AmCham Shanghai and USCBC are pleased to offer comments on the draft law based on specific inputs received from our members. We recommend revisions to several articles in the draft law that need further clarification or may actually hinder the environmental goals of the Revised Regulations. Such concerns include provisions that relate to definitions of key terms in the Revised Regulation; methodology for measuring emissions and quotas, classification for environmental impact assessments, and transparency.
We encourage the Shanghai Municipal People's Congress actively to consider AmCham Shanghai and USCBC's comments while reviewing the Revised Regulations. Addressing these concerns in a comprehensive manner will help to improve the effectiveness of this law and clarify any midsunderstandings.