncertainty brought by the subsequent system transition.

This revision comes at a time when the Ecological Environment Code of the People's Republic of China is set to take effect on August 15, 2026. The revised Measures for the Environmental Management Registration of New Chemical Substances are intended to be implemented in connection with the Ecological Environment Code. The timeline is quite tight, and relevant industries need to pay close attention.

CIRS Group will continue to monitor the revision of relevant regulatory documents, provide professional regulatory interpretations for clients, and offer China new chemical substance compliance consulting and optimal solutions.

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

Our Services

• China new chemical substance registration (Typical registration, Simplified registration, Record);
• Only Representative (OR);
• IECSC Enquiry and Inventory Adding;
• Chemical Safety Report (CSR) Compilation;
• Testing Coordination/Supervision;
• Alternative methods (QSAR, Read-Across, In-vitro, Waiver, Evaluation);
• Post-registration (Annual Report, Certificate Renew)
• China REACH Training Service;

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.