According to the latest WTO public documents, China has submitted a TBT notification for 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)"), incorporating it into the WTO Technical Barriers to Trade (TBT) notification procedure. The notification number is G/TBT/N/CHN/1351/Rev.1, and the document date is July 1, 2026. (WTO notification document: https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-DP.aspx?language=E&CatalogueIdList=326817,326764,326757,326629,326637,326635,326636,326638,326639,326614&CurrentCatalogueIdIndex=4&FullTextHash=&HasEnglishRecord=True&HasFrenchRecord=True&HasSpanishRecord=True)
This means that this round of adjustments to the new chemical substance registration system is regarded as an important technical measure that may affect international trade and cross-border supply chains. Members are required to make transparency disclosures through the WTO mechanism and provide a comment window for other members.
The WTO notification shows that the deadline for international comments is August 30, 2026, while the proposed date of adoption and the proposed date of entry into force are currently to be determined. The revision of the Measures remains at the stage of soliciting comments and refining the rules, and the final text still has room for adjustment.
Based on the comparison of public information, the content of the Measures (Revised Draft for Public Comment) released by the Ministry of Ecology and Environment on June 11, 2026 is consistent with the revised content of this WTO notification. The main revisions in the Measures (Revised Draft for Public Comment) include: comprehensively aligning with the Ecological Environment Code; significantly increasing the penalties for violations related to new chemical substances; overseas enterprises no longer being eligible to serve as registration applicants; products already managed by other regulations, such as pharmaceuticals, pesticides, and cosmetics, also being brought within the scope of new chemical substance registration management; adding exemption circumstances for specific uses such as scientific research; adjusting registration types and abolishing record-filing; adjusting post-registration tracking management requirements; and requiring those who have already completed record-filing under the current Measures to apply for and obtain a registration certificate in accordance with the relevant provisions of these Measures by December 31, 2026. (For an expert interpretation of the revised content, please see the CIRS Group official website: https://www.cirs-group.com/cn/chemicals/sheng-tai-huan-jing-fa-dian-luo-di-zhi-ji-xin-hua-xue-wu-zhi-deng-ji-zhi-du-ying-lai-zhong-gou-shi-xiu-ding)
ChemRadar Insights
Overall, the revision of the Measures for the Environmental Management Registration of New Chemical Substances has entered the WTO notification and public comment stage, marking the steady progress of China's reform of the new chemical substance environmental management system. From a compliance preparation perspective, it also means that enterprises need to shift from "following the revision draft" to "preparing for the implementation of the rules" as soon as possible. Before the final regulatory text is issued, relevant enterprises should focus on the international comment deadline, the subsequent official release date, and transitional policy arrangements, and carry out in advance tonnage structure review, registration pathway reassessment, supply chain responsibility allocation, and internal compliance system upgrades, so as to reduce the uncertainty brought by the subsequent system transition.
This revision comes at a time when the Ecological Environment Code of the People's Republic of China is set to take effect on August 15, 2026. The revised Measures for the Environmental Management Registration of New Chemical Substances are intended to be implemented in connection with the Ecological Environment Code. The timeline is quite tight, and relevant industries need to pay close attention. CIRS Group will continue to monitor the revision of relevant regulatory documents, provide professional regulatory interpretations for clients, and offer China new chemical substance compliance consulting and optimal solutions.
ChemRadar Service
- China's new chemical substance regulatory consulting and training services
- Quality compliance solution design for China's new chemical substance regulations
- China's new chemical substance inventory checking (against the IECSC)
- China's new chemical substance registration (record-filing, simplified registration, regular registration)
- Laboratory commissioning and testing coordination
- Non-testing method data assessment services (QSAR, read-across, WoE)
- New chemical substance risk assessment report preparation
- Application for addition to the Inventory of Existing Chemical Substances in China (IECSC)
- Registration agent and registration certificate management
- Socio-economic analysis (SEA) report
- Carcinogenicity assessment
