"Batch of small and large" should appear in the official document "Measures for the Implementation of Capacity Replacement in Cement and Glass Industry" (Ministry of Industry and Information Technology [2017] 337). According to the document, enterprises that fail to implement the capacity replacement plan, commit fraud and "approve small and build large" should be notified of their dishonest behavior and promote the implementation of joint punishment. In its policy interpretation, it is further stated that, in view of the phenomenon of "approving small projects to build large ones" in the construction of cement clinker projects, in order to advocate trustworthiness and compliance with laws and regulations, the implementation measures stipulate that the capacity indicators used for replacement shall be determined according to the design capacity on the project filing or approval documents. If the actual capacity is less than registered or approved capacity, it shall be determined according to the actual capacity. The actual production capacity continues to be calculated according to the schedule of the original method, but in order to avoid the problem of confusing the inner diameter and outer diameter of the rotary kiln when calculating the production capacity of cement clinker, the implementation method strictly requires that the outer diameter of the rotary kiln be calculated (that is, patching).
Previously, the Measures for the Implementation of Capacity Replacement in Some Industries with Serious Overcapacity (Industry [2014] No.296 of the Ministry of Industry and Information Technology) only made it clear that the number of eliminated projects was approved in accordance with the capacity conversion table (attached). The Measures for the Implementation of Capacity Replacement in Some Industries with Serious Overcapacity (Industry [2015] No.127 of the Ministry of Industry and Information Technology) only specifies the number of capacity of construction projects and the number of capacity to be eliminated after 2015, which is approved in accordance with the (attached) conversion table, but the capacity of construction projects should also be converted according to the kiln diameter. This conversion operation leads to the calculation of new cement clinker projects in the industry in terms of production capacity and kiln diameter, and everyone is afraid of suffering losses.
Since the 2017 edition of the implementation measures for capacity replacement in the cement and glass industry, there has been a saying of "approving small and building large", and in January 2020, when the administrative interpretation of "Operational Questions and Answers on the Implementation Measures for Capacity Replacement in the Cement and Glass Industry" was made, the difference of "approving small and building large" was included in the scope of capacity replacement projects. However, it is clear that the problems caused by the inconsistency between kiln diameter and production capacity before the issuance of the Notice of the Ministry of Industry and Information Technology on the Replacement of Production Capacity in Some Industries with Serious Overcapacity (MIIT Industry [2014] No.296) are excluded. "Operational Questions and Answers" also clearly States that the scale of capacity indicators used for replacement shall be determined according to the design capacity on the project filing or approval documents. If the actual capacity is less than filing or approval capacity, it shall be determined according to the actual capacity, and the actual capacity of the project shall be calculated according to the schedule. The Measures for the Implementation of Capacity Replacement in the
Cement and Glass Industry (original [2021] No.80 of the Ministry of Industry and Information Technology) is the same as the previous documents, and the capacity indicators used for replacement are determined according to the design capacity on the project filing or approval documents. If the actual capacity is less than registered or approved capacity, it shall be determined according to the actual capacity, and if the actual capacity is greater than registered or approved capacity, it shall be determined according to the registered or approved capacity. The actual production capacity of the project is calculated and determined according to the attached table. For the first time, it is proposed to punish the existence of fraud and "approving small projects to build large ones", and to punish them clearly in accordance with the relevant requirements of the Regulations on the Approval and Filing of Enterprise Investment Projects, and not to ignite and put into operation before the rectification is in place. The Regulations on the Administration of Approval and Filing of
Enterprise Investment Projects (Decree No.673 of the State Council) stipulates that those who provide false information to the filing authority shall be ordered by the filing authority to make corrections within a time limit; those who fail to make corrections within the time limit shall be fined not less than 20,000 yuan but not more than 50,000 yuan.
From the provisions of the above documents, it can be concluded that "approval of small and construction of large" means that the capacity of the record (or approval) is small, while the size of the main equipment (rotary kiln) used in the project is large. In order to determine whether the project is a "batch of small and large", a rule has been formulated, that is, to compare the project record capacity with the actual capacity calculated according to the kiln diameter. According to the kiln diameter, when the actual production capacity is greater than record production capacity, it can be basically identified as "small batch and large construction". Before July 10, 2014, the problems caused by the inconsistency between kiln diameter and production capacity ( "approving small and building large") projects will not be traced back.
On June 21 and 22, Shandong Province made public the sixteenth batch of 219 letters and visits and the seventeenth batch of 194 letters and visits handed over by the Third Central Eco-environmental Protection Supervision Group. The letters and visits reflect the environmental problems of cement enterprises. The more prominent problems reflected are "approving small and building large" and long-term illegal overproduction. In the two batches of letters and visits, 22 enterprises were reported to have "approved small and built large". After investigation and verification, there is no problem of "approving small and building large". The reason is that the marked rotary kiln model is consistent with the actual construction situation, or the kiln diameter of the enterprise meets the policy requirements, or the rotary kiln specification does not exceed the requirements of the EIA approval after on-site verification, or the kiln diameter of the rotary kiln equipment actually installed by the enterprise is consistent with the EIA approval; Or the EIA document specifies that the design diameter of the cement kiln is the same as the diameter of the actual rotary kiln equipment, and the production facilities have not changed since the construction. Therefore, the conclusion is that as long as we can build as big as we can, there will be no problem of "building as big as we can.". This is a bit different from the industry's general understanding of "building big with small batches". The Measures for the Implementation of Capacity Replacement in the
Cement and Glass Industry (Version 2024) (original [2024] No.206 of the Ministry of Industry and Information Technology) is to improve the way of capacity verification, cancel the provisions of capacity verification based on the diameter of cement rotary kilns, and promote the unification of registered capacity and actual capacity. Because with the continuous progress of production technology and equipment level, the production capacity approved solely on the basis of the diameter of cement rotary kiln can no longer reflect the actual production capacity. The Implementation Measures make it clear that the production capacity is determined strictly according to the project filing (approval) documents, and the annual production capacity days are calculated according to 300 days. In order to promote the unification of the registered production capacity and the actual production capacity, for the compliance production lines whose actual production capacity is greater than registered production capacity, the difference in production capacity can be supplemented and the relevant procedures such as filing, environmental assessment and energy assessment can be improved in accordance with these Measures. There is no concept of "approving small and building large" in
the Implementation Measures (2024 edition), but only for the compliance production lines whose actual capacity is greater than registered capacity, there is a statement that the difference in capacity should be made up. Therefore, as for the inconsistency between kiln diameter and production capacity before July 10, 2014, the problem of "approving small and building large" no longer exists.
However, if the actual production capacity is significantly greater than record production capacity, although it can not be identified as "batch of small and large", but the production line to fill the balance of production capacity should be clearly included in the rectification requirements. There are two of the
reported production lines:
one is the 4000 t/d cement clinker production line approved in 2007 and completed in 2011, with a cement kiln diameter of 5.2m (according to the list of clinker production lines published by the province);
A 4000 t/d cement clinker production line was approved in 2007 and completed in 2012, with a cement kiln diameter of 5 m. If
these two production lines are calculated according to the previous conversion table, the corresponding clinker production capacity is 6000 t/d and 5500 t/d respectively. Exceed the approved capacity by 50% and 38%. In fact, it belongs to the category of "approving small and building large", although it can not be traced back, but shouldn't it be included in the rectification requirements to make up for the difference in production capacity? According to the data verified by the public survey, the daily production capacity in 2024 reached 7800 t/d and 5846 t/d respectively. It exceeds the approved capacity by 95% and 46%. The former has a production data of about 8000 t/d from January to May 2025, and its daily production capacity reaches 200% of the approved capacity. It is not too much to say that the building is "big"! What
is even more surprising is that the investigation and verification of the 5.2m production line of the kiln shows that the project obtained the environmental impact assessment approval (Lu Huan Shen [2007] No.41) on March 22, 2007, and the environmental impact assessment approved the construction of a 4.7 * 72 m rotary kiln. The company was completed and put into operation in December 2011, and completed the independent acceptance of environmental protection for the completion of the construction project on September 1, 2020. The difference of the kiln diameter of the production line between the EIA approval and the list is as much as 0.5m. What is even more puzzling is that the independent acceptance of environmental protection for the completion of the construction project will be completed eight years after the completion of the project. (Note: If the project is completed and put into operation in December 2011, it should have been completed and accepted by the competent environmental protection department.) In this way, the construction project without acceptance has been put into production or used for 8 years.
For example, when investigating and verifying the contents of the report of "approving small and building big", we only make a policy public reply to the report of "approving small and building big", and the derived problems that may involve environmental violations should not be traced? Is it not necessary to make up for the difference in production capacity rectification for the "approval of small and construction of large" without traceability?
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