On December 25, 2025, to implement the Action Plan for the Management of New Pollutants, the Ministry of Ecology and Environment of China, together with the National Disease Control and Prevention Administration, officially released the Priority Controlled Substances List (Third Batch) (Announcement No. 43 of 2025). This batch includes 23 types of chemicals. Their production and use primarily involve industries such as petrochemicals, plastics, rubber, pharmaceuticals, textiles, dyes, coatings, pesticides, leather, and electroplating.
The Priority Controlled Substances List focuses on chemicals that pose significant environmental and health hazards, may persist in the environment long-term, and present unreasonable risks to ecosystems or human health. Selection is primarily based on factors including environmental behavior characteristics (persistence, bioaccumulation), environmental and health hazard attributes (aquatic toxicity, carcinogenicity, mutagenicity, reproductive toxicity, endocrine-disrupting properties, specific target organ toxicity from repeated exposure, etc.), and environmental exposure scenarios (domestic production/usage volume, application distribution, public exposure frequency).
The previous two batches of the list collectively included 40 types of chemicals, covering various human carcinogens, persistent organic pollutants, and heavy metal substances, involving sectors such as chemical manufacturing, light industry, plastics, rubber, and pharmaceuticals.
For substances listed in the Priority Controlled Substances List (Third Batch), environmental risk control measures should be implemented targeting key stages where environmental and health risks arise, considering economic and technical feasibility, to minimize the impact of their production and use on human health and the environment.
Specific Management Requirements for Listed Substances
- Environmental Impact Assessment (EIA) documents must clearly specify the quantity, type, and purpose of the production or use of such chemicals. For processes involving chemical reactions, the migration and transformation 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.
- The proportion of Priority Controlled Substances and their content in raw and auxiliary materials must be reported based on design values or the actual production values from the previous year.
- Key entities constructing production equipment, storage tanks, or pipelines involving Priority Controlled Substances, or facilities with soil contamination risks such as wastewater treatment ponds and emergency ponds, must design, construct, and install anti-corrosion and leak-prevention facilities, along with leak detection devices, to prevent soil and groundwater contamination by such chemicals.
- Key entities planning to dismantle production facilities, structures, or pollution control equipment involving such chemicals must formulate a pollution prevention plan for the demolition activities in advance and submit it for filing to the local county-level ecology and environment, and industry and information technology authorities at least fifteen working days before commencement.
Enterprises handling Priority Controlled Substances must immediately conduct self-inspections against the new regulations. They are required to establish more refined chemical substance tracking and reporting mechanisms in project EIAs, pollutant discharge permit applications, and daily operations. Some enterprises may also need to upgrade environmental protection facilities to meet the new requirements for leak prevention, monitoring, and related infrastructure. As the list continues to be updated and controls become stricter, traditional production processes reliant on high-risk chemicals will face declining competitiveness. Enterprises are advised to increase R&D investment, seek and adopt safer, more environmentally friendly alternatives and technologies, thereby reducing compliance risks and achieving sustainable development.
Further Information
