China Introduces New Regulations: Upgraded Full-Chain Supervision for ODS and Hydrofluorocarbons

Recently, to implement the Regulation on the Administration of Ozone Depleting Substances and strengthen the full-chain supervision of ozone-depleting substances and hydrofluorocarbons (chemicals listed in China's List of Controlled Ozone-Depleting Substances, hereinafter referred to as controlled substances), China's Ministry of Ecology and Environment (MEE) issued a notice on further strengthening the management of these substances.

The main provisions are as follows:

Strengthening Production Quota Permit Management

• For entities that produce (including by-production) controlled substances for controlled uses (including exempted controlled uses), and entities that produce controlled substances for feedstock uses and sell them externally, production quota permit management must be implemented in accordance with the law.

Controlled uses refer to uses such as refrigerants, blowing agents, fire extinguishing agents, solvents, cleaning agents, process agents, pesticides, aerosol propellants, and expanding agents. Exempted controlled uses refer to specific applications where controlled substances are permitted after their phase-out for controlled uses, such as in laboratory analysis, inspection and quarantine, and as process agents. Feedstock uses refer to uses as raw or auxiliary materials that are ultimately converted into other chemicals through chemical reactions.

• Production entities must apply to the MEE for the next year's production quota before October 31 each year. First-time applications must include the annual quota application form, business license, environmental impact assessment approval document, environmental protection completion acceptance report, management system documents for controlled substance production and operation, and explanations regarding the production site, facilities, equipment, professional technical personnel, and production performance. Non-first-time applications must provide the annual quota application form and materials regarding any changes.
• Production entities needing to adjust their production quota must submit an application form to adjust the current year's production quota. Entities reducing their quota must also provide an explanation of their production situation for the year; entities obtaining a production quota for the first time through an adjustment must submit application materials as required for a first-time application.

Newly established production facilities for controlled substances for feedstock uses that sell externally must apply for the next year's production quota before October 31 each year, or apply for the current year's production quota, and submit application materials as required for a first-time application.

Strict Sales Record-Filing Management

• Record-filing management must be implemented in accordance with the law for entities selling controlled substances (including polyol premixes containing controlled substances, and refrigerant blends). Sales entities must not sell controlled substances or their mixtures to individuals. Production entities selling controlled substances or mixtures they produce themselves are exempt from sales record-filing requirements. Controlled substances produced by production entities solely for use as feedstock in downstream chemical products within the same enterprise must not be sold externally.
• Sales entities must apply for record-filing with the competent department of ecology and environment at the municipal level with districts where they are located. For first-time filing, they must provide the application form, business license, and an explanation of relevant business operations. Non-first-time applications must be submitted between December 1 and January 31 of the following year, including the application form and materials regarding any changes. Sales entities must provide purchasers with accurate information on the type, quantity, intended use, and specifications of the controlled substances sold, and maintain records. Entities selling polyol premixes must clearly indicate on their products the types, content, and date of the controlled substances involved, as well as information about the upstream production or sales entity, ensuring this information remains legible throughout the product's lifecycle.

Strengthening Use Quota Permit or Record-Filing Management

• Quota permit or record-filing management must be implemented in accordance with the law for entities using controlled substances.
• Quota permit management must be implemented in accordance with the law for entities with an annual controlled use of Hydrochlorofluorocarbons (HCFCs) of 100 tons or more and with verified baseline (2009-2010) usage records, entities purifying Carbon Tetrachloride (CTC) for laboratory analytical reagent use, and entities using CTC as a process agent.
• Record-filing management must be implemented in accordance with the law for the following user entities:
• Entities using controlled substances for feedstock purposes;
• Entities manufacturing, constructing, or installing refrigeration and air-conditioning equipment or systems that use controlled substances or their mixtures (excluding those subject to use quota permit management);
• Enterprises using polyol premixes containing controlled substances for polyurethane foam (including spray application);
• Entities manufacturing fire extinguishing system products that use controlled substances;
• Entities compounding controlled substance solvents (dust removers);
• Entities purifying controlled substances for laboratory analytical reagents (excluding CTC) and electronic specialty gases;
• Entities using Methyl Bromide for entry-exit animal and plant quarantine treatment;
• Other entities using controlled substances for controlled uses that do not require use quota permit management.

User entities must apply for record-filing with the competent department of ecology and environment at the municipal level within the districts where they are located. For first-time filing, they must provide the application form, business license, an explanation of relevant business operations, and descriptions of relevant facilities and equipment. Entities using Methyl Bromide for entry-exit animal and plant quarantine treatment must also provide the Approval Certificate for Entry-Exit Animal and Plant Quarantine Treatment Units. Non-first-time applications must be submitted between December 1 and January 31 of the following year, including the application form and materials regarding any changes.

Entities using compounded solvents (dust removers), purified laboratory analytical reagents, or purified electronic specialty gases are exempt from record-filing.

• Entities engaged in foam spray application, or the construction or installation of refrigeration and air-conditioning equipment or systems, must provide users with information on the type, quantity, and upstream production or sales entity of the controlled substances used, and maintain records.

Improving Record-Filing Management for Maintenance, Scrapping, Recovery, Recycling, and Destruction

• Record-filing management must be implemented in accordance with the law for entities engaged in activities such as maintenance or scrapping of refrigeration and air-conditioning equipment, refrigeration and air-conditioning systems, or fire extinguishing systems containing controlled substances, as well as entities engaged in the recovery, recycling, or destruction of controlled substances.
• Maintenance and scrapping entities must file records with the municipal-level ecology and environment authorities; recovery, recycling, and destruction entities must file records with the provincial-level authorities, submitting an application form, business license, and explanations of operations and facilities. Entities must update their filings promptly if information changes, and must cancel their filing if they cease operations.

Regulating the Management of By-Produced Controlled Substances

• Entities producing chloromethanes that by-produce CTC, and entities with an annual CTC usage for feedstock purposes exceeding 1,500 tons, must install automatic monitoring equipment, connect it to the competent department of ecology and environment's network, and ensure its normal operation.
• Entities that by-produce Trifluoromethane (HFC-23), unless using the HFC-23 for feedstock or controlled uses, must employ approved destruction technologies for disposal and must not directly emit it.

Establishing and Improving Data Retention and Reporting Systems

• Entities involved in production, sales, use, maintenance, scrapping, recovery, recycling, and destruction must apply for quotas or file records on the "Ozone-Depleting Substances Information Management System" (http://new-ods.ozone.org.cn) and query relevant information. They must retain complete original records related to their production and business activities for at least 3 years.
• Production, sales, and user entities must report data on controlled substances within 15 working days after the end of each quarter. Maintenance, scrapping, recovery, recycling, and destruction entities must report such data within 30 working days after the end of each year, as required.

Strict Supervision and Law Enforcement

Competent departments of ecology and environment at all levels must strengthen inter-departmental information sharing, focus on key areas, and enhance routine supervision over activities involving controlled substances. They must fully utilize methods such as automatic monitoring, multi-departmental information screening, and big data analysis to improve the precision of supervision and enforcement. Enforcement must focus on activities such as unauthorized production/sales, illegal purchasing/selling, illegal use, failure to file records, data falsification, and failure to install monitoring equipment as required. Cases suspected of constituting crimes must be promptly transferred to judicial authorities.

Strengthening Organization and Implementation

Competent departments of ecology and environment at all levels must attach great importance to the management of controlled substances, enhance monitoring capabilities, promote green alternatives, and strengthen publicity and training. Provincial-level departments must coordinate work within their administrative regions, refine policies and measures, organize record-filing and data reporting, strengthen early warning and source tracing, and guide industries towards low-carbon transformation. Municipal-level departments must strictly review project approvals, organize record-filing and data reporting, equip themselves with necessary detection equipment, improve law enforcement effectiveness, and promptly report violations.

This notice took effect on March 1, 2026. The Notice on Strengthening the Management of Production, Sale and Consumption of Hydrochlorofluorocarbons and the Notice on Implementing Carbon Tetrachloride Production Quota Permits, Use Quota Permits, and Sales Registration Management were repealed simultaneously.

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Further Information

MEE