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The latest version of the Inventory of Hazardous Wastes was published in March 2016. The new version became effective on Aug 1st 2016 and included significant changes compared to its predecessor, the 2008 version. However, industry has encountered some problems relating to the implementation of the Inventory, especially issues relating to solid wastes which are regarded as hazardous but are excluded from the inventory. Recently, Shanghai Environmental Protection Bureau (SEPB) issued a notice clarifying many issues and answering these questions
SEPB stated that the official reply to the environmental impact assessment report should be the foundation for the determination of whether a solid waste is regarded as hazardous waste. In a factory or a construction project, if a solid waste was determined as hazardous waste in the official reply, then it should still be treated as hazardous waste now, even if it is removed from the latest Inventory. If the solid waste was not in the former version of the Inventory but was assessed and regulated as hazardous waste, then it should still be treated as hazardous waste now.
If a solid waste is not in the latest Inventory and the enterprise cannot be sure of whether it is hazardous, the enterprise should entrust Shanghai Solid Waste Management Center to conduct evaluation and identification.
Shanghai has developed the most advanced chemical management system in China. It is the first pilot city for China’s new chemicals post-notification supervision and its policies on hazardous substances and VOCs control is the model for other provinces and cities. So for enterprises outside Shanghai, we recommend that they should follow SEPB’s guidelines when dealing with hazardous wastes, if there are no specific requirements from local governments.
