On March 12, 2026, China formally enacted the Ecological Environment Code of the People's Republic of China, passed at the Fourth Session of the 14th National People's Congress. The Code consists of 5 parts and 1,242 articles and takes effect on August 15, 2026, simultaneously repealing 10 existing laws, including the Environmental Protection Law. This is the largest legislative consolidation in Chinese environmental history.
For industries that manufacture, import, or process new chemical substances — including chemicals, advanced materials, and pharmaceutical intermediates — the most consequential provisions are found in Chapter 34 of Part II (Pollution Prevention and Control), under the subpart titled "Chemical Substance Pollution Risk Management." For the first time, the regulation of new pollutants has been codified at the national statutory level. The legal authority governing new chemical substance registration has been elevated from ministerial regulations to a national code, and the maximum penalty for non-compliance has jumped from tens of thousands of RMB to RMB 2 million, with additional consequences including production suspension and forced closure. With the effective date less than six months away, Regulix strongly urges affected businesses to conduct an immediate compliance audit and initiate registration for any unregistered new chemical substances without delay.
Change #1: New Pollutant Regulation Enters National Law for the First Time
Prior to this Code, new chemical substance management in China was governed primarily by ministerial regulations issued by the Ministry of Ecology and Environment (MEE). The Code changes that fundamentally. Minister of Ecology and Environment Huang Runqiu confirmed that the establishment of a dedicated chapter on chemical substance pollution risk management marks the first time new pollutant regulation has been written into a national statute — a milestone in China's transition from administrative-level chemical management to codified governance.
For businesses, this is not a minor procedural update. Compliance with new chemical substance requirements must now be treated with the same institutional seriousness as tax and business licensing obligations — not simply as a matter of passing routine inspections.
Change #2: Pre-Market Registration Is Now Mandatory — "No Registration, No Production"
The Code explicitly requires that manufacturers and importers of new chemical substances complete environmental management registration before commencing production or importation. A new chemical substance is defined as any substance not listed in China's Inventory of Existing Chemical Substances (IECSC). This requirement applies equally to domestically synthesized substances and to materials sourced from overseas suppliers.
It is worth noting that the Measures for the Environmental Management Registration of New Chemical Substances (MEE, MOFCOM, and General Administration of Customs Order No. 38), which took effect on May 1, 2025, already provides detailed procedural requirements covering registration types (standard registration, simplified registration, and filing), required documentation, and post-registration obligations. With the Code now in force, the enforcement authority behind these requirements becomes significantly stronger.
Regulix recommends that businesses make IECSC verification the first step in any new product development or raw material sourcing process — before R&D investment or supplier contracts are finalized.
Change #3: Information Disclosure Obligations Extend Across the Entire Supply Chain
The Code establishes clear information disclosure requirements that go well beyond the entity that holds the registration. Manufacturers, importers, and processors of new chemical substances are required to pass the following information downstream to their customers: registration certificate number or filing acknowledgment number, approved use, environmental and health hazard profile, risk control measures, and applicable environmental management requirements.
In practice, this means compliance liability is no longer limited to the party that files for registration. Downstream purchasers and processors who cannot produce documentation of their supplier's valid registration are themselves exposed to regulatory risk.
Regulix advises companies to take two concrete steps: first, add new chemical substance compliance clauses to procurement contracts requiring suppliers to provide copies of their registration certificates; and second, maintain a comprehensive internal chemical substance compliance ledger that is audit-ready at all times.
Change #4: Dynamic Inventory Updates — the Priority New Pollutants List Requires Ongoing Monitoring
The Code establishes a dynamic inventory management system. The State Council's ecological and environmental authority will continuously update the Priority New Pollutants Control List, imposing prohibitions or restrictions on the production, use, or discharge of listed substances. Additional lists — including the Inventory of Toxic and Hazardous Air Pollutants, the Inventory of Toxic and Hazardous Water Pollutants, and the Inventory of Priority Toxic and Hazardous Soil Substances — will also be maintained and updated on a rolling basis. Chemical substances added to the Strictly Restricted Import List will be subject to import environmental management permits.
Once a substance is added to any of these lists, affected businesses are required to adjust their processes or substitute materials within a specified timeframe. Regulix recommends that companies assign a dedicated staff member to monitor official MEE announcements on a regular basis and integrate inventory updates into their standard raw material compliance review workflow.
Change #5: Fines Up to RMB 2 Million, Plus Production Suspension and Forced Closure
The Code's legal liability provisions represent its most significant escalation in enforcement. Chapter 11 of Part V (Legal Liability) establishes specific penalties for violations of chemical substance pollution risk management requirements. Businesses that manufacture or import new chemical substances without completing the required registration, or that unlawfully use substances on the Priority New Pollutants Control List, face fines ranging from RMB 200,000 to RMB 2,000,000. Severe violations may result in ordered production suspension, required business closure, or permanent shutdown.
The Code also maintains the principle of proportionality — penalties are scaled to the severity of the violation — while preserving existing enforcement tools such as per-day cumulative fines and administrative detention.
To put this in perspective: the maximum penalty under this Code is approximately 10 to 20 times higher than what was enforceable under previous ministerial regulations. The cost of a single violation now far exceeds the total cost of a professional registration engagement. Regulix emphasizes that this shift fundamentally changes the compliance calculus for any business operating in China's chemical sector.
Closing
China's Ecological Environment Code takes effect on August 15, 2026 — less than six months from now. Regulix recommends that affected businesses complete the following four actions immediately:
Conduct a full audit of all chemical substances currently in production, import, or use, and verify each against the IECSC
Initiate registration proceedings for any identified new chemical substances without delay
Establish or update an internal chemical substance compliance ledger covering the full supply chain
Implement an ongoing monitoring system to track updates to the Priority New Pollutants Control List and related regulatory inventories
For tailored support on new chemical substance registration in China, contact Regulix for a customized compliance solution.
