News Details

The Ministry of Ecology and Environment (MEE) appears to have begun implementing restrictions on overseas enterprises acting as applicants for new chemical substance registrations, despite the relevant revision to MEE Order No. 12 not yet having been formally adopted.

This change was proposed in the Draft Revision of the Measures for Environmental Management Registration of New Chemical Substances, which was published by the MEE for public consultation on 11 June 2026. According to Article 10 of the draft, applicants must be enterprises or public institutions that are legally established in China and are engaged in the manufacture or import of new chemical substances.

Although the MEE has not published an official announcement confirming the implementation of the applicant restriction, reports from affected companies indicate that overseas enterprises are no longer being accepted as registration applicants in practice.
 

Overseas Enterprises Would No Longer Act as Registration Applicants

Under Article 10 of the draft, the applicant must be an enterprise or public institution legally established in China that is engaged in the production or import of new chemical substances.

Key change:

• Domestic manufacturers and importers in China are eligible to submit new chemical substance registration applications.
• Overseas manufacturers and trading companies are no longer being accepted as registration applicants in practice.
• The previous mechanism allowing overseas enterprises to apply through a domestic agent therefore appears to no longer be available.

This represents a significant change from the existing applicant framework, requiring overseas companies to coordinate with a Chinese importer or other eligible domestic entity for future registrations.