# China Factory Environmental Compliance Audit Checklist > Source: https://netray.co/tools/china-factory-environmental-compliance-audit-checklist > Publisher: Netray (netray.co), AI and integration engineering for ERP and manufacturing systems. > Section: Free Tools ## Short answer Check permits, hazardous waste handling, wastewater, air emissions and monitoring records before you onboard or renew a Chinese manufacturer. ## Category compliance-legal ## Region China ## Audience - Supplier quality - Sustainability manager - Sourcing manager - EHS manager ## Tool **Kind:** checklist **Groups:** #### Permits and approvals **Items:** **Text:** Environmental impact assessment (EIA) approval or filing exists for the plant and each major process change **Critical:** true **Text:** Pollutant discharge permit is valid, unexpired and covers the processes actually in operation **Critical:** true **Text:** Completion acceptance of environmental protection facilities recorded for each construction project (three simultaneities rule) **Critical:** true Business scope on the licence matches the processes run on site Permit conditions are known to the plant manager and summarized on site **Text:** No open penalty notices, rectification orders or production restrictions from the local ecology bureau **Critical:** true #### Wastewater and air **Items:** **Text:** Wastewater outlets match the permit and are labeled **Critical:** true Treatment plant is operating and operators are trained, with daily logs Effluent monitoring results meet the permit limits and comparable discharge standard Online monitoring is installed and connected where the permit requires it Exhaust from coating, plating, welding or casting lines is captured and treated VOC controls (capture, activated carbon or combustion) are maintained and media replacement is recorded Boundary noise is measured and within the applicable limit for the zone #### Hazardous waste and chemicals **Items:** **Text:** Hazardous waste types are identified and registered with the local authority **Critical:** true **Text:** Storage area has containment, ventilation, signage, labels and a storage period within the legal limit **Critical:** true **Text:** Waste is moved only by licensed carriers to licensed disposal facilities, with transfer manifests on file **Critical:** true Empty chemical containers, oily rags, sludge and used solvents are classified and handled as required Safety data sheets for all chemicals are available in Chinese at point of use **Text:** Restricted substance controls for customer requirements (RoHS, REACH) are documented **Critical:** false Spill kits and emergency response plan exist, with drills recorded #### Records and management **Items:** Self-monitoring plan is in place and results are retained for the period the permit requires Environmental management responsibilities are assigned to a named person ISO 14001 or equivalent system is certified, or a gap list exists Energy and water use are metered and tracked monthly Third-party environmental test reports are recent and from accredited labs Sub-suppliers that run plating, anodizing, casting or heat treatment are listed and have been screened Corrective actions from previous audits are closed with evidence **Scoring Note:** Any critical item that fails is a stop-ship or onboarding hold until a corrective action plan with dates is accepted. Count the other items to get a percentage and track it per audit. This list is a screening tool, not legal advice. Use qualified local counsel or a certified auditor for legal conclusions. ## Content **Intro:** Environmental violations at a Chinese supplier can stop production overnight, and they land on the buyer as a supply risk and a reputational risk. This checklist helps you screen permits, wastewater, air, hazardous waste and records during a site visit or document review. **Sections:** #### How to run the audit **Body:** Ask for the document list a week before the visit: EIA approval, pollutant discharge permit, acceptance records, monitoring reports and hazardous waste manifests. During the walk-through, compare what you see with what the paperwork says. Tick items as you verify them, mark critical failures, and export the result to PDF for the supplier file. A plant with processes not covered by its permit is a higher risk than one with an untidy storage area. #### Core Chinese environmental concepts **Body:** Three terms matter most. The EIA is the pre-construction assessment and approval or filing. The pollutant discharge permit is the operating licence for emissions and discharges, with limits and monitoring duties. The three simultaneities rule requires that pollution control facilities are designed, built and put into operation together with the main project, followed by acceptance. Hazardous waste has its own regime of registration, licensed carriers and manifests, and storage periods are limited by law. #### Reading the results **Body:** A clean sheet on permits with gaps in housekeeping is usually fixable with a corrective action plan. A missing permit or unlicensed waste disposal is not. Look for patterns, such as monitoring data that is always exactly at the limit, handwritten logs completed in one sitting, or hazardous waste quantities that do not match production volume. These point to weak controls even when the documents look complete. **Bullets:** - Compare waste manifests with production volume - Check permit dates and covered processes - Interview operators, not only managers - Photograph storage areas and outlets #### Common mistakes **Body:** Buyers often rely on an ISO 14001 certificate alone. A management system certificate does not prove permit compliance. Another mistake is auditing only the final assembly plant while plating, casting or heat treatment is subcontracted to unscreened sites. List sub-tier processes and decide which need their own visit. **Cta:** If you track supplier audits and corrective actions across many sites, Netray can help set up a private assistant over your audit reports that surfaces open findings by supplier. **Faq:** #### What is a pollutant discharge permit in China? **Answer:** It is the licence that allows an enterprise to discharge air pollutants and wastewater and generate certain wastes under set limits. It lists pollutants, limits, outlets, monitoring duties and reporting. Operating without a valid permit is a serious violation. #### Is an ISO 14001 certificate enough? **Answer:** No. ISO 14001 shows a management system exists, but it does not replace legal permits, monitoring or hazardous waste compliance. Treat it as supporting evidence and still verify permits and records on site. #### How often should I audit environmental compliance? **Answer:** At onboarding, then at least annually for processes with higher risk such as plating, coating, casting or chemical use, and after any reported incident or ownership change. Lower-risk assembly sites can be checked on a longer cycle. #### Can I do this as a remote document review? **Answer:** Document review is useful for screening, but permit coverage and waste handling are best verified on site. If remote, ask for dated photos and video of storage areas and outlets, and use a local third-party auditor for confirmation. ## Search terms China factory environmental audit checklist, supplier environmental compliance China, pollutant discharge permit China, hazardous waste China supplier audit, EIA approval factory China, three simultaneities environmental, China supplier EHS audit, factory environmental permit checklist --- Talk to an engineer: https://netray.co/contact?intent=erp_ai | Machine catalog: https://netray.co/agent/catalog.json