China to Bring Cosmetic Finished Products into New Chemical Substance Registration Framework

On June 11, 2026, China's Ministry of Ecology and Environment (MEE) initiated a public consultation on a draft revision to the Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No. 12). The draft introduces a major overhaul of the existing registration framework under MEE Order No. 12, with significant implications for chemical manufacturers and downstream industries, including cosmetics. The consultation period will remain open until July 12, 2026, and the revised regime is expected to take effect on August 15, 2026.¹

From Ingredient to Product: The Extension of Regulatory Boundaries

The proposed adjustment to the regulatory scope under MEE Order No. 12 is a key point of attention for the cosmetics industry. Under the current framework, cosmetic finished products are excluded from the application scope, while chemical substances intended for use as cosmetic ingredients remain within the regulatory framework. Accordingly, if a cosmetic ingredient is identified as a new chemical substance, its manufacturer or importer must complete the notification or registration procedures, whereas manufacturers and importers of cosmetic finished products are generally not directly subject to these obligations.

However, in the draft revision, cosmetic finished products are removed from the exclusions. While no cosmetics-specific provisions are introduced, the changes suggest that new chemical substances contained in cosmetic products may be will be integrated into a unified environmental regulatory framework, effectively extending the regulatory boundary from the "ingredient level" to the "product level".

This regulatory expansion poses an immediate challenge for companies: screening formulas for compliance risks. Cosmetic ingredients in China are regulated under the Inventory of Existing Cosmetic Ingredients in China (IECIC), while new chemical substances are determined by the Inventory of Existing Chemical Substances in China (IECSC). These two inventories do not fully overlap. According to a preliminary cross-reference of public records, around 1,500 IECIC-listed ingredients are absent from the public IECSC. While this baseline figure remains a rough estimate, it underscores a notable presence of unlisted chemical substances in the cosmetics supply chain. Looking ahead, finished products containing these ingredients will face mandatory environmental compliance checks.