On August 4, 2026, the Ministry of Ecology and Environment (MEE) issued the Announcement on Supplementing and Modifying the Inventory of Existing Chemical Substances in China (IECSC) (Announcement No. 40 of 2026), adding 486 qualifying chemical substances to the Inventory. The Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No. 12) are currently under revision, which makes this large-scale supplementation of chemical substances into the Inventory particularly significant.
Attachment 1 of the announcement contains 4 chemical substances, all of which had been produced, sold, processed, used, or imported in China before the implementation of the new chemical substance environmental management registration system (before October 15, 2003). According to the announcement, these 4 substances are the "2025 Batch 2 (Total Batch 14) chemical substances proposed for supplementation into the Inventory of Existing Chemical Substances in China" that were publicized on August 11, 2025. Their identification information is fully public, and no permitted or new-use environmental management scope has been set.
Attachment 2 of the announcement contains 482 chemical substances, all of which are new chemical substances that obtained regular registration certificates under the Measures for the Environmental Management of New Chemical Substances (former Ministry of Environmental Protection Order No. 7). They have been proactively listed in the Inventory by the competent authority after five full years from the implementation date of the Measures for the Environmental Management Registration of New Chemical Substances (Order No. 12). With this supplementation, all new chemical substances that obtained regular registration certificates under Order No. 7 have now been included in the Inventory.
Companies should pay special attention to the fact that, among the 482 substances supplemented this time that obtained regular registration under Order No. 7, 40% have been assigned a permitted use / new use environmental management scope. If a company plans to use such substances for other industrial uses beyond the permitted uses, it must obtain a new chemical substance registration certificate for the intended use.
To help companies better understand the content of this Inventory supplementation, focus on its potential impact on their chemical-related activities, and prepare response strategies, CIRS Group has conducted a dedicated analysis of the 482 substances supplemented in this batch that obtained regular registration under Order No. 7.
I. Overall Statistical Analysis of the 482 Substances by Category
According to the statistics, 88.2% of the substances supplemented in this batch have publicly disclosed identification information, of which 77% carry CAS numbers, indicating a relatively high level of Inventory transparency. This makes it easier for companies to determine whether the chemical substances they produce or import have already been included in the Inventory. Confidential substances are concentrated among organic substances (49 of the 57 confidential substances are organic) and polymers (8). Among the 111 substances without CAS numbers, 54 are non-confidential; these substances still appear in the form of "no CAS number" under their public chemical names, mainly corresponding to complex reaction products, polymers, and naturally modified derivatives that are difficult to uniquely identify under the current CAS nomenclature system. All 57 confidential substances are identified by "serial numbers" instead of CAS numbers.
By substance type, there are 449 organic substances, accounting for 93.2% of the total; 18 inorganic substances, 3.7%; and 15 polymers, 3.1%. The 15 polymers are concentrated in the fields of functional polymers and specialty materials, such as the sodium salt of the hydrolyzate of an acrylic ester-vinyl acetate copolymer, and the reaction product of dimethylaminopropyl methyl siloxane with cadmium zinc sulfide selenide. The 18 inorganic substances are mainly multi-component metal oxides, fluorides, and coordination compounds (e.g., potassium fluorozincate, sodium pentaborate, hydrochloric acid solution of (SP-4-1)-tetrachloropalladic(II) acid, and aluminum cobalt lithium nickel oxide), reflecting downstream applications in high-end electronic materials, catalysts, and battery precursors.
Special attention should be paid to the 290 substances whose "new use environmental management scope" is blank. After being included in the Inventory this time, they are regarded as existing chemical substances, and companies may freely use them for any industrial use. However, for substances whose new use environmental management scope is specified as "other industrial uses beyond permitted uses," a company need not conduct a new chemical substance registration only when its use is consistent with the permitted uses; otherwise, it must first obtain a registration certificate for the intended use before it may commence production or import. Most notably, 63 substances have a new use environmental management scope of "all industrial uses," meaning that any company producing or importing such a substance for any industrial use must first conduct a new chemical substance registration and obtain a registration certificate. For substances with a scope of "all industrial uses," it is expected that, before supplementing them into the Inventory, the competent authority re-evaluates the submitted registration materials and hazard data and determines that the corresponding substances fall under the "high-hazard category." Under Order No. 12, for high-hazard chemical substances included in the Inventory, when a registration certificate holder changes the use, or when any person other than the holder uses the substance for industrial purposes, an application for new use environmental management registration must be filed before production, import, or processing use.
|
Statistical Item |
Quantity |
Percentage |
|
I. Total substances |
482 |
— |
|
Confidential (identified only by generic name/serial number) |
57 |
11.8% |
|
Non-confidential (identification info public) |
425 |
88.2% |
|
II. CAS number identification |
— |
— |
|
With CAS number |
371 |
77% |
|
Without CAS number |
111 |
23% |
|
of which confidential (serial number only) |
57 |
11.8% |
|
of which non-confidential (serial number only) |
54 |
11.2% |
|
III. New use environmental management scope |
— |
— |
|
Not subject to new use management |
290 |
60.2% |
|
All industrial uses |
63 |
13.1% |
|
Other industrial uses beyond permitted uses |
129 |
26.7% |
|
IV. Substance category |
— |
— |
|
Organic substances |
449 |
93.2% |
|
Inorganic substances |
18 |
3.7% |
|
Polymers |
15 |
3.1% |
II. Overview and Compliance Impact of This Batch
Figure: Distribution of Key Compliance Characteristics of the 482 New Chemical Substances (Overview)
The figure above provides an at-a-glance view of the key compliance characteristics of this batch: all 482 new chemical substances have completed the transition from "regular registration obtained" to "IECSC-listed," of which about one quarter lack CAS numbers, nearly 40% are subject to new use environmental management, and about 12% are confidential.
For companies that produce, import, or process/use new chemical substances, this Inventory supplementation announcement means:
(1) The window for switching a substance's "new/existing" status has closed: From the date of issuance of this announcement, the substances it covers have switched from "new chemical substances" to "existing chemical substances in China." Relevant companies no longer need to invest in "new chemical substance registration." However, for those subject to new use restrictions, companies must still confirm the boundaries of their use and register new uses as required; otherwise, they may still violate the new chemical substance environmental management regulations.
(2) For confidential substances, proactive confirmation is still required: Confidentiality in the Inventory only means that the way a substance's identity is disclosed is restricted (presented as a generic name/serial number); the competent authority still holds its complete identification information. Companies that cannot confirm whether their chemical substance has been included in the Inventory should proactively entrust a query with the competent authority to confirm whether their substance constitutes a new chemical substance.
III. Practical Compliance Advice for Companies
In light of this batch of Inventory supplementation, the current regulatory requirements under MEE Order No. 12, and the ongoing revision of the Measures, companies are advised to focus on the following two points:
1. Immediately compare material lists. Companies should compare the list of substances supplemented in this batch of the Inventory against their own raw material/product lists to identify the 482 newly added substances — especially the 192 substances subject to new use environmental management — establish a "use compliance list," and have procurement, EHS, and compliance jointly confirm that no use occurs outside the restricted scope.
2. Distinguish between "the transition from new to existing chemical substance" and "new use environmental management." Inclusion in the IECSC does not lift all obligations. Under the Inventory of Existing Chemical Substances in China, chemical substances subject to new use environmental management that are used for other industrial uses beyond permitted uses shall be subject to environmental management as new chemical substances.
IV. Conclusion
With the Ecological Environment Code about to take effect, future penalties for new chemical substance-related violations will be aligned with the Code. For companies that produce or import new chemical substances without obtaining a registration certificate or without complying with the requirements of their registration certificate, or that use new chemical substances for which no registration certificate has been obtained, fines will rise significantly — with the maximum fine reaching two million yuan. Escalating penalties for refusal to correct are even heavier and, depending on the severity, may include restrictions on production, suspension of operations for rectification, and even revocation of the business license or closure.
The revision of the new chemical substance registration management regulations is expected to be advanced and implemented rapidly; companies involved in new substance registration are advised to pay close attention. CIRS Group will continue to monitor the revision of relevant regulatory documents, provide clients with professional regulatory interpretation, and offer China new chemical substance compliance consulting and optimal solutions.
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