Breaking News: China’s Draft Chemical Registration Rules: What Food Companies Need to Know

On June 11, 2026, China’s Ministry of Ecology and Environment (MEE) released the draft Measures for the Environmental Management Registration of New Chemical Substances (“draft Measures”) [1] for comments, with a short period of consultation, due by July 12, 2026.  

One change in the draft that particularly warrants closer attention for food companies is that new chemical registration may be required for newly approved food and food ingredients by China. According to the current MEE Order No. 12 governing new chemical registration, certain products and substances, including foods and food additives, are explicitly excluded from the scope of the chemical registration requirements, except where they are repurposed for industrial uses or involve new chemical substances used as raw materials or intermediates. This exclusion has been considered as establishing an important boundary between China’s food regulatory system and the new chemical substance registration regime.

However, the draft adopts a different structural approach. It defines “new chemical substances” by reference to whether they are listed in the Inventory of Existing Chemical Substances in China (IECSC) or subject to new‑use environmental management and provides that producers and importers must obtain chemical registration prior to production or import. The scope of exclusions under the draft appears narrower and does not expressly retain the current carve‑out for foods and food additives.

The absence of such an express exclusion does not necessarily indicate that MEE has reached a definitive policy position to bring all food‑sector substances within the new chemical substance regime. However, if adopted without further clarification, the draft could introduce uncertainty, requiring companies to assess whether certain substances not listed in the IECSC, such as novel food ingredients and additives, may trigger registration obligations in addition to applicable food approvals.

This development could have significant implications for food product launch planning. New chemical substance registration typically involves substance identification and characterization, testing data, environmental and human health hazard information, as well as exposure and risk assessments. These requirements may not fully align with the data packages prepared for novel food approvals, potentially leading to additional compliance burdens and timelines.

Food companies may use the comment period to assess whether they may be affected and, where appropriate, consider submitting comments requesting clarification from the authority in terms of whether foods and food additives can be continuously excluded from the new chemical registration as the status quo.

According to MEE, the draft is scheduled to take effect on August 15, 2026, alongside China’s new Ecological Environment Code.

We will continue to monitor the draft Measures and their potential impact on food companies. For further analysis of other key changes under the draft Measures, please monitor our upcoming newsletters which can be subscribed to here.

Keller and Heckman represents the food industry around the world on various regulatory matters.  If you have any questions or need any assistance, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), Sharon Tian (tian@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] https://www.mee.gov.cn/xxgk2018/xxgk/xxgk06/202606/t20260611_1159143.html