Overview
The Ministry of Ecology and Environment (MEE) has recently issued the Opinions on Strengthening Environmental Impact Assessment for Construction Projects Involving New Pollutants in Key Industries (MEE EIA Circular [2025] No. 28, hereinafter referred to as "The Opinions"). This document outlines strict ecological and environmental entry requirements for construction projects in key industries involving new pollutants. It emphasizes the importance of source control for new pollutants, such as Persistent Organic Pollutants (POPs) and Endocrine Disrupting Chemicals (EDCs), during the Environmental Impact Assessment (EIA) phase.
What Projects Are Covered by the Opinions?
Key Industries
The Opinions apply to six major industries: petrochemical, coatings, textile dyeing and printing, rubber, pesticide, and pharmaceutical, as identified in the Action Plan for New Pollutant Control.
Key New Pollutants of Concern
The 14 categories of key controlled new pollutants listed in the List of Key Controlled New Pollutants of Concern. Substances from the Catalogue of Toxic and Hazardous Pollutants (including water, air, and soil pollutants). Chemicals in the List of Priority Controlled Chemicals (covering the first and second batches). Substances listed in the annexes of the Stockholm Convention on Persistent Organic Pollutants. For pollutants with established environmental quality, emission, or monitoring standards, priority evaluation is required. Projects in non-key industries or those in key industries not involving new pollutants are exempt from such evaluations. For projects involving new pollutants, evaluations must align with the Technical Guidelines for Environmental Impact Assessment and the Technical Guidelines for Preparing Environmental Impact Report Forms for Construction Projects.
Re-Linking New Chemical Substance Registration with EIA Approval
The Measures for Environmental Management Registration of New Chemical Substances (MEE Order No. 12) replaced the earlier Order No. 7, removing the requirement for new chemical substance registration as a prerequisite for EIA approval. However, The Opinions now re-establishes this link for key industries. If raw materials or products are identified as new chemical substances under the Inventory of Existing Chemical Substances in China (IECSC), or if existing substances are used beyond their approved purposes, registration under the Measures for Environmental Management Registration of New Chemical Substances is mandatory. This integration ensures early identification of new substances during project planning, reducing non-compliance risks. Enterprises are advised to familiarize themselves with registration requirements, as different substances and tonnage levels demand varying registration types. Early preparation is crucial to avoid delays in EIA approval and project timelines.
Key Provisions in the Opinions
Projects involving substances banned under the Stockholm Convention or listed in the List of Key Controlled New Pollutants will not be approved.
Construction projects must optimize raw materials and processes to minimize new pollutant generation at the source.
New pollutants with emission standards must comply with these standards and be included in pollutant discharge permit management.
For pollutants with environmental quality standards, baseline monitoring and regional environmental quality assessments are required.
For pollutants without quality standards but with monitoring methods, regular monitoring and oversight are mandatory. The Opinions also stress the importance of mid- and post-event supervision, quality reviews of environmental documents, and adherence to environmental management requirements.
Why This Integration Matters
The integration of new substance registration, EIA approval, and pollutant discharge permits marks a significant step forward in environmental protection. By focusing on data sharing, process integration, and risk co-management, this initiative strengthens regulatory oversight.REACH24H Consulting Group advises companies to register new chemical substances before production or import to avoid compliance risks. Synchronizing registration and EIA processes, and utilizing tools like parallel approval, can help reduce costs and ensure full compliance throughout the project lifecycle.
