China China issues pollution control guidance for construction projects

China issues pollution control guidance for construction projects

On May 30, China’s Ministry of Ecology and Environment published on its website the Guiding Opinions on Enhanced Control of Ecological and Environmental Pollution Sources for Energy- and Emission-intensive Construction Projects (关于加强高耗能、高排放建设项目生态环境源头防控的指导意见), demonstrating its intention to rigorously control construction under the pollutant discharge permit system.


The guiding opinions consist of five sections, which are outlined below:

  1. For energy- and emission-intensive construction projects, more detailed management of plans and site selection is needed, and environmental impact assessments (EIA s) should be performed.


  1. Energy- and emission-intensive construction projects need to meet the requirements of ecological and environmental regulations and the regulatory limits on key pollutant discharge and carbon emissions. When a project, such as a chemical manufacturing project, is started or expanded, it must be done in an industrial park where strategic environmental assessments have been performed.


  1. In energy- and emission-intensive projects, advanced manufacturing technology and equipment must be used to lower energy and water consumption per unit product enough to reach an advanced green manufacturing level, and measures must be taken to control soil and underground water contamination. Carbon emissions should be factored into EIAs. In EIAs, pollutants and carbon emissions should be assessed and feasible measures to reduce carbon emissions should be considered.


  1. Tighter management of pollutant discharge permits should be put in place. When ecological and environmental departments screen applicants for a pollution discharge permit, they should assess the applicants for all the items in the EIA report. They should conduct on-site inspections of carefully monitored companies (重点管理的企业) as well. Carefully monitored companies must regularly submit reports on pollutant discharge that is done under a pollutant discharge permit, self-monitored and recorded in a register. These companies must also satisfy other requirements of regulations, including disclosure of environmental information.


  1. Ecological and environmental departments should create an Energy- and Emission-intensive Construction Project Register (“两高” 项目管理台账, or 高耗能、高排放项目管理台账) and enter in this register EIAs received in 2021 or later. They should examine energy- and emission-intensive construction projects based on the information in the register; if unlawful acts are found, they should impose penalties on the offender, including construction project suspension, an order to stop producing or using things, or shutdown, as well as properly punishing responsible people.


The full text of the guiding opinions (in simplified Chinese) is available at


Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting


MSc in Earth Science, The University of Tokyo

AOKI Kenji