China’s Regulatory Framework on Pollutant Discharge Permits

The document assesses China's transition toward a comprehensive 'one-permit' governance system for stationary pollution sources, analyzing the legal framework, implementation challenges at the local level, and the role of the Ministry of Ecology and Environment (MEE). It highlights gaps in the current system, such as the exclusion of noise and solid waste from the primary permitting regime and a lack of specific legal liabilities for permit violations. The report compares China's approach with the EU's Industrial Emissions Directive (IED), emphasizing the use of Best Available Techniques (BAT) and risk-based inspection strategies to improve environmental quality.

• China aims to establish a comprehensive 'one-permit' governance system for all stationary pollution sources by the end of 2020, integrating various environmental management systems including environmental impact assessments (EIA), environmental taxes, and emissions trading.
• The current permitting regime in China primarily focuses on air and water pollutants, leaving a gap in the management of soil, marine, and noise pollution, as well as solid waste.
• Local implementation of the PDP system has faced significant challenges, including a heavy workload for local departments and a tendency to prioritize the quantity of permits issued over the quality of the permits.
• There is a critical lack of specific legal liabilities for failing to observe permit requirements or for failing to maintain environmental management records, meaning authorities often cannot impose penalties even when violations are found.
• The report identifies a common misunderstanding among local officials who view the emission permit as a mere 'identity card' or registration document rather than a performance control tool that mandates specific conditions for operation.
• The EU's Industrial Emissions Directive (IED) 2010/75 serves as a reference for China, utilizing 'Best Available Techniques' (BAT) to set emission limit values and ensuring that environmental quality standards prevail over individual emission limits.
• In China, the relationship between the EIA and the permitting system is not explicitly defined as a prerequisite in current documents, though the report recommends that EIA should be a mandatory prerequisite for granting a permit.
• The report suggests that China's total emission control system should transition from a top-down approach based on administrative divisions to a bottom-up approach based on individual discharging institutions and companies.
• Third-party agencies are increasingly used in China to support both government review processes and corporate compliance, but there is a need for clear accountability and qualifications for these verifiers.

APA

Bigg, M., De Boer, D., He, R., Huang, X., Jia, L., Kramer, L., Li, Y., & Pei, X. (2020). China’s Regulatory Framework on Pollutant Discharge Permits. ClientEarth. https://www.clientearth.org/media/eyhjspy5/06-permitreport_1_nov2024.pdf

Chicago

Bigg, Martin, Dimitri De Boer, Rong He, Xueju Huang, Lei Jia, Ludwig Kramer, Yuanyuan Li, and Xiaofei Pei. China’s Regulatory Framework on Pollutant Discharge Permits. ClientEarth, 2020. https://www.clientearth.org/media/eyhjspy5/06-permitreport_1_nov2024.pdf.

Wikipedia

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BibTeX

@techreport{bigg2020chinas, author = {Bigg, Martin and De Boer, Dimitri and He, Rong and Huang, Xueju and Jia, Lei and Kramer, Ludwig and Li, Yuanyuan and Pei, Xiaofei}, title = {{China’s Regulatory Framework on Pollutant Discharge Permits}}, institution = {ClientEarth}, year = {2020}, month = dec, url = {https://www.clientearth.org/media/eyhjspy5/06-permitreport_1_nov2024.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }