According to the regulations on the filing of enterprise investment projects, for projects subject to filing management, the enterprise shall inform the filing authority of the following information through the online platform before starting construction: (1) Basic information of the enterprise; (2) Project name, construction site, construction scale and construction content; (3) Total investment amount of the project; (4) Statement that the project conforms to the industrial policy. The construction scale in the investment project information referred to in the
regulations is the capacity referred to in the industry. Usually, the production capacity is calculated in years, which is obtained by the daily production capacity of the production line * the number of production days per year. In March
2023, the National Development and Reform Commission issued the outline and instructions for the preparation of the feasibility study report of investment projects, in which the first part of the reference outline for the preparation of the feasibility study report of enterprise investment projects (2023 edition) is an overview. (I) Project overview: full name and abbreviation of the project. Summarize the project construction objectives and tasks, construction site, construction content and scale (including main output), construction period, investment scale and source of funds, construction mode, main technical and economic indicators, etc. (4) The project construction content, scale and output plan shall elaborate the overall objectives and phased objectives of the proposed project, put forward the construction content and scale of the proposed project, clarify the project product plan or service plan and its quality requirements, and evaluate the rationality of the project construction content, scale and product plan. According to the reference outline for compiling the feasibility study report of
enterprise investment projects, on the basis of implementing the investment autonomy of enterprises, it is mainly to guide enterprises to attach importance to the feasibility study of projects, strengthen the internal decision-making management of investment projects, promote production and operation in accordance with the law, and achieve healthy and sustainable development. The choice of production days and capacity to
determine the size of the scale is the autonomy of the enterprise. In practice, the project feasibility study is usually carried out according to the number of days recommended by the design specification. The project construction scale (design capacity) filed
by legal procedures (including previous approval and approval) is the legal capacity of the project.
In the previous cement capacity replacement method, the capacity index used for replacement is determined according to the design capacity on the project record or approval document. If the actual capacity is less than registered or approved capacity, it shall be determined according to the actual capacity. This introduces the concept of actual capacity. The actual capacity shall be calculated and determined by the kiln diameter according to the cement clinker capacity conversion table. This is in view of the fact that there is a 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 capacity indicators 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.
The new version of the cement production capacity replacement method cancels the provision that the approved production capacity is based on the diameter of the cement rotary kiln, and promotes the unification of the registered production capacity and the actual production capacity. Cancellation of the capacity conversion table of the approved capacity scale mainly considers that with the continuous progress of production technology and equipment level, the approved capacity based solely on the diameter of cement rotary kiln can no longer reflect the actual production capacity. The production capacity shall be determined strictly according to the project filing (approval) documents, and the annual production capacity days shall be 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 made up according to the method and the relevant procedures such as filing, environmental assessment and energy assessment can be improved. The actual capacity referred to in the new cement capacity replacement method refers to the actual production capacity, which is no longer the capacity corresponding to the kiln diameter. Returning to the record capacity is the only benchmark for the project capacity.
In actual production, enterprises should produce and operate in accordance with the law. In case of heavy pollution weather, emergency state, environmental protection, energy consumption, safety, quality and technology are not up to the standard, according to the relevant government plans and rectification requirements, the limit should be changed. A-level enterprises with environmental performance can arrange independently in heavy polluted weather.
If the annual production days of enterprises are approved by administrative means, a new concept of capacity, administrative approved capacity, is derived, and this capacity is dynamic.
As long as the enterprise operates in compliance with the regulations, the production line is the autonomy of the enterprise. The enterprise has high management level, strong competitiveness and high capacity utilization rate, and the annual production days are higher than recommended days of the design specification to determine the production scale. Recently, there are project cases that determine the annual production capacity by 330 days.
For enterprises that fail to meet the standards of environmental protection, energy consumption, safety, quality and technology, they should be rectified within a time limit. Among the production days announced by some provinces in 2025, enterprises whose energy efficiency is below the benchmark level in 2023 have also approved 270 production days in 2025.
The Energy Conservation Law is clear. For key energy-using units with imperfect energy-saving management system, non-implementation of energy-saving measures and low energy utilization efficiency, the department in charge of energy-saving work shall conduct on-site investigation, organize and implement energy efficiency testing of energy-using equipment, order the implementation of energy audit, and put forward written rectification requirements for rectification within a time limit. Sixteen departments, including the
Ministry of Industry and Information Technology, issued the Guiding Opinions on Using Comprehensive Standards to Promote the Withdrawal of Backward Production Capacity in Accordance with the Law and Regulations (No.30, 2017), which clearly States that the Energy Conservation Law shall be strictly enforced and that the production capacity that fails to meet the requirements of the mandatory energy consumption quota standards shall be rectified within six months; If it is really necessary to extend the rectification period, an application for an extension of not more than 3 months may be submitted; if the rectification is not carried out within the time limit or the rectification is still not up to the standard, it shall be closed down and withdrawn according to law. If the energy consumption of the enterprise is not up to the standard, can it be approved to produce for 270 days?
The current fact is that there are not a few people who have stopped production for 200 or more days in the year of peak staggering production, and it seems that it is of little practical significance to verify the number of days of three-grade production. In July
2024, the decision of the Central Committee of the Communist Party of China on further deepening reform and promoting Chinese-style modernization put forward that the system and rules of factor market should be improved to promote the smooth flow of production factors, the efficient allocation of various resources and the full release of market potential. We should improve the price mechanism of factors mainly determined by the relationship between supply and demand in the market, improve the system and rules of factor markets, and promote the smooth flow of production factors, the efficient allocation of various resources and the full release of market potential. In May
this year, the General Office of the Central Committee of the Communist Party of China and the General Office of the State Council put forward the main objectives of improving the market-oriented allocation system of resources and environmental factors: by 2027, the trading system of carbon emission rights and water rights will be basically improved, the trading system of emission rights will be established and improved, and the market-oriented mechanism of energy conservation will be more sound. The trading market of resources and environmental factors is more active, the price formation mechanism is more sound, the smooth flow and efficient allocation of resources and environmental factors are promoted, the market potential is fully released, and the supporting role for the realization of relevant resources and environmental objectives is effectively enhanced. Efficient allocation of
resources and full release of market potential should be the goal of cement manufacturing industry.
Last month, the Ninth Congress of China Cement Association was held in Hefei, Anhui Province, and Yan Xiaofeng, president of China Building Materials Federation, delivered a speech. Yan Xiaofeng believes that the current domestic competition in all walks of life is very fierce, facing the same situation, in addition to the cement industry, the development of few industries still rely on enterprises to stop production and limit production to maintain. We can not use the thinking habits and behavior of planned economy to deal with the problems under the conditions of market economy for a long time, which will not be effective or lasting. Yan Xiaofeng stressed that market problems are mainly solved by the market. In the process of pursuing efficient allocation of resources and full release of market potential in the
cement industry, market problems mainly depend on the market to solve. Production capacity is an important and sensitive topic in the cement industry. For each cement clinker production line, it is OK to have a registered production capacity, but it seems useless to have more.
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