ROHS Compliance

On December 25, 2025, the Ministry of Ecology and Environment of China, together with the National Disease Control and Prevention Administration, released the Priority Controlled Substances List (Third Batch) (Announcement No. 43 of 2025) to implement the Action Plan for the Management of New Pollutants. This third batch covers 23 types of chemicals, mainly used in sectors such as petrochemicals, plastics, rubber, pharmaceuticals, textiles, dyes, coatings, pesticides, leather, and electroplating.

The list targets chemicals that pose significant environmental and human health risks, particularly those that are persistent, bioaccumulative, or hazardous (e.g., carcinogenic, mutagenic, reprotoxic, endocrine-disrupting, or highly toxic to aquatic life). Selection is based on environmental behavior, hazard characteristics, and exposure scenarios, including production volume and public exposure frequency. Together with the first two batches, the list now covers 63 chemicals.

For substances included in the third batch, environmental risk control measures must be applied at key stages of production and use, taking into account technical and economic feasibility to reduce impacts on human health and the environment.

Key management requirements include:

· EIA documents must clearly state the type, quantity, and purpose of use, and assess the generation, migration, and transformation of new pollutants throughout production processes.

· Enterprises must report the proportion and content of listed substances in raw and auxiliary materials based on design values or actual data from the previous year.

· Facilities involving these substances must implement anti-corrosion, leak-prevention, and leak-detection measures to prevent soil and groundwater contamination.

· Entities dismantling relevant facilities must prepare and file a pollution prevention plan at least 15 working days in advance.

Enterprises handling listed substances are required to conduct immediate self-inspections, strengthen chemical tracking and reporting mechanisms, and, where necessary, upgrade environmental protection infrastructure. As controls tighten, companies are encouraged to invest in R&D and transition toward safer and more sustainable alternatives to reduce compliance risks and enhance long-term competitiveness.