China Releases Third Batch of Priority Controlled Substances, 24 High-Risk Substances Subject to Enhanced Regulation

On November 19, 2025, China's Ministry of Ecology and Environment (MEE) and the National Disease Control and Administration published a joint announcement introducing the China Inventory of Priority Controlled Substances (Third Batch) (Draft for Comments). This update is part of the ongoing implementation of the Action Plan for the Control of New Pollutants (No. 15 [2022], which requires the dynamic expansion of the national list of priority controlled substances. Building on recent progress in environmental risk screening and assessment of new pollutants, the two departments have compiled a new draft list and are now seeking public input.

All institutions, organizations, enterprises, and individuals are welcome to submit feedback. Written comments should be sent to the MEE, with electronic copies emailed to the designated contact email. The consultation period ends on December 2, 2025.

China Inventory of Priority Controlled Substances (Third Batch) (Draft for Comments)

This batch includes 24 types of chemical substances. The production and use of these chemicals primarily involve sectors such as petrochemicals, plastics, rubber, pharmaceuticals, textiles, dyes, coatings, pesticides, leather, and electroplating.

The latest screening and assessment targeted high-hazard chemicals with a focus on substances that exhibit one or more of the following characteristics:

• Persistence,
• Bioaccumulation,
• Chronic aquatic toxicity – Category 1,
• Carcinogenicity – Category 1 or 2,
• Mutagenicity – Category 1 or 2,
• Reproductive toxicity – Category 1 or 2,
• Specific target organ toxicity (repeated exposure) – Category 1, and
• endocrine disruption.

The review also prioritised chemicals already under strict domestic control, including those regulated through industrial policies and import-export measures, as well as substances covered by major international environmental conventions.

The previous two batches of the Inventory collectively included 40 types of chemical substances, covering various human carcinogens, persistent organic pollutants, and heavy metals, involving industries such as chemical engineering, light industry, plastics, rubber, and pharmaceuticals.

The Inventory prioritizes control of chemical substances that pose significant environmental and health hazards, may persist long-term in the environment, and present unreasonable risks to ecological environments or human health.

Based on these principles, high environmental risk substances are identified through systematic environmental risk screening and assessment of chemicals, incorporated into the Inventory, and subject to continuous dynamic updates.

Key Management Requirements for Listed Substances

• Pursuant to the Guidance on Strengthening Environmental Impact Assessment for Construction Projects Involving New Pollutants in Key Industries, the EIA document must specify the quantity, type, and use of any chemical listed in the Inventory. For processes involving chemical reactions, the transformation and migration of new pollutants in primary and secondary reactions must be analyzed; relevant new pollutants must be included as assessment factors; and the generation and emission of new pollutants at each stage must be accounted for.
• According to the Technical Specification for Application and Issuance of Pollutant Discharge Permits – General Rules, for chemicals listed in the Inventory and their percentage composition in raw or auxiliary materials, the designed value or the actual production value from the previous year must be reported.
• In accordance with the Soil Environmental Management Measures for Industrial and Mining Land (Trial), key units constructing production installations, storage tanks, pipelines, or facilities posing soil pollution risks (e.g., wastewater treatment ponds, emergency ponds) involving listed chemicals must design, construct, and install corrosion prevention, leakage prevention, and leakage detection devices according to national standards and specifications to prevent soil and groundwater contamination.
• Key units dismantling production equipment, structures, or pollution control facilities involving such chemicals must prepare a pollution prevention plan for the demolition activity and submit it to the local competent departments of ecology and environment and industry and information technology at the county level 15 working days prior to commencement.

Enterprises involved with the aforementioned 24 types of chemical substances need to immediately conduct self-assessments against the new rules. They must establish more refined chemical tracking and reporting mechanisms for project EIAs, pollutant discharge permit applications, and daily management. Simultaneously, upgrades to environmental protection facilities may be required to meet new requirements for leakage prevention, monitoring, etc.

As the Inventory is continuously updated and controls become stricter, traditional production processes reliant on high-risk chemicals will gradually lose competitiveness. This necessitates increased investment in R&D by enterprises to identify and adopt safer, greener alternatives and technologies, thereby fostering sustainable development.

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Further Information

MEE