China Shanghai, China strengthens supervision of enterprises registered new chemical substance for environmental management

Based on the “Measures on new chemical substance environmental management registration” (Ecology and Environment Order No.12, hereafter as Order No.12), the Ministry of Ecology and Environment will reissue new chemical substance environment management certificate for the relevant enterprises in Shanghai every year. To strengthen the post-mortem supervision of the certificating of new chemical substance environmental management, on February 7, 2021, the Shanghai Municipal Bureau of Ecology and Environment released the “Notice on strengthening the supervision of new chemical substance environmental management registered enterprises”, based on the requirements of “Letter on enterprise information related to environmental management registration of new chemical substances (Solid Letter [2020] No.32)”. The notice mentions that strengthening the control by implement on-site inspections and random sampling inspections. The details are as following.

The Shanghai Municipal Bureau of Ecology and Environment dynamically updates the enterprises list and registration information on “Shanghai Chemical Environmental Management Information System” ( based on the information supplied by the Ministry of Ecology and Environment. Each branch of Shanghai Municipal Bureau of Ecology and Environment, related management committees and other departments will strictly inspect on the illegal activities in the production of un-registered new chemical substances and the import of new chemical substances on the daily environmental management, and make punishment. Additionally, every year, the Shanghai Municipal Bureau of Ecology and Environment

entrusts the municipal solidification management center and the third-party organizations to carry out the evaluation of new chemical substances follow-up spot inspection and training.

The enterprises that manufacture, process and use imported key environmental management hazardous or high-hazard new chemical substances in regular registration are the key targets of supervision. The following inspections are mainly carried out.

  • For the key targets, on-site inspection should be carried out at least once a year. And the enterprises will be required to register the environmental management requirements and environment risk control measures on the registration certificate.
  • For high-hazard and key environmental management hazards, management requirements such as discharge volume or discharge concentration, annual report and other management requirements stated in the registration certificate for restricted new chemical substance should be checked
  • After being included in the “China Existing Chemical Substances List”, if the new chemical is used for new industrial purposes other than permitted purposes, check whether the environmental management registration for new uses has been registered with the Ministry of Ecology and Environment.

The regular registered manufacturers of new chemical substances, and storage and processing users of new chemical substances that are classified into hazardous chemicals or major risk sources, should formulate emergency plans and emergency measures in accordance with the “Measures for Environmental Incidents Emergency Management” and other relevant regulations, and file them with the local ecology and environment departments.

For the original text of the notice, please refer to the following URL (in simplified Chinese).