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

Nov 25, 2025
China
Priority Management Chemicals
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On November 19, 2025, the General Office of the Ministry of Ecology and Environment and the Comprehensive Department of the National Disease Control and Administration jointly issued an announcement. In implementing the requirements of the Action Plan for the Control of New Pollutants (No. 15 [2022] of the General Office of the State Council) regarding the dynamic development of the Inventory of Priority Controlled Substances, the two departments continuously carried out environmental risk screening and assessment of new pollutants. Based on recent achievements, they organized the compilation of the China Inventory of Priority Controlled Substances (Third Batch) (Draft for Comments) and are now soliciting public feedback.

All institutions, organizations, enterprises, and individuals are invited to submit comments and suggestions. Opinions should be provided in writing to the Ministry of Ecology and Environment, with electronic copies simultaneously sent 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 current screening and assessment focused on chemicals with high hazards such as 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. Particular attention was given to substances already subject to strict controls under relevant domestic industrial and import-export policies, as well as 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. Selection is primarily based on factors including environmental behavior characteristics (e.g., persistence, bioaccumulation), environmental and health hazard attributes (e.g., aquatic toxicity, carcinogenicity, mutagenicity, reproductive toxicity, endocrine disruption, specific target organ toxicity – repeated exposure), and environmental exposure scenarios (e.g., domestic production and usage volume, application patterns, frequency of public contact).

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.

 

Further Information

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