Regulatory update: China’s Environmental Code entered into force on 15 August 2026. Article 998 establishes a national legal basis for prohibiting or restricting specified non-degradable single-use plastic products, promoting recyclable, readily recoverable, degradable and harmless alternatives, and requiring designated retail, e-commerce, express-delivery and food-delivery businesses to report single-use plastic use and recovery data. Article 1225 sets penalties for non-compliance.
- The Code is now effective; it was adopted on 12 March 2026 and took effect on 15 August 2026.
- Article 998 does not itself list every prohibited SKU. Existing national catalogues, policies, standards and local implementation rules remain essential.
- Article 1225 can penalize prohibited production or sale at one to three times the value of the affected goods, alongside confiscation measures.
- Material names and “eco-friendly” wording alone do not establish compliance. Buyers need product-specific standards, test evidence and accurate claims.
- Molded pulp can be a useful plastic-reduction option, but food-contact, performance, sourcing and end-of-life claims must still be verified.
What changed on 15 August 2026?
The Environmental Code of the People’s Republic of China was adopted by the National People’s Congress on 12 March 2026 and entered into force on 15 August 2026. It consolidates major areas of environmental law into a code-level framework. For packaging and foodservice buyers, Articles 998 and 1225 are especially relevant because they connect single-use plastic restrictions with explicit legal duties and penalties.
This is not a brand-new list replacing every earlier plastic-control measure. The Code uses the phrase “in accordance with law” and refers to national provisions. Businesses must therefore read the Code together with applicable national catalogues, product standards, sector rules and local measures.
Article 998: restrictions, alternatives and reporting
Article 998 provides three connected directions:
- China prohibits or restricts the production, sale and use of non-degradable plastic bags and other specified single-use plastic products according to law.
- The state encourages reduced use and active recovery of single-use plastic products and promotes alternatives that are reusable, readily recyclable, degradable and harmless.
- Operators of retail venues, e-commerce platforms, express-delivery businesses and food-delivery businesses must report their use and recovery of single-use plastics to commerce, postal and other competent authorities as required by national rules.
The phrase “degradable and harmless” is important, but it should not be converted into an unsupported claim that every material marketed as degradable is automatically compliant. The product, application, marking and evidence must be assessed against the applicable rule and standard.
Article 1225: the penalty framework
Article 1225 provides that prohibited production or sale can result in an order to stop, confiscation of illegally produced or sold products, a fine of one to three times the value of those products, confiscation of illegal income and, in serious cases, licence revocation.
For prohibited or restricted use, competent commerce, postal and other authorities can order correction and fine enterprises or public institutions RMB 10,000–100,000. Other business operators can be fined RMB 500–5,000. Failure to report required single-use plastic use and recovery data is penalized under the same paragraph.
These are statutory ranges, not a prediction of the outcome in every case. Enforcement depends on the product, operator, conduct, evidence and competent authority.
Which plastic products are already prohibited or restricted?
China’s established national plastic-pollution policy includes prohibitions or restrictions covering categories such as:
- plastic shopping bags thinner than 0.025 mm;
- single-use expanded-plastic tableware;
- single-use plastic-stem cotton buds other than relevant medical devices;
- rinse-off personal-care products containing intentionally added plastic microbeads;
- plastic products made from medical waste;
- specified uses of non-degradable plastic shopping bags and single-use plastic tableware in retail, foodservice and other defined settings.
The scope and timetable come from national policies and detailed standards issued before the Code, including the 2020 national opinion on strengthening plastic-pollution control. Local rules may be stricter or cover additional products. Buyers should not present this list as if every item were newly created by Article 998.
Does the Code automatically approve PLA, PBAT, paper or molded pulp?
No material name creates a blanket exemption. PLA, PBAT, PBS, PHA, starch blends, paper, bamboo pulp and molded pulp may support different plastic-reduction or degradability strategies, but compliance depends on the exact product, formulation, use, applicable standard and claim.
Paper and molded pulp are not biodegradable plastic products, so the “double-j” marking rules in GB/T 41010—2021 should not be indiscriminately applied to them. Molded pulp food packaging should instead be evaluated through the product’s applicable quality, food-contact, fiber-sourcing and compostability evidence. If a coating, laminate or additive is used, it must be included in the assessment.
How GB/T 41010—2021 should be used
GB/T 41010—2021, Biodegradable Plastics and Products—Degradation Performance and Marking Requirements, provides degradation-performance and marking guidance for biodegradable plastics and products. The official standard explanation says the text marking includes material, degradation environment, reference standard and product name. Its graphic marking combines a circular-arrow symbol, the double “j” motif, material abbreviation, degradation environment, product standard and product name.
A marking is useful evidence, but buyers should not rely on the symbol alone. They should verify:
- Product identity: Is the report or declaration tied to the purchased SKU or covered family?
- Material composition: Are polymers, fiber, coatings and additives identified accurately?
- Applicable standard: Does the cited standard actually cover this product category?
- Degradation environment: Industrial composting, home composting, soil and marine conditions are not interchangeable.
- Test evidence: Are the laboratory, sample, method, result and date available?
- Claim wording: Does the label describe what the evidence proves without implying universal or instant degradation?
Relevant product standards for biodegradable plastics
Different product types use different standards. Examples include GB/T 38082—2019 for biodegradable plastic shopping bags, GB/T 18006.3—2020 for disposable degradable tableware, GB/T 35795—2017 for fully biodegradable agricultural covering film and GB/T 38727—2020 for biodegradable plastic packaging bags used in express delivery.
The national standards platform lists GB/T 38082—2025 as published on 2 December 2025 and scheduled to replace the 2019 shopping-bag standard when it takes effect on 1 January 2027. Procurement files should record the version currently applicable to the order rather than cite a future standard prematurely.
Biodegradable does not mean “disappears anywhere”
Degradation claims are tied to defined environmental and test conditions. Many commercially compostable materials require controlled temperature, humidity, oxygen and microbial activity. A compliant industrial-composting claim does not mean a product will rapidly disappear in a household bin, river or the open environment.
This distinction matters for both legal accuracy and consumer communication. Degradation should not be used as permission to litter, and waste prevention, reuse and reduction remain higher-priority decisions where practical.
What this means for molded pulp food-packaging buyers
Molded pulp can replace selected plastic formats in takeaway containers, bowls, plates, trays, beverage carriers, lids and other applications. It can also support right-sizing, nesting and fiber-based sourcing strategies. However, buyers should still verify the complete product rather than relying on the word “pulp.”
For every shortlisted item, confirm:
- fiber source and any applicable FSC documentation;
- food-contact evidence for the intended food, time and temperature;
- coating, additive and PFAS position where relevant;
- finished-product compostability scope where claimed;
- dimensions, weight, fit, strength, grease and moisture performance;
- production site, approved specification and change-control process;
- destination-market labelling and importer obligations.
Grandlink Hopes maintains verified FDA food-contact compliance and BPI certification support, and its range is covered by verified EN 13432 and FSC documentation. Applicable evidence is matched to the selected item during product approval. See our FDA, BPI, EN 13432 and FSC buyer guide for the different questions these references answer.
Supplier due-diligence checklist after the Code takes effect
- Identify whether the SKU falls within a national or local prohibited or restricted category.
- Confirm the product standard and version applicable on the supply date.
- Request a bill of materials or controlled material declaration.
- Match test reports and certificates to the product and manufacturing source.
- Review every “degradable,” “compostable,” “recyclable” or “plastic-free” claim.
- Keep purchase specifications, samples, labels and supplier declarations under version control.
- For affected operators, establish reliable use and recovery data collection.
- Recheck requirements when the material, coating, factory, market or rule changes.
Grandlink Hopes’ supply-chain response
Compliance evidence is only useful when it remains connected to production. Grandlink Hopes coordinates customer requirements, approved specifications, material and document checks, process monitoring, finished-product inspection and shipment release through one supply-chain interface.
Qualified resources across China’s main molded pulp regions and a strategic manufacturing relationship in Thailand support allocation flexibility, while common specifications and release requirements protect consistency. Learn more about our quality and supply-chain control framework, browse molded pulp product categories, or request product-specific documentation.
Frequently asked questions
When did China’s Environmental Code take effect?
It entered into force on 15 August 2026 after being adopted on 12 March 2026.
Does Article 998 contain a complete list of prohibited plastic products?
No. Article 998 establishes the legal direction and duties, while applicable national catalogues, policies, standards and local measures define detailed product and use restrictions.
Is a “double-j” mark mandatory evidence for molded pulp?
No. GB/T 41010—2021 concerns biodegradable plastics and products. Molded pulp is a fiber-based material and should be assessed using the standards and evidence applicable to the finished fiber product and any coating or additive.
Are all PLA or PBAT products automatically compliant?
No. Compliance depends on the exact formulation, product category, application, standard, marking and supporting evidence—not only the polymer name.
Does industrial compostability mean a package will degrade in nature?
No. Industrial compostability is demonstrated under controlled conditions and should not be represented as rapid degradation in a household bin, waterway or open environment.
Official sources
- Ministry of Ecology and Environment: Environmental Code of the People’s Republic of China
- National People’s Congress: Environmental Code legislation portal
- National Development and Reform Commission: Opinion on strengthening plastic-pollution control
- State Administration for Market Regulation: Official explanation of GB/T 41010—2021
- National standards platform: GB/T 38082 standard status
This article provides general procurement information, not legal advice. National catalogues, product standards, enforcement guidance and local rules can change or add requirements. Buyers and operators should confirm the current rule with the competent authority or a qualified adviser.
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