An Introduction to China REACH

China’s Ministry of Ecology and Environment (MEE) is seeking public feedback on draft indicative lists of long-chain perfluorocarboxylic acids (PFCAs), their salts, and related compounds. These substances are widely used in industrial applications, such as the production of non-stick cookware, stain-resistant fabrics, and firefighting foams. They are known for their environmental persistence, bioaccumulation potential, and suspected adverse health effects.

The proposed lists were developed in cooperation with the Stockholm Convention Secretariat and are part of China’s efforts to implement control measures for persistent organic pollutants (POPs) under the Convention.

Draft Chemical Lists Linked to the Stockholm Convention

The MEE has prepared a draft list of these long-chain PFCAs and related substances. The list is part of the MEE’s work under the Stockholm Convention on Persistent Organic Pollutants, to which China has been a party since 2004. This international agreement aims to eliminate or restrict the production and use of harmful chemicals. The government is encouraging businesses and experts to provide feedback on the draft list before 19 May 2025.

Potential Impact on Industry

If these chemicals are added to China’s control list, manufacturers may need to adapt their processes. This could affect how companies source materials or produce goods that rely on these chemicals.

What Companies Should Do

• Check whether their products use these chemicals, especially C9–C21 PFCAs.

• Review how the proposed rules might affect them.

• Send written feedback to the Environmental Convention Implementation Centre.

• Visit the official MEE website here for full details.

The Lists in the Consultation Include:

1. An indicative list of long-chain perfluorocarboxylic acids (PFCAs), their salts and related compounds.

2. A updated list of perfluorooctanoic acid (PFOA) its salts and related compounds.

3. A updated list of perfluorohexane sulfonic acid (PFHxS), its salts and related compounds.

Next Steps for Companies

Stakeholders are encouraged to provide input early on. Early participation may help shape the final rules, request exceptions, or suggest a longer transition periods. Companies should also monitor updates from the upcoming global meeting of the Conference of the Parties to the Stockholm Convention, scheduled for late April to early May 2025.

The Standing Committee of the 14th National People's Congress (NPC) has reviewed the draft Hazardous Chemicals Safety Law of the People's Republic of China. To encourage public participation in the legislative process, a public consultation on the draft law was launched on December 26, 2024.

The Draft Hazardous Chemicals Safety Law establishes a comprehensive regulatory framework covering the planning and design of hazardous chemicals, as well as safety in production, storage, use, business operations, and transportation. It also outlines registration requirements for hazardous chemicals, emergency response measures, and legal responsibilities.

Key Provisions of the Draft Law

• Mandatory Training: Employees in hazardous chemical units must undergo education and training and pass an assessment before starting work.

• Lifecycle Management: Hazardous chemicals must be electronically tracked and monitored electronically throughout their lifecycle using identification and information management systems.

• Safety Data Sheets (SDS) & Labeling: Manufacturers and importers of hazardous chemicals are required to provide SDS and labels for their products, with penalties for non-compliance.

• Exemptions for R&D and Small-Scale Use: Hazardous chemicals in small low quantities, minimal release, and limited exposure during research, trial production, and market trials are exempt from registration.

• Prohibited Activities: No entity or individual may carry out activities involving chemicals whose hazardous properties have not been determined.

Public Consultation and Feedback

The draft law is available for public review on the NPC official website and the National Database of Laws and Regulations. The public can submit feedback online or by mail to the Legislative Affairs Commission of the NPC Standing Committee at No. 1 Qianmen West Street, Xicheng District, Beijing, 100805. Submissions should be clearly marked as relating to the “Draft Hazardous Chemicals Safety Law Consultation.”

The consultation period will last 30 days, offering stakeholders across industries, regulatory bodies, and the general public an opportunity to shape the future of hazardous chemical safety regulation in China.

For official details and to submit feedback, please visit the NPC official website.