China Law on the Prevention and Control of Environmental Pollution by Solid Waste
ENFORCEMENT TIMELINE
Effective September 1, 2020
Overview
China's "Law on the Prevention and Control of Environmental Pollution by Solid Waste" is a powerful law requiring all manufacturing plants in China to properly sort, store, recycle, and treat industrial solid waste and hazardous waste. It is the legal foundation of China's distinctive green policy achieving "zero waste imports," and imposes fines of up to RMB 1 million (roughly JPY 20 million) for violations of proper on-site storage standards or for entrusting disposal to unlicensed operators. In addition, representatives of companies that improperly entrust waste disposal face administrative detention of up to 15 days.
Enforcement Timeline
- September 2020: The newly revised "Solid Waste Law" took full effect.
- 2023: Traceability was strengthened through integration of provincial industrial waste registration systems with customs systems.
- 2025/2026: Full mandatory implementation of Extended Producer Responsibility (EPR) collection models covering electrical and electronic products, EV batteries, and similar items.
Business Impact
Japanese-affiliated plants in China: Waste-generator responsibility is extremely strict -- if a disposal contractor illegally dumps waste, the plant that entrusted the disposal also bears full joint liability (substantial remediation costs and risk of the representative's detention). Thorough license audits and manifest management of local disposal contractors are therefore essential.
