▪︎ GHS
China Is Abolishing the Notification Procedure: New Registration Requirements for New Chemical Substances Effective August 2026
With the revision and entry into force of the Chinese Environmental Protection Law on August 15, 2026, China has fundamentally changed the requirements for certain new chemical substances. This affects substances that could previously be reported via a “Record Notification” for quantities of less than one metric ton per year. These substances are now subject to a registration requirement. This also applies to polymers, for which a notification was previously sufficient under certain conditions. At the same time, foreign companies are no longer permitted to act as applicants themselves.
Expanded Requirements Under the Registration Procedure
For new substances and polymers that previously qualified for the notification procedure, the requirements of the simplified registration process will now apply. In China, new chemical substances are generally defined as substances that are not listed in the Inventory of Existing Chemical Substances in China (IECSC). Companies must provide additional information on the intended use of the substance, as well as available data on its physicochemical properties and potential environmental and human health hazards. Furthermore, a justification must be submitted if certain information is requested to be treated as confidential. For many companies, this will result in a greater documentation burden and more extensive preparation prior to the manufacture or import of a substance.
Applications Can Only Be Submitted by Chinese Entities
Another significant change concerns applicant eligibility. Since August 15, 2026, the Chinese authorities no longer accept registration applications from companies established outside China. For imported substances, only China-based importers or other eligible local entities may act as applicants. Foreign manufacturers should therefore review their import and compliance strategies and determine now which Chinese business partner will assume the role of applicant. At the same time, responsibilities for providing substance data, use information, and confidential business information should be clearly defined.
Act Early to Secure Market Access
The new requirements call for careful preparation by affected companies. Businesses exporting new chemical substances to China or having them manufactured there should review their existing processes and assess the potential impact on ongoing and planned projects now. In particular, the appointment of a suitable Chinese applicant and the preparation of the required registration documentation should be addressed in good time to avoid delays in market access. We support companies in evaluating their China registration obligations, developing appropriate registration strategies, and coordinating with local partners. With our regulatory expertise, we help businesses implement new requirements efficiently and minimize compliance risks throughout the supply chain.
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