On June 11, 2026, the MEE released the Measures for the Environmental Management Registration of New Chemical Substances (Draft Revision for Comments). The draft makes significant adjustments to the scope of application, registration applicants, and legal liabilities. At the same time, local authorities have introduced relevant measures bringing a number of ecological and environmental violations within the scope of reportable, rewardable offenses. For the cosmetics industry, the most noteworthy change is that cosmetics have been removed from the regulation's “scope of non-application” — meaning that new chemical substances contained in finished cosmetic products may, in the future, be brought within the scope of environmental management registration for new chemical substances.
The environmental compliance risks and liability boundaries for cosmetics companies are undergoing profound changes. CIRS Group hereby presents an interpretation of the main contents of this revision, its impact on cosmetics companies, and the associated penalties, for your reference.
Background
The current Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No. 12), promulgated in 2020 (hereinafter “the current Order No. 12”), is China's regulation governing the environmental management of new chemical substances. On June 11, 2026, the MEE released the Measures for the Environmental Management Registration of New Chemical Substances (Draft Revision for Comments) — i.e., the revision draft of MEE Order No. 12 (hereinafter “the revised Order No. 12”). It is currently at the public consultation stage, with the deadline for comments being July 12, 2026. The revised Order No. 12 is planned to take effect in August in coordination with the implementation of the Ecological Environment Code.
Cosmetics Removed from the “Scope of Non-Application”
Before revision: Under the current Order No. 12, pharmaceuticals (including active pharmaceutical ingredients), pesticides (including technical-grade pesticides), veterinary drugs (including active ingredients), cosmetics, foods, food additives, feed, feed additives, and fertilizers are not subject to Order No. 12. This provision was established on the basis that the products involved are already managed by other competent authorities and relevant regulations.
After revision: The revised Order No. 12 indicates that the above special products will also be brought within the scope of new chemical substance registration management, rather than determining applicability solely on the basis of the industry to which a product belongs.
If this revision is implemented, the impact on enterprises in related industry chains — pharmaceuticals, pesticides, cosmetics, and food — will be particularly direct. Relevant enterprises need to re-examine their new substance registration obligations in scenarios such as product import, the production/import of active pharmaceutical or technical ingredients, and the production/import of additives.
CIRS Interpretation: Under the current Order No. 12, finished cosmetic products are not subject to supervision by the ecological and environmental authorities with respect to the new chemical substances they contain; however, where a cosmetic ingredient itself is determined to be a new chemical substance, it must still be registered by the ingredient's manufacturer or importer.
The revised Order No. 12 deletes the above exemption clause, and finished cosmetic products will no longer fall within the “scope of non-application.” For cosmetics, this means that new chemical substances contained in finished cosmetic products may, in the future, also be brought within registration management. The most directly affected are imported cosmetics: if an imported cosmetic contains an ingredient that qualifies as a new chemical substance, then before importation in the future — in addition to completing the cosmetic's own registration/filing — the relevant new chemical substance may need to be registered in advance. This undoubtedly imposes new compliance requirements on imported cosmetics companies.
From a legislative-logic perspective, on the one hand, the Code establishes a registration system for the environmental management of new chemical substances without excluding any specific product category, reflecting an orientation toward unified management of the environmental risks of all types of new chemical substances; on the other hand, as personal care products, cosmetics — after use — may allow some difficult-to-degrade components to enter water bodies and accumulate in aquatic organisms, and given the frequency of use and the size of the exposed population, their environmental exposure cannot be overlooked. Expanding the scope of management from “new chemical substances in cosmetic ingredients” to “new chemical substances in finished cosmetic products” makes regulatory coverage more complete.
How Many Cosmetic Ingredients Are New Chemical Substances?
CIRS Interpretation: Inventory of Existing Chemical Substances in China (IECSC): used to identify chemical substances that have been legally manufactured, imported, or used in China. The inventory was first published in 2003 and has since undergone multiple supplements and updates. Any chemical substance not listed in the inventory (including the confidential inventory) is regarded as a “new chemical substance” and must be registered under the Measures for the Environmental Management Registration of New Chemical Substances before it is first manufactured or imported.
Inventory of Existing Cosmetic Ingredients in China (IECIC): can serve as an important reference for determining whether a given ingredient qualifies as a new cosmetic ingredient.
So, how many cosmetic ingredients are new chemical substances? Through a simple matching exercise conducted by an AI program independently developed by CIRS Group between the IECSC and the IECIC, the substances that did not match in the databases number at least in the thousands.
Registration Applicants Tightened — Directly Relevant to Imported Cosmetics
Before revision: The current Order No. 12 allows overseas manufacturing or trading enterprises that export new chemical substances to China to act as applicants (a domestic agent must be designated), and, under specific circumstances, processors/users may also act as applicants.
After revision: The draft makes clear that only enterprises and institutions within China that manufacture or import new chemical substances may act as registration applicants; overseas enterprises and domestic processing/using enterprises may no longer act as registration applicants.
Legal Liability Significantly Increased
The draft aligns the penalties for new chemical substance-related violations with the Ecological Environment Code. For producing or importing new chemical substances without obtaining a registration certificate or not in accordance with the requirements of a registration certificate, as well as for using new chemical substances from unlicensed sources to manufacture products, fines have been substantially increased — up to a maximum of RMB 2 million — with graduated penalties for refusal to correct being even heavier. The targets of penalties are no longer limited to the production and import stages; the “use” stage has also been expressly brought within the scope of liability. For cosmetics companies, new chemical substance compliance is no longer merely an issue at the point of registration application, but a comprehensive legal risk running through procurement, import, R&D, production, and downstream management.
Local Authorities Bring New Chemical Substance Violations Within Rewardable Reporting
The Shanghai Measures for Rewarding the Reporting of Ecological and Environmental Violations (Hu Huan Gui [2026] No. 3), effective from June 5, 2026, brings a number of ecological and environmental violations within the scope of reportable, rewardable offenses, among which those directly relevant to cosmetics companies include:
(8) Producing or importing new chemical substances not in accordance with the requirements of a new chemical substance environmental management registration certificate; producing or importing new chemical substances without a registration certificate, or using new chemical substances without a registration certificate to manufacture products; producing or importing chemical substances listed in, or using listed chemical substances to manufacture products, not in accordance with the environmental risk control measures for key-controlled new pollutants;
Where the above acts are verified and the ecological and environmental authority issues an administrative penalty decision, the reporter may receive a reward of RMB 3,000; if the reporter is an employee of the reported enterprise, an additional RMB 10,000 is awarded; where the clue is transferred to a public security organ and a criminal case is filed, an additional RMB 30,000 is awarded; and for major contributions to preventing particularly serious ecological and environmental violations, eliminating major safety hazards, or assisting in the investigation of particularly serious cases, a one-time reward of up to RMB 500,000 may be granted. Reporting channels include the 12345 citizen service hotline, the official website of the Shanghai Municipal Bureau of Ecology and Environment, the “National Ecological and Environmental Complaint and Reporting Platform” WeChat official account, and letters.
This means that the compliance risks for cosmetics companies using new chemical substances, as well as the pollutant discharges of manufacturers, will in the future be subject to strengthened supervision.
A Tight Timeline for Transition Between the Old and New Systems
The draft stipulates that new substances for which filing has been completed under the current Order No. 12 must re-apply for and obtain a registration certificate under the new rules by December 31, 2026; registration certificates previously obtained will remain valid after the revised Measures take effect, and registration applications already accepted may continue to be processed under the current Measures. Given the large number of new substances that have completed filing under Order No. 12, the re-application of existing projects will test both enterprises' compliance capacity and the approval efficiency of the competent authorities, and enterprises should review their existing portfolios and formulate compliance plans as soon as possible.
Whether it is the re-application of existing substances or the new development that finished cosmetic products may be brought within registration management, the key step is to accurately identify which ingredients in a formulation are new chemical substances. Around this core need, CIRS Group offers the following two services:
① Cosmetic Formulation New Chemical Substance Screening Service (Precise Matching)
At the stages of formula review, product launch, or downstream customer audit, what enterprises worry about most is “whether a new chemical substance is hidden in the formula.” CIRS Group, against the Inventory of Existing Chemical Substances in China (IECSC), performs item-by-item precise matching of an enterprise's formula ingredients (including CAS numbers and chemical names), identifies ingredients that may qualify as new chemical substances, and provides registration pathways and compliance recommendations for the matched ingredients.
② Global CosIng-IECSC × IECIC Dual-Inventory Self-Service Query
Enterprises may also log in to the Global CosIng platform independently developed by CIRS Group and, by comparing the two major inventories — the Inventory of Existing Chemical Substances in China (IECSC) and the Inventory of Existing Cosmetic Ingredients in China (IECIC) — carry out their own screening of new chemical substances in their formulations.
CIRS Reminder
The environmental management of new chemical substances is being elevated from the level of a “departmental regulation” to that of a “code,” with regulatory intensity, scope of liability, and social supervision tightening in tandem, and the long-standing situation of “relatively lenient environmental compliance” for the cosmetics industry may change. It is recommended that cosmetics and related ingredient enterprises:
- Screen the ingredients in their formulations against the Inventory of Existing Chemical Substances in China (IECSC) for those that may qualify as new chemical substances, and assess registration obligations in advance — particularly for imported finished cosmetic products;
- Clarify the registration applicant entity — overseas enterprises may no longer act as applicants; for imported cosmetics, the domestic importer should act as the registrant;
- Pay attention to the re-application deadline for existing filed projects (before December 31, 2026), and assess the impact of the abolition of filing and the unification of registration on product launch timelines.
The draft is still at the consultation stage, and the final regulatory approach shall be subject to the official text. CIRS Group will continue to track the progress of the relevant regulatory revisions and provide you with professional regulatory interpretation and China new chemical substance and cosmetics compliance solutions.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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