China’s changes to chemical registration and proposed operating-permit rules are broadening compliance responsibilities across manufacturers’ supply chains, according to Compliance Week. The developments affect businesses producing, importing, distributing or using chemicals in China, linking substance approvals more closely to sourcing arrangements, storage and the allocation of responsibility between companies.
The Ministry of Emergency Management published draft revisions to hazardous-chemical operating-permit measures on 21 September, with public consultation running until 22 October. The proposal distinguishes between operations without storage, chemical shops, petrol stations, storage businesses and warehousing. It also covers electronic permits and licensing responsibilities. These provisions remain proposals rather than final law.
According to Compliance Week, the draft envisages fines of RMB100,000 to RMB500,000 for operating hazardous-chemical businesses without the necessary permit. Operators buying hazardous chemicals from an enterprise trading illegally without the required authorisation could face penalties of RMB200,000 to RMB500,000. The proposed purchasing penalty makes supplier authorisation relevant alongside an operator’s own licensing position.
Separate changes to new chemical substance management took effect on 15 August, following implementation of China’s Ecological and Environmental Code. The Ministry of Ecology and Environment stopped processing environmental-management filings for new substances from that date. Businesses previously eligible for that route must instead apply for environmental-management registration before production or import, following the applicable simplified-registration process and timetable.
The revised framework also ends direct acceptance of new-chemical registration applications from overseas enterprises. China-based importers can act as applicants under the relevant framework. Compliance Week’s analysis says multinational manufacturers should establish which entity will apply and import the substance, and check whether supplier arrangements and internal records still match those responsibilities.
The ministry also announced the addition of four chemicals and 482 previously registered new substances to China’s Inventory of Existing Chemical Substances. Listing alone does not settle every compliance requirement: intended uses, conditions and restrictions still need assessment. Compliance Week argues that businesses should connect inventory and registration records with actual procurement, importing, warehousing and production arrangements, reviewing them when corporate identities or supply-chain responsibilities change.
