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Petrochemicals, Chemicals and Refining (PCR) Working Group
Key Recommendations
1. Standardise Penalties Imposed on Pollutants in the Chemical Industry
• Provide guidance on how to adjust operations in order to adhere to local emission standards, and
recommend third-party agents to advise on local compliance issues.
• Set up a corresponding punishment mechanism for each specific market, and regulate the
environmental services market.
• Examine the Articles 21, 22 and 23 of the Environmental Protection Law (EPL) in terms of its
operability, rather than focusing on the macroscopic description.1
2. Optimise the Allocation Methodology in China’s Emissions Trading System
(ETS) to Encourage Advanced Technologies in the Chemical Industry
• Involve industry experts in the detailed definition of China’s ETS related to the chemical industry.
• Establish a fair and consistent process—from one region to another, from expansion to new
projects—for initial free allocation, reflecting the nature of industries, the energy intensity of
installations and technological levels.
• Invite industry experts to work out fuel-specific emissions benchmarks per unit product for the
chemical industry so that grandfathering or tons of CO2 per gross domestic product (GDP) (tCO2/
CNY 10,000) output can be substituted for free allowances allocation.
3. Reduce Data Requirements on New Chemical Notification for Intermediates
in China
• Recognise that intermediates present a lower risk than other regular substances.
• Revise current data requirements on intermediates to treat isolated-intermediates as a special group
of substances, and lower their notification requirements.
4. Promote Legislation to Optimise Administration on Hazardous Chemicals
(HCs)
• Clarify the administration scope of relevant licence/permit/registration applications—especially for
distribution, storage, production and transportation¬—and publish the corresponding guidelines to
ensure regulatory compliance of all industry players.
• Complete supporting documents related to identification of hazardous physical property, and
publicise the “Inventory exempted from identification”.
• Adopt international, advanced practices on chemical identification and classification, for example
(EC) No. 1272/2008 on Classification, Labelling and Packaging (CLP).
• Accept classification results from companies for pure substances and mixtures based on reliable
resources such as Good Laboratory Practice (GLP) laboratories, worldwide authoritative databases
and the technical United Nations (UN) calculation principle for the Globally Harmonised System
(GHS) of classification.
• Accept compliant material safety data sheets (MSDS) based on the Safety Data Sheet for Chemical
Products (GB/T 16483-2008), and continue implementing the transition period for the 2013
1 Environmental Protection Law of the People’s Republic of China, Ministry of Environmental Protection, 25th
April, 2014, viewed 29th
April, 2015, <http://www.gov.cn/
xinwen/2014-04/25/content_2666328.htm>
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Guidance on Compilation of Safety Data Sheet for Chemical Products (GB 17519-2013).
• Award appropriate exemptions for the import of low volume hazardous chemicals (HCs) for laboratory
and research and development (R&D) usage.
5. Take Prudent Steps in Consumption Tax Reform
• Publicise the selection criteria and list of potential categories that may be subject to consumption tax
for public opinion.
• Involve experts to discuss the standards and measurement of particular matters (e.g. consumption
tax rate, tax production stage or retail stage) according to the current development of chemical
industry in China.
• Involve industry experts to analyse the impact of the draft consumption tax reform on related
enterprises and end customers.
Introduction to the Working Group
The Petrochemicals, Chemicals and Refining (PCR)
Working Group represents the leading European
companies in the petroleum and chemical industry in
China, many of which are global Fortune 500 companies.
The aim of the working group is to help our members
adapt to the China market by facilitating communication
between the member companies, and the government as
well as Chinese industrial associations, providing up-to-
date information and presenting common challenges and
making recommendations on regulatory issues.
Recent Developments
The working group has a continued strategic dialogue
with the Chinese Government and relevant institutions,
including high-level meetings with Chinese and European
authorities, such as: the Ministry of Environmental
Protection (MEP); the Ministry of Commerce (MOFCOM);
the State Administration of Taxation (SAT); the State Food
and Drug Administration (SFDA); the China Petroleum
and Chemical Industry Federation (CPCIF); the State
Administration of Quality Supervision, Inspection and
Quarantine (AQSIQ); and senior European Commission
(EC) officials.
The working group greatly appreciates both the
constructive dialogue between European industry and
Chinese officials, and the market-driven orientation of
much of the new domestic legislation regulating the
PCR industry.
The Petrochemicals, Chemicals and Refining Working
Group is keen to continue constructive dialogues with all
relevant Chinese ministries and institutions and to bring
in relevant expertise in terms of the latest technologies,
as well as best available techniques, for both industrial
practises and regulatory approaches.
Key Recommendations
1. Standardise Penalties Imposed on Pollutants
in the Chemical Industry
Concern
Local governments are setting stringent local pollutant
discharge standards for pollutants not specified in
the national pollutant discharge standards, which has
created a complex series of emissions standards across
different provinces and municipalities.
Assessment
According to Article 16 of Environmental Protection
Law of the People’s Republic of China, the people’s
governments of provinces, autonomous regions, and
municipalities directly under the central government
may establish their local standards for the pollutant
discharge of items not specified in the national pollutant
discharge standards and may set local pollutant
discharge standards that are more stringent than the
national ones.
In light of this clause and their own environmental
capacities, provinces and municipalities can create
their own legislation for a series of emissions standards
of pollutants. For instance, the Shanghai Municipal
Environmental Protection Bureau and the Shanghai
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Third Plenum Reality Check
What did the Third Plenum’s Decision2
say?
What is the reality?
We will persist in equality of rights,
opportunities and rules, abolish all
forms of irrational regulations for
the non-public economy, remove all
hidden barriers, and adopt specific
measures for non-public enterprises
to enter franchising fields.
Over the past two years, with the streamlining of government
approvals, the scope of projects requiring government approvals
has narrowed, and more project approval power is now controlled
by local governments. Working group members hope that this will
help to shorten the project approval time for their investments, and
that the central government will strengthen “overall balancing” to
minimise the risk of overcapacity.
The National Layout Plan for seven major petrochemical parks
was adopted by the State Council in June 2014. Private firms
have been granted more access to invest in refinery, cracker and
downstream products in these parks. Working group members hope
that the Chinese Government will publicise more details of this plan.
In the revised Foreign Investment Industrial Guidance Catalogue
promulgated in March 2015, caps on equity ratios for foreign direct
investment (FDI) have been removed for sectors like cracker and
refinery. Working group members see more opportunities in cracker
downstream investments.
Any price that can be determined by
the market must be left to the market,
and the government is not to carry
out improper interventions. We will
push ahead with pricing reforms of
water, oil, natural gas, electricity,
transportation, telecommunications
and some other sectors while relaxing
price control in competitive areas.
The price of natural gas increased unexpectedly in 2014. This placed
a severe burden on the operations of Petrochemicals, Chemicals
and Refining Working Group members’ facilities that use natural gas
a raw material. On top of that, more factors such as the increased
consumption tax on naphtha and other petrochemical feedstocks,
increasing costs for hazardous waste treatment, adoption of
consumption tax on chemicals like coatings, the introduction of the
national emissions trading scheme (ETS) (to be launched in 2016),
environmental and carbon taxes, all combine to create additional
cost burdens for working group members’ investments in China.
We will encourage non-public
enterprises to participate in SOE
reform, foster mixed enterprises with
non-public capital as the controlling
shareholder, and encourage qualified
private enterprises to establish the
modern corporate system.
Working group members noted positive developments in the reform
of ‘mixed ownership’ in central SOEs, and the promotion of the
public-private partnerships (PPP) model in sectors like infrastructure
and environmental protection.
We will have the same laws and regulations
on Chinese and foreign investment, and
keep foreign investment policies stable,
transparent and predictable.
Working group members noted China’s progress in adopting
negative lists in pilots FTZs and the drafting of Foreign Investment
Law.
2 The Third Plenum of the 18th
National Congress of the Communist Party of China Central Committee was held in November 2013, and concluded with a decision laying out
new economic and policy initiatives – the Decision.
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Bureau of Quality and Technical Supervision released
the Air Pollutant Emissions Standards in the Printing
Industry (DB 31/872-2015) in the first quarter of this
year. They proposed the limitation of the maximum
allowable emissions concentration and maximum
allowable emissions rate on five types of substances
related to the printing industry: benzene, toluene,
xylene, non-methane hydrocarbon and particulate
matter. These standards are mandatory for any new
formulation. Enterprises guilty of discharging pollutants
exceeding the standards will incur a penalty of Chinese
Yuan (CNY) 8,000 per ton for every day they continue
to pollute.
Enterprises are at risk of involuntarily violating local
emissions standards due to this complex regional
legislation. Also, it can be difficult and costly to adjust
operations to local standards whilst trying to supply the
entire market. Access to clear and coherent guidance
on local emissions standards is not easily accessible
making compliance unnecessarily difficult and
potentially costly.
Recommendation
• Provide guidance on how to adjust operations in order
to adhere to local emission standards, and recommend
third-party agents to advise on local compliance issues.
• Set up a corresponding punishment mechanism for
each specific market, and regulate the environmental
services market.
• Examine the Articles 21, 22 and 23 of the EPL in
terms of its operability, rather than focusing on the
macroscopic description.
2. Optimise the Allocation methodology in
China’s Emissions Trading System (ETS)
to Encourage Advanced Technologies in
the Chemical Industry.
Concern
The Chinese ETS is underdeveloped in comparison
to international equivalents: without properly taking
into account the chemical sector’s specificities and
its sub-sectors’ heterogeneity, ETS rules can (i)
introduce undue biases among similar activities, (ii)
lead to counter-effective outcomes and (iii) favour more
emitting technologies over efficient ones.
Assessment
Under the current rules of China’s ETS, allocation of
free allowances is mostly based on historical emissions
levels for petrochemical and chemical sectors. Whereas
petro-chemical multinational corporations (MNCs) have
invested in the most efficient plants with best available
technologies (BAT), under current ETS policies based
on historical emission levels those players are put at a
disadvantage compared to their peers who would have
invested in low-cost, less-efficient technologies. This
allows historically high polluting companies to become
more competitive while only slightly improving their
operations and still emitting more CO2 than those with
a BAT. In other words the Grandfathering scheme is not
fair.
Moreover, under the current rules, capacity expansions
or debottlenecking on existing installations are treated
differently (grandfathering) to new projects (benchmarking).
This may have a counter-effective impact as it would
discourage investment in expansion plans that could
improve efficiency.
The working group welcomes the decision to have
the Chinese ETS evolve into a ‘benchmark’ for future
allocation methodology. The European Chamber regrets
that the current proposed outcome of the benchmarking
process (a general output ratio expressed in tCO2/
RMB) does not accurately reflect the energy efficiency
of the production processes within the petrochemical
and chemical industry.
Due to the diversity of its industry, the working group
is advocating for a benchmark methodology similar
to what has been applied in other regions, such as in
Europe. Such a benchmark would be done by category
of products, thereby differentiating the most energy-
intensive sub-sectors (ammonia, ethylene oxide,
industrial gases, nitric acid) from the less energy
intensive ones, based on BAT for the available fuel/
feedstock (e.g. coal, natural gas). This measure would
improve extraction efficiency and create added value
from resources.
Petrochemicals and chemicals are by nature energy
and carbon intensive, but indispensable as a pillar of
the economy. Without a fuel-specific benchmark by
product, the ETS will not encourage the deployment
of energy-efficient and low-emitting technologies, and
will limit the development of the necessary industrial
infrastructure in China.
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The Chinese ETS is in a crucial phase of design and
testing. Fair treatment for initial free emissions allowances
allocation is fundamental to the long-term success of
the scheme. It is also essential that the scheme be
applied consistently throughout the country under a
clear allocation policy that will guide the implementation
within the different regions. Petrochemical, Chemical and
Refining Working Group members have rich experience
in a wide variety of issues in these fields, both in the EU
and globally, and can assist the Chinese Government in
this regard.
Recommendation
• Involve industry experts in the detailed definition of
China’s ETS related to the chemical industry.
• Establish a fair and consistent process—from one
region to another, from expansion to new projects—for
initial free allocation, reflecting the nature of industries,
the energy intensity of installations and technological
levels.
• Invite industry experts to work out fuel-specific
emissions benchmarks per unit product for the
chemical industry so that grandfathering or tons of
CO2 per gross domestic product (GDP) (tCO2/Chinese
Yuan (CNY)3
10,000) output can be substituted for free
allowances allocation.
3. Reduce Data Requirements on New
Chemical Notification for Intermediates
in China
Concern
The data requirements for notifying a new intermediate
in China are the most stringent in the world and the time
taken for notification is the longest, which puts Chinese
intermediate manufacturers at a big disadvantage.
Assessment
Chemical intermediates are a common necessity during
the synthesis of many products such as pesticides,
pharmaceuticals, cosmetics and dyes. Industrial
applications usually require intermediates to be produced
in high volumes. An intermediate is a chemical substance
that is only produced in order to be consumed in a
subsequent chemical reaction. As such, an intermediate
is only handled in the industrial setting and will—due to
its consumption in the reaction—not be used as a direct
ingredient in formulations, and the exposure will be very
low. For some intermediates there are even dedicated
3 In China, for the measurement tons of CO2 per GDP (tCO2/GDP), GDP equates
to CNY 10,000.
technical and organisational measures in place to keep
the substance contained and controlled. To reduce the
data requirements for the registration of intermediates
is therefore a process that follows the scientific principle
that risk is a function of hazard and exposure. Low
exposure lowers the resulting risk. Good regulatory
practice benefits from such principles by balancing the
regulatory burden through effective provisions in order
to protect human health and the environment. That was
the reason why reduced registration requirements were
introduced into almost all chemical regulations in the
world.
The current guidance for New Chemical Notification
does not differentiate an intermediate (manufactured
or imported in annual quantities greater than one ton
(>1t/y)) from a regular substance in terms of notification
data requirements, which is unusual when compared
to international chemical regulations. The European
Chamber hopes the Ministry of Environmental
Protection (MEP) can consider the special situation
of lower exposure risk of intermediates which will be
consumed in further reactions, and difficulties faced
by the industries in treating isolated-intermediates as
a special group of substances, and therefore lower
their notification requirements for the companies with
proper exposure management measures. Differentiating
intermediates from general substances and lowering
registration requirements for intermediates will align
with the MEP's chemical risk management guidelines,
making it more refined and scientific. Enterprises who
wish to benefit from reduced registration requirements
must provide strict risk management measures to
reduce exposure and commit to implementing them,
thereby reduced registration requirements can result
from the scientific basis that a substance poses a lower
risk if the exposure is lower. Enhanced supervision on
the annual reporting of intermediates and downstream
manufacturers’ clarification can be initiated by the
relevant authority to ensure that the reduced registration
requirements are not claimed incorrectly.
Intermediates are distinguished from other substances
and different provisions on reduced requirements for
intermediates exist in other major industrial countries
and regions including the United States (US), the
European Union (EU), Switzerland, Canada and Japan.
For example, the provisions below are implemented in
the European Regulation on Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH):
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Type of Intermediates Registration Requirement Notes
Non-isolated intermediates Exempt
On-site isolated intermediates
manufactured or used under
strictly-controlled conditions
<1 ton: exempt from registration.
1-1,000 tons: only existing
data is required.
>1,000 ton: only need to follow
the 1-10t/y standard registration
requirement.
Reduced data requirements;
if the intermediates are sold, the
manufacturer or importer needs confirmation
from the customer that they observed that
the conditions were strictly controlled.
Transported isolated intermediates
manufactured or used under strictly-
controlled conditions
Isolated intermediates that are not
manufactured or used under strictly-
controlled conditions
Standard registration requirement
according to 4 tonnage levels.
Data requirements on standards registration is
less than those stipulated in the Environmental
Management Measures on New Chemical
Substances (2010 revision)
Order No. 7 of the Ministry of Environmental
Protection.
Recommendations
• Recognise that intermediates present a lower risk than
other regular substances.
• Revise current data requirements on intermediates
to treat isolated-intermediates as a special group of
substances, and lower their notification requirements.
4. Promote Legislation to Optimise
Administration on Hazardous Chemicals
(HCs)
Concern
The Catalogue of Hazardous Chemicals (2015 Version)
implemented on 1st
May, 2015, introduces Globally
Harmonised System (GHS) classification and the
building block principle in addition to 2,828 listed items,
which greatly exceeds the scope and compliance
requirements of previous versions.
Assessment
Under State Council decree 591 (Regulations on Safe
Management of Hazardous Chemicals), hazardous
chemicals in the Catalogue of Hazardous Chemicals
must meet the safety management requirements for HC
production, storage, use, operation and transportation.
This regulation implements a licensing system for
producers/operators/users of hazardous chemicals in
Catalogue. The scope of the Catalogue of Hazardous
Chemicals will directly influence the controlled scope
of relevant licensing and registration applications,
e.g. the safety production licence, the trading licence,
hazardous chemical registration, etc. Though the
2015 version appears smaller in size compared with
its 2002 predecessor (total items have been reduced
from 2,936 to 2,828),4
the actual scope has expanded
with the introduction of the ‘building brick’ principle.
The application scope of each relevant permit/
licence/registration is ambiguous and will impede HC
compliance procedures in China.
So far the corresponding guideline of the 2015
catalogue includes GHS classification information, but
the United Nations (UN) number has not been released.
Meanwhile, the “Inventory exempted from identification”
mentioned in Method No. 66 for hazardous chemicals
has been delayed several times, which has led to
unnecessary workload for companies who now have to
identify the hazardous chemicals within officially-known
hazard classifications.
Material safety data sheets (MSDS) play a significant
4 The new catalogue of hazardous chemicals will come into effect on May 1, China
Quality News, 30th
March, viewed 30th
April, 2015, <http://www.cqn.com.cn/news/
zggmsb/diliu/1021450.html>
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role in HCs registration. The Safety Data Sheet for
Chemical Products Content and Order of Sections (GB
16483-2008)5
was set up to define the structure, content
and generic forms of the Safety Data Sheet (SDS). In
September 2013, GB 17519-20136
was issued and
serves as the supporting document to GB 16483-
2008, which introduced more stringent rules to cover
MSDS format and content. It appears vastly changed
compared with the previous version. Even though GB
17519 is a recommended standard, it is still taken as a
mandatory requirement in some inspection processes.
Since the MSDS maintenance and management of
most multinational chemical companies relies on a
complex and comprehensive SAP Enterprise Resource
Planning (ERP) software system, even a minor change
of the MSDS results in high costs in system adjustment.
Multi-level administration of HCs registration for large-
scale industry use and for research and development
(R&D) use should be applied in a way that is consistent
with similar international and domestic regulations
(e.g. REACH, the MEP’s Environmental Management
Measures on New Chemical Substances (2010 revision)
Order No. 7).
Current requirements for registration procedures for
regular chemicals, such as waiving registration for HCs
for quantities less than 1t/y, should be revised for R&D
use for the purpose of cost savings, workload reduction
and to control supply chain shortage risks.
Recommendations
• Clarify the administration scope of relevant licence/
permit/registration applications—especially for
distribution, storage, production and transportation¬—
and publish the corresponding guidelines to ensure
regulatory compliance of all industry players.
• Complete supporting documents related to identification
of hazardous physical property, and publicise the
“Inventory exempted from identification”.
• Adopt international, advanced practices on chemical
identification and classification, for example (EC) No
1272/2008 on Classification, Labelling and Packing
5 Safety data sheet for chemical products-Content and order of sections, 18th
June, 2008, Ministry of Industry and Information Technology, viewed 30th
April,
2015, <http://www.miit.gov.cn/n11293472/n11293877/n14505342/n14506895/
n14514379/14514476.html>
6 Guidance on the compilation of safety data sheet for chemical products,
Standardisation Administration of the People's Republic of China, 6th
September,
2015, viewed 30th
April, 2015, <http://www.sac.gov.cn/SACSearch/search
?channelid=160591&templet=gjcxjg_detail.jsp&searchword=STANDARD_
CODE=%27GB/T 17519-2013%27>
(CLP).
• Accept classification results from companies for pure
substances and mixtures based on reliable resources
such as GLP laboratories, worldwide authoritative
databases and the technical United Nations (UN)
calculation principle for the GHS of classification.
• Accept compliant MSDS based on the Safety Data
Sheet for Chemical Products (GB/T 16483-2008), and
continue implementing the transition period for the
2013 Guidance on Compilation of Safety Data Sheet
for Chemical Products (GB 17519-2013).
• Award appropriate exemptions for the import of low
volume HCs for laboratory and R&D usage.
5. Take Prudent Steps in Consumption Tax
Reform
Concern
The reform of consumption tax and the introduction of
environment taxes, as proposed by the Third Plenum
in 2013, needs a solid impact assessment in order to
incentivise the industry to develop energy-saving and
environmental procedures and minimise the impact on
consumers.7
Assessment
A consumption tax was firstly imposed in 1994 on
consumer goods that have a high energy cost to produce
and are highly polluting, in order to guide production
and consumption toward being environmentally-friendly
and to promote a sustainable economic growth model.8
Tax adjustment of petroleum products is a global trend
and underlines the urgent need to promote a green
economy worldwide. Recently, China announced that it
will impose consumption tax on some chemical-related
products, such as certain types of batteries and paint,
which are currently not subject to consumption tax
in China, and raise consumption tax rate on some
products to encourage environmental protection and
sustainable development.9
While this is a welcome
step towards a more sustainable and environmentally-
7 Notice on the 12th
Five-year Plan about the State Environmental Protection,
State Council, 2011, viewed 14th
April, 2015, <http://www.gov.cn/zwgk/2011-
12/20/content_2024895.htm> (Alternatively: Expert: Green taxes meet a difficult
in the choosing time and the early effect is not too big, China Environment, 6th
December, 2010, viewed 14th
April, 2015 <http://www.chinaenvironment.com/
view/viewnews.aspx?k=20101206171437500>)
8 The Interim Regulations on Consumption Tax of the People's Republic of China,
SAT, 1993, implemented 1st
January, 1994, viewed 14th
April, 2015, <http://
hd.chinatax.gov.cn/guoshui/action/GetArticleView1.do?id=547&flag=1>
9 Notice on New Consumption Tax of Battery Coating, SAT & MOF, 2015, viewed
14th
April, 2015, <http://www.chinatax.gov.cn/n810341/n810755/c1489741/
content.html>
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friendly development model, there are concerns about
efficiency and equality in the application of the revised
consumption tax.
In November 2014, the Ministry of Finance (MOF) and
the State Administration of Taxation (SAT) announced
that it will impose consumption tax on crude oil products
to help cut emissions and boost the green economy.10
The tax involves other petroleum products including
naphtha, lubricating oil and jet fuel, while small-
displacement motorcycles, tyres and ethyl alcohol were
exempted in order to reduce burdens on the low and
middle-income group.
It is counterproductive to impose a blanket consumption
tax on chemical enterprises without taking into account
the individual company’s environmental record in terms
of energy use and pollutant emissions. It is in the
interests of the industry to promote a tax system that
incentivises environmentally-friendly business practices.
In light of the adjustment on petrochemical-related
products, boosting consumption tax may not satisfy
the goal of more efficient social income redistribution.
Most enterprises in the chemical industry are aware of
their social responsibilities in terms of environmental
impact. Therefore, it is counterintuitive not to align
environmental best practices with profit, i.e. lower
consumption tax for lower emissions. Otherwise, an
increased tax liability for enterprises will ultimately be
passed onto customers in the form of higher prices.
Recommendations
• Publicise the selection criteria and list of potential
categories that may be subject to consumption tax for
public opinion.
• Involve experts to discuss the standards and measurement
of particular matters (e.g. consumption tax rate, tax
production stage or retail stage) according to the current
development of chemical industry in China.
• Involve industry experts to analyse the impact of the
draft consumption tax reform on related enterprises and
end customers.
10 Notice on the Further Increase on Consumption Tax of Oil Products, SAT &
MOF, 2015, viewed 14th
April, 2015, <http://www.gov.cn/xinwen/2015-01/12/
content_2803343.htm>
Abbreviations
CNY Chinese Yuan
CLP Classification, Labelling and Packaging
ERP Enterprise Resource Planning
ETS Emissions Trading System
EPL Environmental Protection Law
EC European Commission
EU European Union
FTZs Free Trade Zones
GHS Globally Harmonised System
GLP Good Laboratory Practice
GDP Gross Domestic Product
HCs Hazardous Chemicals
MSDS Material Safety Data Sheets
MOFCOM Ministry of Commerce
MEP Ministry of Environmental Protection
MOF Ministry of Finance
MNCs Multinational Corporations
PCR Petrochemicals, Chemicals and Refining
PPP Public-Private Partnerships
REACH Registration, Evaluation, Authorisation
and Restriction of Chemicals
R&D Research and Development
SDS Safety Data Sheet
SAP Standard Assessment Procedure
AQSIQ StateAdministration of Quality Supervision,
Inspection and Quarantine
SAT State Administration of Taxation
SFDA State Food and Drug Administration
UN United Nations
US United States