Comments to the MEE's Draft Amendment to the Solid Waste Pollution Prevention Law

2018-08-17 | All chapters

The European Union Chamber of Commerce welcomes the decision of the Ministry of Ecology and Environment to call for comments on the Draft Amendment to the Solid Waste Pollution Prevention Law.  The European Chamber welcomes this Draft Amendment as a step to make solid waste pollution prevention in China more aligned with international practice. There are, however, some aspects that we would like to comment from this Draft Amendment.

First, we suggest the proposed Draft Amendment should take further measures to combine solid waste pollution prevention and control, which means not only to control solid waste pollution, but also to prevent its generation from the source. More specific rules on agricultural and industrial solid waste pollution prevention and control could be added to Chapter III.

Secondly, we suggest encouraging enterprises to develop ecological designs, which comprehensively consider the whole life-cycle of products and packaging, i.e. raw material processing, use, design, manufacture, consumption, disposal and recycling. Therefore, responsible sourcing as well as bio-based materials and renewable raw materials should be further encouraged in the Draft Amendment.

In order to ensure a smooth transition, we propose that the relevant legislative bodies further issue corresponding specific implementation rules, so that the reformed "Solid Waste Pollution Prevention Law" can be effectively implemented. Related documents should be released in order to clarify aspects surrounding standards required by this law for products and materials.