Food and Feed May Face New Chemical Substance Registration with China's MEE

MEE Order 12 – the Measures for the Environmental Management Registration of New Chemical Substances (also known as China REACH) – is undergoing a new round of systematic revisions, including taking products such as pharmaceuticals, pesticides, cosmetics, food, food additives, feed, feed additives, and fertilizers that were already regulated by relevant regulations into the scope of new substances registration.

On June 11, 2026, China's Ministry of Ecology and Environment (MEE) released 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)), soliciting public comments from government agencies, organizations, enterprises, institutions, and individuals. The deadline for public comments is July 12, 2026. Click here to learn the ten most significant changes and their impacts on enterprises.

If the revisions take effect, any food, food additive, feed, or feed additive that is not listed in the Inventory of Existing Chemical Substances in China (IECSC) will be required to undergo new chemical substance registration before it can be produced or imported for market release. This means that food raw materials and food additives may will undergo both the new food registrations with the National Health Commission and new substances registration with the Ministry of Ecology and Environment, while feed raw materials and feed additives will need to undergo new feed raw materials or new feed additives declaration with the Ministry of Agriculture and Rural Affairs and the new substance registration with the Ministry of Ecology and Environment.

According to the current regulation, products such as pharmaceuticals (including active pharmaceutical ingredients), pesticides (including pesticide active ingredients), veterinary drugs (including active pharmaceutical ingredients), cosmetics, food, food additives, feed, feed additives, and fertilizers were not subject to MEE Order 12. This provision was based on the fact that the products involved were already managed by other competent authorities and relevant regulations. However, according to the Measures (Revised Draft for Public Comment), the aforementioned special products will also fall under the management scope of new chemical substance registration, and will no longer be determined solely based on the industry to which the product belongs.

By searching the IECSC, we found that the vast majority of food raw materials, food additives, feed raw materials, and feed additives are NOT listed in the IECSC, including the popular new foods approved over the past two years (D-allulose, steviol glycosides, NAG, etc.) and feed additives (green coffee bean extract (active components are chlorogenic acid and its analogs), sucralose, etc.).

Enterprises can search if their substance is listed in the IECSC by using CIRS’s ChemRadar.

CIRS Group will continue to monitor the amendments to relevant regulatory documents, provide clients with professional regulatory interpretations, and offer compliance consulting and optimal solutions for new chemical substances in China.

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.

The vast majority of members in CIRS Food Business Division have over 10 years of professional experience in food compliance, with more than 80% hold Master’s or Doctoral degrees in food-related disciplines. The CIRS toxicology expert team consists 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 2 European Registered Toxicologists (ERT). CIRS has provided one-stop food compliance services to over 1,000 domestic and international food and related enterprises. Leveraging its technical expertise, diverse resources, and global network, the CIRS Food Business Division offers global food compliance services, including but not limited to:

• Health food registration and filing in China;
• Application for “Three New Foods (new food additives, new food raw materials and new food-related products” in China;
• U.S. GRAS, NDI, and CAP notifications;
• EU Novel Food, food additives, and food enzymes applications; and
• Application for new feed ingredients and feed additives in China, the U.S., and the EU.

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

Free Webinar

To help enterprises better cope with the new regulations, CIRS is to host a free webinar on Tuesday, June 30, 2026, at 14:00 – 15:00 pm (GMT+1). In this webinar, we will analyze the legislative background of the Ecological and Environmental Code alongside the key proposed changes in the draft revised measures. The session will provide a structured overview of the regulatory logic behind the reform, highlight the principal compliance risks and response priorities for businesses, and offer practical guidance on how companies can identify regulatory impacts early, optimize registration and supply chain compliance strategies, and prepare for the transition through internal planning and capability building. Click here to learn more details.