China REACH Update: Proposed Changes Could Impact Overseas Chemical Exporters

China's Ministry of Ecology and Environment (MEE) has published a draft revision of the new chemical substance registration regulation (China REACH), with the public consultation open until 12 July 2026 and the revised regulation is expected to enter into force on 15 August 2026.

One of the most significant proposed changes is the removal of the current overseas applicant model.

If adopted, only enterprises or institutions registered in mainland China and engaged in manufacturing or importing the substance would be eligible to act as applicants for new chemical substance registrations. This proposal could have important implications for companies exporting chemical substances to China or planning future market access. Existing compliance strategies, supply chains, and the protection of confidential business information may need to be reassessed.

What could this mean for your business?

·         Do you currently export, or plan to export, chemical substances to China, either as such or in mixtures?

·         Do you currently hold, rely on, or plan to obtain a China new chemical substance record notification or registration for exports to China?

·         If the current overseas applicant model is no longer available, would this affect your compliance route, supply-chain setup or protection of confidential business information for exports to China?

 Please contact us if you would like to discuss whether your substances, supply chain or project status may be affected. Contact us to learn how we can support you.

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