On July 20, 2026, Taiwan's Ministry of Environment (MOE) pre-announced the addition of six substances — Toluidine Red, Para Red, Bisphenol B, Bisphenol F, 2-methyl-4-(methylthio)-2-morpholinopropiophenone (MMMP), and gamma-butyrolactone (GBL) — as concerned chemical substances. According to their characteristics, the five operations of manufacture, import, sale, use, and storage will be subject to tiered management based on control concentrations. From the official announcement date, sales on online and other platforms that cannot identify the parties to a transaction will be prohibited, with violations subject to fines of up to NTD 300,000. Affected businesses are also granted a one-and-a-half-year transition period to apply for approval documents and complete labeling.
Background and Listed Substances
The six substances pre-announced fall into two categories of concerned chemical substances based on their characteristics and potential risks.
- Toluidine Red and Para Red are substances notified under the European Union's Rapid Alert System for Food and Feed (RASFF) and pose a potential food safety risk of entering the food supply chain. They are therefore added as concerned chemical substances in the “food safety risk concern” category to enable source control.
- Bisphenol B has already been included on the EU's Substance of Very High Concern (SVHC) list, and Bisphenol F may have endocrine-disrupting properties. As such substances can be used in consumer products, Bisphenol B and Bisphenol F are added as concerned chemical substances in the “livelihood issues” category, in order to track source flows and prevent substitution among structurally similar substances.
- MMMP and GBL are brought into concerned chemical substance management pursuant to a directive of Taiwan's Executive Yuan, balancing the needs of legitimate uses while guarding against misuse; they are likewise placed in the “livelihood issues” category.
Tiered Control Requirements by Category
The six substances are assigned different control concentrations by category, with operational management requirements applying in tiers according to concentration thresholds, as detailed in the table below.
|
Substance |
Category and Operational Management Requirements |
|
Toluidine Red, Para Red |
“Food safety risk concern” category; control concentration 30%; obtain approval before operation, report operational records monthly, label and prepare SDS; containers and packaging must bear the Chinese wording “Not for use in food and feed.” |
|
Bisphenol B, Bisphenol F |
“Livelihood issues” category; control concentration 1%; obtain approval before operation, report operational records monthly, label and prepare SDS. |
|
MMMP |
“Livelihood issues” category; control concentration 90%; obtain approval before operation, report operational records monthly, label and prepare SDS; containers and packaging must bear the Chinese wording “For industrial use only.” |
|
GBL |
“Livelihood issues” category, tiered management, control concentration 20%. Operations at 20% or above but below 90%: comply with labeling and SDS requirements under the Regulations for the Labeling and Safety Data Sheets for Toxic and Concerned Chemical Substances, and containers and packaging must bear the Chinese wording “For industrial use only”; other operations are not regulated under the Toxic and Concerned Chemical Substances Control Act. Operations at 90% or above: obtain approval before operation, report operational records monthly, label and prepare SDS, and containers and packaging must bear the Chinese wording “For industrial use only.” |
Online Sales Ban and Penalties
The MOE emphasized that, once the six substances are officially designated as concerned chemical substances, sales on online and other platforms that cannot identify the parties to a transaction will be prohibited immediately. Violations may incur a maximum fine of NTD 300,000; where a violation causes death or harm to human health, the offender may be sentenced to life imprisonment or to imprisonment of seven years or more.
Transition Period Arrangements
Taking into account current usage in Taiwan, China, the MOE grants existing operators a transition period for approval applications and container/packaging labeling. In addition to maintaining operational records and submitting periodic reports from the official announcement date, operators must obtain the required approval documents and complete container/packaging labeling within 1.5 years of the announcement date.
Public Consultation
Stakeholders may, within 60 days from the day following publication of the pre-announcement, submit comments or revision suggestions to the MOE for legislative reference (Email: zhijun.jian@moenv.gov.tw). Pre-announcement materials will be available for download from Taiwan's Executive Yuan Gazette Information Network three days after the pre-announcement date.
ChemRadar Insights
The addition of the above six substances as concerned chemical substances remains at the pre-announcement stage; the official announcement date and the final controlled concentrations and substance list shall be subject to the MOE's subsequent official announcement. Companies handling any of these substances in Taiwan, China are advised to note the following compliance points:
- Verify the substance list and category: Confirm whether the substances you handle fall within the six newly added concerned chemical substances, identify their category (“food safety risk concern” or “livelihood issues”), and the corresponding control concentration thresholds.
- Understand the control concentration thresholds: Control concentrations vary widely — Bisphenol B/F as low as 1%, Toluidine Red/Para Red at 30%, MMMP at 90%, and GBL tiered at 20%/90%. Use these to determine whether your operations reach a control threshold and which management requirements apply.
- Complete container/packaging labeling: Toluidine Red and Para Red must carry “Not for use in food and feed,” and MMMP and GBL at 20% or above must carry “For industrial use only.” Relevant businesses should complete labeling rectification and prepare SDS within the transition period.
- Use the transition period for approvals: Relevant businesses should apply for approval documents and complete container/packaging labeling within one and a half years of the official announcement date, and start keeping operational records and submitting periodic reports from the announcement date, so as to avoid overdue violations.
- Adjust sales channels: Once the substances are officially announced, sales via online and other platforms that cannot identify the parties to a transaction will be prohibited. Relevant sellers should adjust their sales channels promptly; violations may incur fines of up to NTD 300,000.
