China’s Ministry of Ecology and Environment (MEE) has announced a public consultation for the addition of four chemical substances to the Inventory of Existing Chemical Substances in China (IECSC). The proposed update—2025’s second batch—was published on 11 August and will remain open for comment until 22 August 2025.
This development affects manufacturers, importers, and downstream users across industries operating in or exporting to China. Inclusion in the IECSC can significantly alter regulatory obligations for registration, use, and reporting.
What Are the Newly Proposed Substances?
The proposed additions include chemicals used in polymer production, coatings, lubricants, and as intermediates:
- Cyclohexyl vinyl ether – Used in resins and polymer synthesis.
- Ethoxylated trimethylolpropane trimethacrylate – A multifunctional acrylate monomer often found in UV-curable coatings.
- 1,3-Butylene glycol diesters with decanoic and octanoic acids – Commonly used in cosmetic formulations and lubricants.
- C14–20 fatty acid cobalt (2+) salts – Applied as drying agents in paints and coatings.
These additions stem from applications that met the technical and regulatory criteria outlined in the Measures on Environmental Management of New Chemical Substances and its implementation guidelines.
Why This Matters for Global Supply Chains
Inclusion on the IECSC removes the obligation to register the substance as a “new chemical” in China, easing market access and compliance burdens. For exporters and multinational manufacturers, this can streamline imports and reduce delays tied to pre-market approvals.
However, affected companies should still assess whether usage conditions, volume thresholds, or other sector-specific regulations (e.g. for cosmetics, electronics, or coatings) apply.
The move also reinforces China's shift toward more transparent chemical regulation, mirroring global trends in substance inventory management such as those seen under EU REACH and US TSCA.
Stakeholder Response and Next Steps
MEE has encouraged public feedback via telephone, fax, or email. Stakeholders are urged to review the draft listing and raise objections or provide additional information by 22 August 2025. After this period, approved substances will be formally listed in the IECSC, enabling broader commercial use.
Companies operating in high-risk sectors or exporting regulated mixtures and products should review their substance portfolios against the proposed list. Identifying overlaps can highlight opportunities to reduce compliance barriers—or signal the need for strategic reformulations.
