Opinions on the Application of Law for the "Production" Concept Specified in the Administrative Regulations on Ozone-Depleting Substances

Opinions on the Application of Law for the "Production" Concept Specified in the Administrative Regulations on Ozone-Depleting Substances
Opinions on the Application of Law for the "Production" Concept Specified in the Administrative Regulations on Ozone-Depleting Substances

Huan Fa Gui Han [2019] No.101

August 30, 2019

Departments (bureaus) of ecology and environment of all provinces, autonomous regions and municipalities directly under the Central Government, Bureau of Ecology and Environment of Xinjiang Production and Construction Corps, and bureaus of ecology and environment of cities with independent planning status and provincial capitals,

Paragraph 1 of Article 3 of the Administrative Regulations on Ozone-Depleting Substances (the "Regulations") stipulates that: "These Regulations shall apply to activities such as production, sale, use, import and export of ozone-depleting substances within the territory of the People's Republic of China." Paragraph 2 stipulates that: "Production as referred to in the preceding paragraph refers to activities that produce ozone-depleting substances." In the process of implementation of the Regulations, there are different views on how to understand and apply the "production" as stipulated in the Regulations.
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