Talk about the determination of production capacity in the replacement of cement clinker production capacity.

There are basically such clauses in the replacement implementation measures before the Measures for the Implementation of Capacity Replacement in the

Cement and Glass Industry (2021 edition). 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 cement clinker production capacity conversion table. According to the interpretation of this policy

in 2017, 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 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 shall continue to be calculated according to the cement clinker production capacity conversion table of the original method. According to the interpretation of this policy

in 2021, capacity verification involves withdrawal and new construction, which is an important work to promote scientific and fair replacement. There are clear criteria for approval in the new approach. The capacity index used for replacement shall be determined according to the design capacity and time completion capacity on the project filing or approval documents, and the smaller one shall be approved by the smaller one. This special approval procedure has been added to the

capacity replacement in order to prevent the "batch of small and large" projects from taking advantage of the capacity replacement. It should be said that at the same time, it also prevents the "batch of large and small" projects from taking advantage of "cheap".

By 2024, the quantity of production capacity used for replacement will be determined strictly according to the production capacity specified in the project filing (approval) documents, and the annual production capacity days will be calculated according to 300 days. According to the policy interpretation, the cancellation of the approved capacity conversion table 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. Starting

from the new method, we will no longer ask whether there is any "trick" in the production capacity of the "batch of small and large" or "batch of large and small" projects that have been completed before, but only recognize the size of the approved (filed) production capacity. To put it bluntly, it is no longer necessary to ask whether there is any "advantage" in capacity replacement.

Recently, I saw the capacity replacement plan of a cement clinker project (supplement) in a large cement province in the south. The transfer-out capacity project is one Φ3.5 × 47m rotary kiln, and the approved capacity is 2000t/d in 2011. According to the replacement ratio of 1.5: 1, the transferred project is supplemented with 1333 t/d. Looking back, if according to the previous method, the corresponding (actual) capacity of Φ3.5m kiln is 1500 t/d, the difference between the two is 500 t/d, and the approved capacity is 1.333 times of the actual capacity. According to the previous method, the replacement capacity can only be 1000 t/d. The capacity difference between them is 333 t/d.

Since the "special" procedure was implemented to determine the replacement capacity in order to advocate trustworthiness and compliance with the law and promote scientific and fair replacement, the corresponding policies should maintain a certain degree of continuity, and there should be continuity in specific practices. Fair replacement of production capacity should also include the fairness of project replacement after the implementation of capacity replacement. That is to say, the implementation time of the Implementation Measures for Capacity Replacement in Some Industries with Serious Overcapacity can be taken as the boundary from July 10, 2014. When the previously approved (approved) cement clinker project capacity is used for replacement, the original replacement method should still be added to the comparison procedure to determine the capacity that can be used for replacement; When the capacity of the cement clinker project approved (filed) thereafter is used for replacement, the capacity that can be used for replacement shall be determined strictly according to the capacity specified in the project filing (approval) document. For the (supplementary) capacity replacement scheme of the above cement clinker project, the replacement supplementary capacity should not be 1333 t/d, but 1000 t/d is more appropriate.