On August 15, 2026, the Standing Committee of the National People's Congress (NPC) confirmed that the Ecological and Environmental Code of the People's Republic of China (Presidential Order No. 70) entered into force, five months after its adoption on March 12, 2026. The Code is only China's second statutory codification after the Civil Code, and for the chemicals industry its immediate consequence is concrete: Book II, Part IX, Chapter 34 (Articles 648-651) lifts chemical-substance pollution-risk control from departmental rule to statute for the first time, and MEE Order No. 12, the registration measure known as "China REACH", is repealed and replaced on the same date.
For manufacturers and importers of substances not listed in the Inventory of Existing Chemical Substances (IECSC), the legal basis for pre-marketing registration of new chemical substances has moved up the hierarchy without a transition window. Compliance teams must now anchor their registrations, risk assessments, and new-pollutant obligations in the Code itself, with a revised MEE implementing measure aligned to it taking effect alongside.
What changed for new chemical substance registration?
The Code's Articles 650-651 establish, at statute level, the pre-marketing registration system for new chemical substances and the List of New Pollutants under Key Management. Until August 15, 2026, these obligations sat in MEE Order No. 12 (effective January 1, 2021), a departmental rule that had replaced MEP Order No. 7. The three-track structure is preserved, record-filing for substances below 1 tonne per year, simplified registration for 1 to 10 tonnes, and regular registration at 10 tonnes and above, plus the new-use route, but it now derives its authority from an NPC statute rather than a ministry order. The competent authority remains the Ministry of Ecology and Environment (MEE), acting through its Solid Waste and Chemicals Management Centre (SCC).
Who is impacted, and what must change operationally?
Any chemical manufacturer or importer placing a non-IECSC substance on the Chinese mainland market, including overseas suppliers selling into China through a domestic entity, must re-baseline their compliance documentation to the Code. The shift is legal rather than procedural: existing registrations under MEE Order No. 12 remain valid, but new submissions, tonnage-band reviews, and new-pollutant risk-control obligations now cite Articles 648-651. A revised MEE draft measure (circulated June 11, 2026) aligns the operational registration rules with the Code and entered into force on August 15, 2026, so teams should already be filing against the updated text. The Code also elevates the List of New Pollutants under Key Management to statutory footing, tightening the link between chemical registration and the separate new-pollutants regime covering PFAS and persistent toxic substances.
How does the Code interact with the rest of China's chemicals regime?
The Code does not absorb the hazardous-chemicals safety regime under State Council Decree No. 591, nor the disinfectants regime administered by the National Health Commission. Those instruments continue to apply in parallel: a single substance can simultaneously require MEE new-substance registration under the Code, hazardous-chemicals registration with the National Registration Center for Chemicals, and separate product approvals. Compliance leads should not collapse these regimes into one. The Code's contribution is the statutory floor for pollution-risk control, which sits above and now governs the environmental registration layer that MEE Order No. 12 previously defined alone.
| Layer | Before August 15, 2026 | From August 15, 2026 |
|---|---|---|
| New-substance registration legal basis | MEE Order No. 12 (departmental rule) | Ecological and Environmental Code, Arts. 650-651 (NPC statute) |
| New pollutants list footing | MEE and State Council instruments | Statutory, under the Code |
| Implementing rules | MEE Order No. 12 (2021) | Revised MEE measure aligned to the Code |
What should compliance teams do now?
Verify that every active and pending new-substance registration is mapped to its new statutory basis, confirm that in-flight submissions use the revised MEE implementing measure, and brief regulatory affairs and product-stewardship teams on the parallel-but-distinct hazardous-chemicals and new-pollutants regimes. For substances on the List of New Pollutants under Key Management, reassess environmental risk-control duties, including environmental impact assessment and discharge permitting, against the Code's statutory language. Continuous, per-jurisdiction monitoring of MEE and NPC publications surfaces this kind of hierarchy shift the moment it publishes.
Take advantage of this real-time watch
The entry into force of the Code closes the departmental-rule era for new chemical substance registration in China and opens a statutory one. Confirm applicability across your portfolio, re-anchor registration citations to Articles 648-651, and track MEE's aligned implementing rules as they are issued. Obsidian monitors this transition continuously, so the next implementing detail reaches you without delay.
