Guidance on Applying for an Extension of Chemical Substance Identification Information Disclosure

On August 20, 2025, the Solid Waste and Chemicals Management Center released a Work Notice on Applying for an Extension of Chemical Substance Identification Information Disclosure on its official website. The notice specifies that registration certificate holders requiring an extension must prepare necessary supporting documents and submit their applications to the competent authority by September 15, 2025. To assist relevant enterprises in accurately understanding and complying with the extension application process, CIRS Group has compiled this guidance. The guidance clarifies the confidentiality period for chemical substance identification information listed in the Inventory of Existing Chemical Substances in China (IECSC), outlines the conditions for extension applications, details the preparation of application materials, the operational procedures of the online registration system, and the review standards of the competent authority. It also includes professional recommendations to provide clear guidance for registration certificate holders applying for an extension.

What are the regulations on the confidentiality period and extension applications for the disclosure of identification information of chemical substances listed in the Inventory?

• The Inventory of Existing Chemical Substances in China (2013) (IECSC) contains 45,612 chemical substances, including 3,270 confidential entries. The confidentiality period for the identification information of these confidential substances ends on December 31, 2025, and no extension for disclosure may be applied for.
• Chemical substances produced, imported, sold, or processed in China before October 15, 2003, and applied for inclusion in the IECSC, must fully disclose their identification information. No application for information protection is permitted.
• Chemical substances that obtained normal declaration registration certificates under the former State Environmental Protection Administration’s Order No. 17 were all included in the IECSC by June 18, 2021. For those with protected identification information, the confidentiality period ends on December 31, 2025, and no extension for disclosure may be applied for.
• Chemical substances that obtained regular declaration registration certificates under the former Ministry of Environmental Protection’s Order No. 7 before January 1, 2021, and have conducted initial activities, were included in the IECSC by the competent authority in batches five years after their initial activities. For those approved for confidentiality during registration, they are automatically listed as confidential, with the confidentiality period ending no later than December 31, 2025. Applicants may apply to the competent authority for an extension of information disclosure by September 15, 2025, for a maximum extension of five years.
• Chemical substances that obtained regular declaration registration certificates under the former Ministry of Environmental Protection’s Order No. 7 before January 1, 2021, but have not conducted initial activities, will be included in the IECSC by the competent authority on December 31, 2025. For those approved for confidentiality during registration, applicants may apply to the competent authority for an extension of information disclosure by September 15, 2025, for a maximum extension of five years.
• During the transition period of the new chemical substance environmental management registration regulations from January 1, 2021, to June 30, 2021, chemical substances that obtained regular declaration registration certificates under the former Ministry of Environmental Protection’s Order No. 7 will be included in the IECSC by the competent authority five years after registration (no later than June 30, 2026). For those approved for confidentiality during registration, applicants may apply to the competent authority for an extension of information disclosure by December 31, 2025, for a maximum extension of five years.
• Chemical substances that obtained regular registration certificates under the Ministry of Ecology and Environment’s Order No. 12 will be included in the IECSC by the competent authority five years after the initial registration date. For those approved for confidentiality during registration, applicants may apply to the competent authority for an extension of information disclosure six months before the confidentiality expiration date, for a maximum extension of five years.
• Chemical substances for which registration certificate holders voluntarily cancel regular registration certificates will still be included in the IECSC by the competent authority five years after the initial registration date. However, chemical substances whose regular registration is withdrawn or revoked by the competent authority in accordance with the law will not be included in the IECSC.
• Chemical substances that obtained simplified declaration registration certificates and scientific research filings under the former Ministry of Environmental Protection’s Order No. 7, as well as those that obtained simplified registration certificates and filings under the Ministry of Ecology and Environment’s Order No. 12, are not included in the IECSC.
• For new chemical substances, if no application for chemical substance identification information protection was made during registration or if the application was not approved, no extension for chemical substance identification information disclosure may be applied for.

How should application materials for an extension of chemical substance identification information disclosure be prepared?

• Prepare basic applicant information, including the registration certificate number (including the certificate), the names of the applicant and agent, contact details of the liaison, and the name of the signatory. If the signatory is not the legal representative, a power of attorney from the legal representative must also be prepared.
• Assess the basic situation of the applied substance, including whether it is a high-hazard chemical substance and whether it poses significant potential environmental or health risks, where delayed disclosure could significantly impact public health or environmental interests.
• Review the applicant’s information protection status, explaining whether chemical substance identification information (e.g., chemical name) was applied for protection during registration and whether protection was granted.
• Prepare necessary supporting documents for the extension of information disclosure, including:

• The specific identification information fields for which extension is requested (e.g., Chinese/English chemical name, CAS number, molecular weight, molecular formula, structural formula, SMILES code) and the requested extension period;
• Documentation indicating whether the identification information for which extension is requested is publicly known, such as whether the public or competitors could access this information through public sources or associate it with the applicant, and whether the information has been disclosed by domestic or foreign authorities;
• An explanation of the commercial value of the identification information for which extension is requested, preferably with supporting evidence;
• Details of the continuous preventive measures taken by the applicant to protect this chemical identification information;
• The necessity statement must be signed and sealed and submitted as an attachment.

Operational procedures for submitting an extension application for information disclosure via the new chemical substance online registration system

• First, log in to the Ministry of Ecology and Environment’s online service hall (https://www.mee.gov.cn/) and enter the new chemical substance online registration system. Under the regular registration section, find the Application Form for Extension of Chemical Substance Identification Information Disclosure.
• After entering the application form, fill in each item step by step and upload relevant attachments, including the registration certificate and the necessity statement for information protection. Fields marked with an asterisk (*) are mandatory. It is recommended to save the form periodically during filling.
• After completing all sections of the application form, preview it to ensure accuracy before printing. Note that the form cannot be edited after printing. After printing, have the signatory sign and affix the company seal, then upload a color-scanned copy (PDF file) of the completed form to the registration system. Click "Submit" to complete the application.
• After submission, applicants can view all submitted application records and review progress under History in the registration system.

Competent authority’s review decision on extension applications for information disclosure

• Applications for extension of information disclosure will not be approved under the following circumstances:

• There are multiple registration certificate holders for the chemical substance, and one or more have not submitted an extension application on time;
• The necessity statement for extension is deemed insufficient upon review;
• The substance is a high-hazard chemical substance or poses significant potential environmental or health risks, and delayed disclosure could significantly impact public health or environmental interests.

• If all registration certificate holders of the chemical substance submit extension applications on time, the necessity statement is deemed sufficient and reasonable upon review, and the substance does not fall under item (3) above, the extension will be approved.

CIRS Group’s recommendations on submitting extension application materials

First, CIRS Group can help you quickly assess which chemical substances require extension application materials by answering the following questions:

• Has your company obtained a regular declaration registration certificate under the former Ministry of Environmental Protection’s Order No. 7?

If not, your company does not need to submit an extension application for substance identification information disclosure. If yes, proceed to the next question.

• Was your company’s chemical substance approved for identification information confidentiality during the regular declaration under Order No. 7?

If not, your company does not need to submit an extension application. If yes, proceed to the next question.

• Does your company wish to continue keeping the substance’s identification information confidential in the Inventory after December 31, 2025?

If not, your company does not need to submit an extension application. If yes, your company must actively prepare application materials for extending information disclosure and submit the application via the new chemical substance registration system by September 15, 2025.

Second, what aspects should your company pay special attention to when preparing application materials for extending substance identification information disclosure?

• Accurately assess the hazards of the applied substance. If the chemical substance is determined to be a high-hazard substance under Order No. 12, or if it has significant health or environmental hazards and is likely to be frequently exposed to humans or the environment, the extension application will not be approved.
• Verify whether the chemical substance identification information can be obtained through public channels. Public channels include published literature, patents, databases, search engines, and official inventories or public materials. If the identification information can be retrieved through public channels, it is unlikely to be approved for continued confidentiality based on experience.
• Collect sufficient and reasonable evidence of the commercial value of the chemical substance identification information. This includes, but is not limited to: Whether the applicant exclusively developed the substance and holds exclusive patents; Whether the substance has significant technological advantages in its application field, with substantial market potential and economic benefits; The importance of the substance in maintaining the company’s high market share, leading industry position, and competitive advantage; The potential losses and their extent if competitors obtain the identification information. It is recommended to monetize or quantify the commercial value as much as possible and provide supporting evidence.

Finally, it is worth noting that the requirements for extension application materials are largely consistent with those for information protection applications during new substance registration. However, since the implementation of the Ministry of Ecology and Environment’s Order No. 12 on January 1, 2021, the competent authority has been very strict in reviewing chemical substance identification information protection applications. Only about 10% of new substances under regular and simplified registration have been approved for information protection. Here, CIRS Group recommends that if your company needs to apply for an extension of chemical substance identification information disclosure, ensure that the application materials are prepared diligently in accordance with the requirements, with a fully reasoned necessity statement and clear evidence.