Ask: Does the industry say that the production line needs to be re-evaluated and re-evaluated to make up for its production capacity?
Answer: In the industry, the term "production line supplementary capacity" refers to the compliance production line whose actual capacity is greater than registered capacity, which can be supplemented according to the Measures for the Implementation of Capacity Replacement in the Cement and Glass Industry (2024). It is necessary to formulate a capacity replacement plan to
make up for the difference in capacity. The Measures stipulate that within two years from the date of announcement of the capacity replacement scheme, the project construction enterprise shall complete the formalities of filing and environmental assessment. In the policy interpretation, it is more clearly pointed out that the balance of production capacity should be completed and the relevant procedures such as filing, environmental assessment and energy assessment should be improved.
The Environmental Impact Assessment Law stipulates that after the approval of the environmental impact assessment document of a construction project, if the nature, scale, location, production process or measures to prevent pollution and ecological damage of the construction project have changed significantly, the construction unit shall re-submit the environmental impact assessment document of the construction project for approval.
According to the Notice of the former Ministry of Environmental Protection on Issuing the List of Major Changes in Construction Projects of Fourteen Industries, such as Pulp and Paper Industry, in 2018, the scale of cement clinker exceeding 10% is a major change, and the EIA should be re conducted.
If the production capacity to make up the difference reaches or exceeds 10% of the original record (approved) production capacity, the EIA shall be carried out again.
According to the latest provisions of the Measures for Energy Conservation Review and Carbon Emission Assessment of Fixed Assets Investment Projects issued by the National Development and Reform Commission in 2025 (implemented on September 1), when conducting energy conservation review of projects, the carbon emission level, implementation impact and carbon reduction measures of projects are evaluated synchronously according to the requirements of dual control of carbon emissions, and the evaluation results are formed. The carbon emission assessment results of the project are included in the energy conservation review opinions of the project. Therefore, the carbon emission assessment of the project should be carried out at the same time of the energy conservation review.
The Measures stipulate that the project has been put into production and use, but the construction unit, construction site and construction scale have changed, and the main production equipment, energy-using equipment and technological route have changed; If major changes such as changes in major product varieties occur, or if the requirements of energy-saving review opinions are not fulfilled, such as comprehensive energy consumption and carbon emissions per unit product, actual annual comprehensive energy consumption or total carbon emissions higher than 10% of the approved level of energy-saving review, the department in charge of energy-saving work shall order the construction unit to rectify within a time limit. Those who fail to rectify, fail to rectify or fail to rectify within the time limit shall be punished by the department in charge of energy conservation in accordance with the relevant provisions of laws and regulations.
In accordance with the provisions of the Measures, if a project that has passed the energy-saving review has undergone major changes before or during the construction process, the construction unit shall submit an application for change to the original energy-saving review organ. According to the actual situation, the energy conservation review organ shall make a decision to agree to the change or conduct a new energy conservation review or (new) carbon emission assessment. Therefore, for how to rectify the production line that needs to be supplemented in energy conservation review and carbon emission assessment, a change application should be submitted to the original energy conservation review authority of the project. The energy conservation review authority shall decide how to rectify the completed project, or agree to the change according to the major changes in the construction process of the project, or re-conduct the energy conservation review, or (add) the carbon emission assessment.
According to the National Development and Reform Commission's Plan for Improving the Dual Control System of Energy Consumption Intensity and Total Amount in 2021, the state will continue to take the reduction of energy consumption intensity as a binding target for the five-year plan of national economic and social development, rationally set the total energy consumption target, and decompose and issue the five-year target of dual control of energy consumption to all provinces (autonomous regions and municipalities directly under the Central Government). The state implements the dual-target management of basic target and incentive target for the reduction of energy consumption intensity in all provinces (autonomous regions and municipalities directly under the Central Government). The basic target is the binding target that each region must ensure to achieve, and the incentive target is set according to a certain extent exceeding the basic target. Reasonably determine the target of reducing energy consumption intensity and total energy consumption of provinces (autonomous regions and municipalities directly under the Central Government).
Therefore, in addition to the energy conservation review, enterprises should not exceed the energy consumption indicators issued by the local government. If they exceed the consumption indicators issued by the local government, they should apply for an increase in the energy consumption indicators. However, the probability of "two high" projects needs to be solved by enterprises themselves within the scope of policy provisions.
Ask: Is it a reconstruction and expansion project to make up the difference in production capacity?
Answer: If it is only to make up the difference in the production capacity scale of the production line, it should be regarded as a simple unified operation of the actual capacity and the filed capacity, and the relevant procedures such as filing, environmental assessment and energy assessment should be improved.
If the process flow and equipment of the production line are changed in the process of making up the balance capacity of the production line, it can not be regarded as a simple unified operation of the actual capacity and the registered capacity, but should be regarded as a reconstruction and expansion project.
According to the requirements of the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Ecology and Environment, the General Administration of Market Supervision and the National Energy Administration's Special Action Plan for Energy Conservation and Carbon Reduction in Cement Industry in 2024, the energy-saving review and environmental assessment of fixed assets investment projects should be strictly carried out. New and expanded cement projects must reach the benchmark level of energy efficiency and A-level environmental performance, and the main energy-using equipment must reach the advanced level of energy efficiency.
For such reconstruction and expansion projects that make up the difference in production capacity, after making up the difference in production capacity, the production line should be checked and accepted according to the level of energy efficiency benchmark and A-level environmental performance.
At present, the cement industry is facing the double test of energy saving, environmental protection and industrial intelligence upgrading. In order to implement the relevant policy requirements and accelerate the green low-carbon transformation and high-quality development of the cement industry, China Cement Network is scheduled for September 23-24. The 14th China Cement Energy Conservation and Environmental Protection Technology Exchange Conference and the 6th Intelligent Summit Forum were held in Zibo, Shandong Province. This conference will bring together industry experts, enterprise representatives and many industry stakeholders to gather group wisdom and promote energy-saving, environmental protection and intelligent transformation and upgrading of the cement industry. During
the meeting, we will also organize a visit to the demonstration project of Qingzhou Zhonglian Cement Co., Ltd. with an annual output of 200000 tons of carbon dioxide oxy-fuel combustion coupled carbon capture.
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