Compliance Challenges for Multinational Corporations in China

In recent years, China has been crafting an array of innovative environmental laws and regulations, elevating the standards for environmental compliance and intensifying the enforcement of penalties. The year 2017 marked the inception of a novel pollutant discharge permit (PDP) system. Together with environmental impact assessment (EIA) system, these two systems have been positioned as the pivotal mechanism for overseeing stationary pollution sources. This system encompasses a holistic approach to multimedia environmental management.
 
Over the subsequent seven-year period, the Ministry of Ecology and Environment (MEE) has meticulously revised key environmental statutes, including the Air Pollution Prevention and Control Law, the Water Pollution Prevention and Control Law, the Solid Waste Pollution Environmental Prevention Law, and the Environmental Impact Assessment Law. Concurrently, a suite of new regulations has been introduced, addressing a spectrum of issues from noise, soil, underground water, hazardous and general industrial solid waste, greenhouse gas (GHG) management, as well as information disclosure and environmental protection taxes. These regulations have progressively refined and enhanced the specific requirements within the PDP and EIA.
 
The dynamic and iterative nature of these legal and policy updates presents big challenges for corporate environmental compliance. For the international headquarters of multinational corporations, staying abreast of the latest Chinese environmental policies and standards is no small feat. Consequently, to effectively oversee the compliance of their Chinese facilities, it is necessary to utilize the expertise of professionals who possess extensive experience in environmental compliance within China.
 

How China Team Supports U.S. Offices

Trinity’s China team has been actively collaborating with various Trinity U.S. offices to deliver consulting services to U.S.-based clients. Here are some notable examples:
 

• • Environmental Compliance Audits in Chemical Sector:
    • In 2024, the China team support the chemical service sector in conducting environmental compliance audits for Houston clients. A significant audit in March focused on the air compliance of a multinational client’s China facility. The client sought Trinity’s expertise for global audits, including those in the U.S., Europe, and China. The China team took the lead in auditing the Chinese facility, ensuring compliance with air-related regulations, PDP and Environmental Impact Assessment (EIA) reports, ODS laws, hazardous chemicals management, and LDAR requirements.
    • Scheduled for October, a multimedia environmental audit will be led by another client’s corporate EHS team, with local support from Trinity’s China team. This audit will provide a thorough review of two Chinese facilities’ compliance with PDP and EIA requirements, encompassing air, wastewater, noise, solid waste, and the management of hazardous and toxic chemicals.

• • Environmental, Health and Safety Audits:
    • • Since 2016, the China team has been providing regular environmental and safety audits for the Chinese facility of an Ohio-based client in the vehicle manufacturing industry. These audits, conducted every two to three years, have been instrumental in maintaining oversight of the client’s compliance status in China.
      • In 2018, the China team assisted the Dallas office with a health and safety audit project for an engine manufacturing client. Under the leadership of Sue Sung, Trinity’s Global EHS Director, the team conducted health and safety audits across multiple facilities in various Chinese provinces.

     

• • Paperwork Review:
    • In 2019, the China team embarked on a collaborative effort with the Albany office to support a client in the glass manufacturing industry. This partnership entailed a meticulous review of environmental documentation for the client’s Chinese facilities, including EIA reports and PDP applications. Our team’s profound expertise in these areas has fostered trust with both the client’s corporate office and the local Chinese facilities. Since the inception of this collaboration, the China team has emerged as the “go to person” for technical inquiries from the client’s corporate office and local Chinese sites and have expanded our services to encompass a diverse range of consulting engagements for them.

• Due Diligence:
  • • In 2018, the China team assisted the Sacramento office with the due diligence process for a Chinese facility. This support was crucial in the context of a broader, global site assessment initiative for a client in fiber manufacturing, ensuring a comprehensive evaluation of the site’s environmental and operational standards.

   

China Team Capabilities in Support of Clients’ Audits and Compliance Services

Trinity’s first China office was established in 2006 in Hangzhou, Zhejiang province, a mere 160 kilometers from Shanghai. By 2024, our presence has expanded to include the Xi’an office in the northwest and the Hainan office in the southernmost part of China. With nearly two decades of experience providing environmental services to clients across various industries, institutions and government entities in China, Trinity’s China team has earned a reputation for its expertise and high-quality deliverables in the field of PDP, EIA, air modeling, compliance audits, and GHG services.
 
Our team is comprised of seasoned environmental professionals with over ten years of experience and talented young people graduated from top universities such as MIT, Tsinghua University, and Zhejiang University. A notable 20% of our team members are certified EIA engineers in China, and we have several members featured in the expert databases of the MEE or provincial departments.
 
In our role as trusted advisors for compliance and audit services, the China team has provided comprehensive audit services to a diverse clientele, ranging from large domestic enterprises to international corporations. We have also been entrusted by environmental agencies to audit the compliance of businesses under their jurisdiction. Through on-site inspections, documentation reviews, and personnel interviews, we evaluate the operational specifics—such as outfalls, control devices, and process equipment—as well as environmental records to ascertain compliance with national and local environmental regulations and client-specific internal policies. Our audits empower clients to gain insights into their current compliance status, address environmental challenges, enhance their environmental management practices, and mitigate the risks of legal non-compliance.
 
A distinct advantage of Trinity’s China team in providing compliance and audit services to multinational companies is our close collaboration with Trinity’s U.S. offices, which offer compliance services to clients’ other sites across the U.S. This synergy ensures a uniform approach and depth in our audit services.
 
China Team Capabilities encompass:

• Conducting environmental compliance audits
• Technical review of documentation, including PDP and EIA applications
• Analysis of local regulatory applicability
• Facilitating EIA applications
• Assisting with PDP applications
• Developing Environmental Risk and Emergency Plans

For more information and assistance evaluating your current compliance requirements, please contact Inaas Darrat, PE, at 713.552.1371 or Yiyue Zhang at +86-13051109581