China's Ministry of Ecology and Environment (MEE) will stop accepting record-filings for new chemical substances from August 15, 2026, forcing low-tonnage substances previously cleared by notification onto the simplified registration track. The General Office notice, signed July 31, 2026 and published by the Solid Waste and Chemicals Management Centre (MEESCC) on August 5, 2026, routes former record-filing cases into simplified registration under MEE Order No. 12. The cut-over lands on the same day China's Ecological Environment Code enters into force.
Under the notice, enterprises that previously qualified for record-filing under the Provisions for the Environmental Management of New Chemical Substances (MEE Order No. 12) must, before manufacture or import, submit a new chemical substance environmental management registration application form, evidence meeting the conditions of Article 10, paragraph 3 of the Provisions, and any information they already hold on the substance's environmental and health hazard characteristics and environmental risk. The State Council ecological and environmental authority will accept and approve these submissions following the simplified registration procedure and its statutory time limits. The notice self-supersedes once MEE issues fresh new-chemical-substance registration rules.
Who has to change track, and why now?
The change hits manufacturers and importers introducing substances not listed in the Inventory of Existing Chemical Substances in China (IECSC) at volumes below 1 tonne per year, the band that until now could clear the market via record-filing. From August 15, 2026 that notification route closes: those substances must instead pass simplified registration before first manufacture or import. Foreign exporters into China are affected through their domestic agents, who file on their behalf, and the shift raises the data and timeline bar for low-volume introductions across specialty chemicals, electronics, cosmetics ingredients and downstream supply chains.
The trigger is statutory. The Ecological Environment Code (Presidential Order No. 70, promulgated March 12, 2026) enters into force on August 15, 2026, and Book II, Part IX, Chapter 34 (Articles 648 to 651) elevates chemical-substance pollution-risk management, including pre-market registration of new substances, to statute for the first time. The notice operationalises that codification ahead of the revised Measures aligning MEE Order No. 12 with the Code, which are expected to take effect on the same date and repeal Order No. 12.
What does simplified registration require that record-filing did not?
Record-filing was the lightest of MEE Order No. 12's three tracks, available for substances below 1 t/yr. Simplified registration, which previously covered the 1 to 10 t/yr band, carries real dossier obligations: a completed application form, the Article 10(3) evidence (typically hazard and exposure information supporting the lower-tier risk conclusion), and any further hazard and risk data the enterprise already possesses. The authority reviews the file against the simplified procedure's statutory time limit rather than issuing an acknowledgment of notification.
In practice, teams that treated sub-tonnage introductions as near-automatic must now build a simplified-registration dossier before launch. Substances already cleared by record-filing before August 15, 2026 are not re-opened by the notice; the change governs new filings from that date. The notice also signals that further MEE rules on new-chemical-substance registration will displace it automatically, so compliance programmes should be built for the Code-aligned regime, not just the interim procedure.
What should compliance teams do before August 15?
First, audit the IECSC status and tonnage band of every substance slated for manufacture or import into China in the next two quarters. Any sub-tonnage, IECSC-unlisted substance relying on record-filing must be re-routed: either file record-filing now, before the window closes, or prepare a simplified registration dossier for submission from August 15. Second, confirm whether Article 10(3) evidence and existing hazard data are sufficient for the simplified track, or whether testing must be commissioned. Third, brief domestic agents and upstream suppliers, since the cut-over affects the whole introduction chain, not only the legal entity holding the certificate.
| Track under MEE Order No. 12 | Volume band | Status from August 15, 2026 |
|---|---|---|
| Record-filing | < 1 t/yr | Closed; route to simplified registration |
| Simplified registration | 1 to 10 t/yr | Open; now also receives former record-filing cases |
| Regular registration | ≥ 10 t/yr | Unchanged; chemical risk assessment report required |
Continuous, per-jurisdiction real-time monitoring surfaces this kind of procedural cut-over the moment a ministry publishes, which matters when the gap between notice and entry into force is measured in days.
Take advantage of this real-time watch
Act now: confirm which of your substances depended on record-filing, decide whether to file before August 15 or move straight to simplified registration, and align dossiers and agents with the Code-aligned regime that takes its place.
