CHINA Trends and Developments Contributed by: Rongliang Wu, Mei Wan, Qirong Huang and Xueqi Huang, Jin Mao Law Firm
Implementation of pollutant discharge permit system The pollutant discharge permit (PDP) is a certificate that contains all environmental management require- ments for the production and operation period. The PDP has become the main basis for enforcement supervision by the authorities at the MEE. There are three types of PDP: • permit with focused management; • permit with simplified management; and • emissions registration. The PDP covers information such as production pro- cesses, the discharging points, the emission con- centration limits and quotas, and the self-monitoring requirements (online and manual). In 2025, the MEE issued the Implementation Plan for the Full Implementation of the Pollutant Discharge Permit System (the “Implementation Plan”). This pro- posed the implementation path for the construction of the core pollutant discharge permit system. With the improvement of eco-environmental quality as the main line, the Implementation Plan puts forward paths for linking the PDP system with other systems, including environmental impact assessment, total emission control, self-monitoring, eco-environmental law enforcement, eco-environmental statistics, and environmental protection tax. These efforts aim to implement the PDP system as the core supervision system for stationary pollution sources. Implementation of PDPs As per the requirements, enterprises must disclose the implementation information (including the quar- terly implementation report and annual implementa- tion report) on the national administrative online plat- form. The authorities at the MEE will keep track of the information uploaded by the enterprises to improve the efficiency of their supervision. Anyone can access the online platform and some basic information is also available to the public.
Recommendations for PDP owners In order to better cope with the law enforcement trend of a “one permit” governance system, enterprises with PDPs should focus on the following main aspects. • Information checking – the information on the PDP should be compared with the environmental impact assessment (EIA) document, the on-site situation and the relevant standards. • Pollutant emission and total control – the emission concentration of pollution factors should meet the corresponding standard and the total emissions should not exceed the quota listed on the PDP. • Environmental monitoring – enterprises should conduct the routine environment monitoring and record findings as required by the PDP. • Document management – the details of the envi- ronmental management ledger should be recorded properly and should be kept for at least five years. • Submission of reports – annual reports are due before January 15th each year and quarterly reports are due before April 15th, July 15th and October 15th each year. Carbon regulations and standards advancing in tandem as national carbon market expands On 24 September 2025, addressing the UN Cli- mate Change Summit by video, China’s head of state unveiled the country’s new round of nationally determined contributions. By 2035, economy-wide net greenhouse gas (GHG) emissions will be cut by 7–10% below their peak, with every effort to exceed this target. Carbon-related policies, regulations and standards advance on multiple tracks In August 2025, the General Offices of the Communist Party of China (CPC) Central Committee and the State Council released the first-ever central-level document, Opinions on Promoting Green and Low-Carbon Trans- formation and Strengthening the National Carbon Market. This positioned the carbon market at the core of China’s “dual-carbon” goal and set targets to cover all major industrial emitters by 2027 and to establish an internationally aligned carbon-pricing mechanism by 2030.
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