A little story of a monstrous mess II｜Greenpeace

A little story of Monstrous Mess II Investigation of hazardous chemicals in the wastewater from dyeing facilities in Shishi China Greenpeace Jan. 2014

Contents 1. Haitian WWTP: the communal wastewater treatment plant (WWTP) of the Wubao Dyeing Industrial Zone .............................................................................. 2 a. Guan Hong Holdings Co., Ltd in the Wubao Dyeing Industrial Zone...... 4 b. Hua Run Facility in the Wubao Dyeing Industrial Zone ............................. 4 2. Testing Results ...................................................................................... 5 3. Policy .................................................................................................... 8

Greenpeace1 team witnessed and documented a huge, black plume of wastewater, on the surface of the sea neighboring China's Wubao Dyeing Industrial Zone, which is estimated covering an area equal to 50 Olympic swimming pools2 and was easily spotted in satellite imagery. The plume of wastewater stretched directly above the outlets of a long submerged pipe perpendicular to the coastline. The pipe belongs to the communal wastewater treatment plant of the Wubao Dyeing Industrial Zone - Haitian Environmental Engineering Co. Ltd. The Wubao Dyeing Industrial Zone in Shishi city consists of 19 dyeing facilities, all of which share one wastewater treatment plant3. A Greenpeace investigation has found toxic chemicals such as the hormone disruptor nonylphenol (NP), chlorinated anilines and antimony in the wastewater discharged from two of these dyeing facilities, before reaching the wastewater treatment plant. Some of the chemicals found in current study matched those detected in some children’s clothing made locally in Shishi and tested by Greenpeace4.

As the wastewater from Haitian Environmental Engineering Co. Ltd is discharged through a 2.4 km pipe down below the surface of the sea3, it is nearly impossible for the public to monitor what toxic chemicals are being discharged into the sea via this pipe. This pipe belonging to the Wubao Dyeing Satellite Imagery of Wubao Dyeing Industrial Zone Industrial Zone is just the tip of the iceberg of a much larger problem. There are 435 such discharge points along the coastline of China, which altogether release 32.2 billion tons of wastewater per year.

Among them, 68% have records of illegal discharge, and 25% have never met national environmental 1

In this document, all the “Greenpeace”, except the final one, refers to “Greenpeace East Asia”.

2 The area is approximately 625,000 m . It is calculated based on the satellite imagery taken in 2012 March. According to the field investigation conducted by Greenpeace, the area of this black plume varies, for example, it was much bigger on the satellite imagery taken in 2009.

3 Shishi EPB (2013) Government Affairs of Shishi Environment Protection Bureau monthly report, February 2013 http://huanbao.shishi.gov.cn/ewebeditorword/uploadfile/20130312093656833.doc 4 Greenpeace East Aisa (2013), A Little Story About a Monstrous Mess: Investigating the toxic residues in children’s clothing from China’s largest manufacturing towns http://www.greenpeace.org/eastasia/publications/reports/toxics/2013/little-story-monstrous-mess/ 2

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standards, according to official data from China’s State Ocean Administration5.

“Measures for the Registration of Dangerous Chemicals for Environmental Management” is a new policy promulgated by the Ministry of Environment Protection, and came into effect in March 2013. This policy requires factories that use and discharge hazardous chemicals to register the discharge and transfer information and disclose this information to the public. Greenpeace is calling for the Chinese government to enforce this policy, and urging factories to disclose information on hazardous chemicals discharge and step by step eliminate such chemicals from the production of clothes.

The black plume of wastewater, on the surface of the sea neighboring Wubao Dyeing Industrial Zone. th

25 October in 2013, Shishi, Fujian Province.

1. Haitian WWTP: the communal wastewater treatment plant (WWTP) of the Wubao Dyeing Industrial Zone In 2013, Greenpeace witnessed and documented a huge, black plume of wastewater on the surface of the sea neighboring China's Wubao Dyeing Industrial Zone, which was easily spotted in satellite imagery.

The plume stretched directly above the outlets of a long submerged pipe perpendicular to the coastline that belongs to the communal wastewater treatment plant of the Wubao Dyeing Industrial Zone - Haitian Environmental Engineering Co. Ltd. (Haitian WWTP).

Haitian WWTP was established in 2001, by 12 companies located in the Wubao Dyeing Industrial Zone, and has a treatment capacity of 90,000 tons/day and water recycling capacity of 10,000 tons/day. It receives wastewater from all 19 dyeing and finishing facilities located in this industrial zone. 6 The wastewater treated by the Haitian WWTP is discharged into the ocean through a 2.4 km long pipe down below the sea's surface. Haitian Environmental Engineering Co. Ltd. is included in the National Key WWTP for Monitoring and Control List in 2013.7 5

Report On the State of the Ocean Environment In China (2012). China's State Oceanic Administration (SOA). http://www.soa.gov.cn/zwgk/hygb/zghyhjzlgb/201303/t20130329_24713.html 6 Shishi EPB (2011) Government Affairs of Shishi Environment Protection Bureau monthly report, November 2011 http://huanbao.shishi.gov.cn/ewebeditorword/uploadfile/20120206170033384.doc (last accessed: November 6, 2013) Shishi EPB (2013) Government Affairs of Shishi Environment Protection Bureau monthly report, February 2013 http://huanbao.shishi.gov.cn/ewebeditorword/uploadfile/20130312093656833.doc (last accessed: November 6, 2013) 7 Notice of National Key Pollution Enterprise for Monitoring and Control List in 2013 http://www.fjepb.gov.cn/userFiles/image/20130506154330911.PDF 2

Records of illegal discharges of Haitian WWTP Following disclosure by local government records8,9, in October 2011 and February 2013, Haitian WWTP was fined 100,000 RMB by the Shishi Bureau of Environmental Protection for the illegal discharge of untreated wastewater directly into deep sea.

Shishi, Fujian Province and Hongshan Town Located in the southwest costal area of Fujian Province, Shishi has long been an important clothing production and export base10 of China. Shishi began production of children’s clothing in the 1980s in the downtown Fengli Street area. As the nation's oldest distribution centre for children’s clothing, in 2005 it earned the title “China’s Top Town for Children’s Clothing” from the China’s Textile Industry Association. During its peak, it alone accounted for 80% of the market share in China11.

In 2011, Shishi produced at least 0.2-0.3 billion children’s clothing items, with an annual production value of 26 billion RMB, making up half of the total clothing industry in Shishi. There are over 3,000

Shishi, Fujian Province

manufacturers12 of children’s clothing present. And 70-80% of the products are exported, with the Middle East being the largest buyer, but also to Europe, the United States, Southeast Asia and African countries13.

Dabao, Wubao and Jinshang dyeing and printing centres have been built for the integrated purposes of dyeing, weaving, bleaching and printing in the costal towns of Xiangzhi, Hongshan and Jinshang in Shishi.

There are several dozens of textile dyeing manufacturers that distribute here, functioning as upstream suppliers in the local clothing production chain.

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Records published by Shishi Bureau of Environment Protection in December 2011. http://huanbao.shishi.gov.cn/News/ShowArticle.asp?id=418 9 Records published by Shishi Bureau of Environmental Protection in March 2013. http://huanbao.shishi.gov.cn/News/ShowArticle.asp?id=1062 10 Shishi city government website. http://www.shishi.gov.cn 11 Shishi Children’s Clothing: A Smart Move with its Industry Advantages. Shishi Daily. http://www.ssrb.com.cn/News/ShiShi/2011/0328/211071.html. 2011-03-28 12 The Crisis-Ridden Shishi Children’s Clothing Industry Awaiting Better Prospects After Transformation. Shishi Daily. http://www.ssrb.com.cn/News/Finance/2011/0916/246998.html. 2011-09-16 13 Children’s Clothing Embroidery Becoming Popular After Ramadan. Shishi Daily. http://www.qxkjb.com/html/sss_20_12324.html.

2011-09-19 3

Hongshan Town of Shishi, located in the eastern part of Shishi, covers an area of 15.12 square meters and 10 km of coastline. It was granted by China’s Textile Industry Association the title "China’s Casual Wear Fabric14 Town" in 2008. In 2010, Hongshan Town’s textile production capacity reached 1 billion meters/year15. The Wubao Dyeing Industrial Zone was founded in 1996, covering 61.68 hectares along the coastline of Hongshan16. The zone is comprised of 19 dyeing and finishing textiles facilities, and all facilities share the Haitian WWTP for wastewater treatment.

Wubao Dyeing Industrial Zone

a. Guan Hong Holdings Co., Ltd in the Wubao Dyeing Industrial Zone As one of the largest fabrics suppliers in Shishi, Guan Hong Holding Co., Ltd17 is a Chinese-foreign equity joint venture, whose business activities cover fabric research and development, weaving, dyeing and finishing. Guan Hong has become a key fabric research and development center for casual wear in China, in particular for functional fabrics.

b. Hua Run Facility in the Wubao Dyeing Industrial Zone The Hua Run facility is a subsidiary company of the Huafeng Textile International Group (stock code HK: 0364), which was established in 1988 and with an annual production capacity of over 146,000 tons. The facility opened in 2000 with an investment of 80 million RMB. Hua Run’s core business is dyeing and finishing. Its market covers multiple provinces in China, as well as Northeastern Asia, Europe and America.

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The casual wear fabric mentioned here is mainly used for the manufacture of leisure style clothing, and may include chemical fibres and functional fabrics (such as, crease-resistant, shrink-proof, flame-retardant, iron-free and waterproof fabric functions).

15 Wan Han. (2010). Hongshan: Building the Leisure Fabric Manufacturing Top Town. Textile and Garment Weekly, 29, 13.

16 Shishi EPB (2013) Government Affairs of Shishi Environment Protection Bureau monthly report, February 2013 op cit.

17 http://www.guanhong.com/ 4

2. Testing Results On August 6, 2013, Greenpeace team collected three wastewater samples from monitoring access points of underground wastewater pipes in the Wubao Dyeing Industrial Zone. These pipes served individual facilities which all sent their wastewater to the local WWTP – Shishi City Haitian Environment Engineering Co., Ltd. plant for treatment. For the two wastewater samples close to the Guan Hong Holdings Co., Ltd. one wastewater sample was collected from each of the two monitoring access points in the immediate vicinity of Guan Hong’s facility (we found no other monitoring access points in the immediate vicinity of Guan Hong’s facility). The third wastewater sample was collected in the immediate vicinity of the monitoring access point next to the Hua Run facility (we found no other monitoring access points in the immediate vicinity of Hua Run’s facility).18

Sampling Point of Guan Hong Holdings Co. Ltd

Sampling Point of Hua Run Facility

Key findings  NP and NPEs Nonylphenol (NP) was found in the two wastewater samples collected from the Guan Hong Group, with concentrations of 7.14 g/l and 17.1 g/l. One of the samples also contained nonylphenol ethoxylates (NPEs) at a concentration of 121g/l. The wastewater sample from Hua Run contained even higher concentrations of nonylphenol (212 g/l) and nonylphenol ethoxylates (558 g/l).

NPEs are used as detergents and surfactants in textile manufacture and degrade in wastewater treatment plants or in the environment to form the persistent hormone disrupting contaminant nonylphenol (NP). NP does not break down easily in the environment, and can therefore persist long after being released. It can also accumulate in body tissue throughout the food chain19. In 2010, a Greenpeace investigation found

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All references in this document of samples collected “from” Guan Hong and Hua Run monitoring access points is within the preceding indicated context and circumstances.

19 OSPAR (2004) Nonylphenol/nonylphenolethoxylates, OSPAR Priority Substances Series 2001, updated 2004, OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic, OSPAR Commission, London, ISBN 0-946956-79-0: 20 pp.

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NP in wild fish of the Yangtze River20. Research showed that for the general public, eating contaminated food or drinking contaminated water is the major route of exposure to NP21.

NP is toxic to aquatic life. Scientific studies have found that exposure to NP can lead to altered sexual development in some organisms, most notably the feminization of fish22,23. In the EU, NP and NPE are effectively banned in most industries, including textile manufacturing. Meanwhile, in China they were listed in the recently released “Dangerous Chemical Catalogue(draft)”24, and factories which produce and use these chemicals are required to register with the environmental bureau.

 Chlorinated anilines All three samples contained chlorinated anilines, which is of serious concern despite their relatively low concentrations in the wastewater samples (the sum of 3-chloro- and 4-chloroanilines was in range of 0.59 - 1.7µg/l). This is of concern due to the fact that one of these compounds, 4-chloroaniline25, is a carcinogenic chemical and as such is included in Chinese regulations26 prohibiting the use of azo dyes that can degrade to form carcinogenic amines.

 Antimony All three samples contained high concentrations of antimony. The concentrations of the two samples from Guan Hong were 137µg/l and 314µg/l respectively, while the sample concentration from Hua Run Company was 132 µg/l. Concentrations of antimony in unpolluted surface freshwater are typically below 1 µg/l27.

Antimony (in the form of antimony trioxide) is used as a catalyst during the manufacture of polyester fibers.

Antimony shows many similarities in its chemistry and toxicity to arsenic28,29. Trivalent antimony, as present in antimony trioxide, is a more toxic form of the antimony compound30,31, with effects including dermatitis, irritation of the respiratory tract, and interference with the immune system32. In addition, antimony trioxide is listed as "possibly carcinogenic to humans" principally due to inhalation of dust and 20

http://www.greenpeace.org/china/zh/publications/reports/toxics/2010/fish2010-rpt/ IPCS (2002) Global Assessment of the state-of-the-science of endocrine disruptors. Chapter 6: Exposure of selected potential EDCc in humans and wildlife. http://www.who.int/ipcs/publications/en/ch6.pdf 22 Jobling, S., Reynolds, T., White, R., Parker, M.G. and Sumpter, J.P. (1995) “A variety of environmentally persistent chemicals, including some phthalate plasticizers, are weakly estrogenic”, Environmental Health Perspectives, vol. 103, no. 6, pp.582-587 23 Jobling, S., Sheahan, D., Osborne, J.A., Matthiessen, P. and Sumpter, J.P. (1996) “Inhibition of testicular growth in rainbow trout (Oncorhynchus mykiss) exposed to estrogenic alkylphenolic chemicals”, Environmental Toxicology and Chemistry, vol. 15, no. 2, pp.194-202 24 http://www.chinasafety.gov.cn/newpage/Contents/Channel_5826/2013/0926/220588/content_220588.htm 25 WHO: Concise International Chemical Assessment Document 48: 4-CHLOROANILINE http://www.who.int/ipcs/publications/cicad/en/cicad48.pdf 26 Chinese regulations include GB 18401-2010 National General Safety Technical Code for textile products etc.

27 Filella, M., Belzile, N., Chen, Y.W. (2002) Antimony in the environment: a review focused on natural waters II. Relevant solution chemistry. Earth-Science Reviews 59: 265–285 28 Andrewes, P., KitChendian, K.T. and Wallace, K. (2004) Plasmid DNA damage caused by stibine and trimethylstibine. Toxicology and Applied Pharmacology 194: 41-48 29 Patterson, T.J., Ngo, M., Aronov, P.A., Reznikova, T.V., Green, P.G. & Rice, R.H. (2003) Biological activity of inorganic arsenic and antimony reflects oxidation state in cultured human keratinocytes. Chemical Research in Toxicology 16(12): 1624-1631 30 Patterson et al (2003) op cit.

31 De Boeck, M., Kirsch-Volders, M. and Lison, M. (2003) Cobalt and antimony: genotoxicity and carcinogenicity. Mutation Research 533: 135–152 32 Kim, H.A., Heo, Y., Oh, S.Y., Lee, K.J. and Lawrence, D.A. (1999) Altered serum cytokine and immunoglobulin levels in the workers exposed to antimony. Human and Experimental Toxicology 18(10): 607-613 6 21

vapor33. Inhalation exposure to antimony is more common in occupational settings, whereas the general population is exposed to antimony mainly through ingestion of food and water.

 Metal 



Chromium: one sample collected from Guan Hong Group also turned up in testing with elevated levels of chromium (244 µg/l dissolved, 284 µg/l total), well above background concentrations expected in uncontaminated surface freshwater (median values are commonly around 10 µg/l)34.

Zinc: the sample concentration reached 138 µg/l dissolved, 201 µg/l total from Guan Hong and 72 µg/l dissolved, 155 µg/l total from Hua Run’s sample.

According to our investigation, wastewater containing hazardous chemicals are discharged to the Haitian WWTP and then further discharged into the ocean following treatment. However, the WWTP is often unable to completely treat all contaminants prior to their discharge into receiving waters, for example, as previously shown for nonylphenolic compounds35 detected in samples of untreated wastewater in our study. These contaminants could be still present in the treated wastewater or treatment plant sludges at substantial concentrations36. If such wastewaters are introduced into coastal environments, some of the contaminants may contaminate seawater and accumulate in bottom sediments and aquatic organisms.

Unfortunately, it was not possible to representatively collect the sample directly from the discharge pipe of Haitian WWTP due to a combination of factors including large depth of submerged pipe, lack of underwater visibility, and rough sea conditions. Therefore, a sample of mixture of wastewater and seawater collected from the huge, black plume, which can be seen directly above the outlets of the discharging pipe of Haitian WWTP, did not allow to fully assess the range and levels of chemicals actually discharged from the Haitian WWTP pipe. Nonetheless, trace levels of some hazardous chemicals37 were still found in this sample.

Considering the difficulty of sampling directly from the submerged pipe, it is currently impossible for the public to monitor its activities, further highlighting the necessity for information disclosure concerning such potential sources of marine environment pollution.

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IARC (1989). International Agency for Research on Cancer (IARC) Monographs programme on the evaluation of carcinogenic risks to humans: Some Organic Solvents, Resin Monomers and Related Compounds, Pigments and Occupational Exposures in Paint Manufacture and Painting vol. 47, pp. 291–306 34 ATSDR (2012) Toxicological profile for chromium, United States Public Health Service, Agency for Toxic Substances and Disease Registry, September 2012. http://www.atsdr.cdc.gov/ToxProfiles/tp7.pdf 35 González, S., Petrovic, M. & Barceló, D. (2004) Simultaneous extraction and fate of linear alkylbenzene sulfonates, coconut diethanol amides, nonylphenol ethoxylates and their degradation products in wastewater treatment plants, receiving coastal waters and sediments in the Catalonian area (NE Spain). Journal of Chromatography A, 1052(1–2): 111-120 36 Clara, M., Windhofer, G., Hartl, W., Braun, K., Simon, M., Gans, O., Scheffknecht, C., Chovanec, A. (2010) Occurrence of phthalates in surface runoff, untreated and treated wastewater and fate during wastewater treatment. Chemosphere 78(9):1078-1084 37

Most of the hazardous chemicals we found in this sample were also found in the control seawater sample. The key difference

between the sample and the control sample was trace levels of DEHP (0.5 µg/L) found in the seawater of the affected area. DEHP is a kind of phthalate and toxic to the reproductive system. It was also found in a children's clothing sample produced in Shishi, which can be seen in the report below: Greenpeace East Aisa (2013), A Little Story About a Monstrous Mess: Investigating the toxic residues in children’s clothing from China’s largest manufacturing towns http://www.greenpeace.org/eastasia/publications/reports/toxics/2013/little-story-monstrous-mess/ 7

3. Policy On March 1 of 2013, China’s regulation “Measures for the Environmental Management Registration of Hazardous Chemicals (for Trial Implementation)38” came into force. This is a first in terms of regulations that manage the production and release of existing hazardous chemicals in China. Enterprises using and producing chemicals listed in the regulation are required to report the discharge and transfer data of listed chemicals before January 31 of every year. January 31, 2014 will be the first deadline for such enterprises, following the regulation being put into effect. This data must be made publically available via the "Pollutants Release and Transfer Register" (PRTR), and as outlined in the government regulation.

Today, China is the biggest manufacturer and user of chemicals in the world. There are over 45,000 chemicals39 being used, sold and/or manufactured in China, and many of them are hazardous chemicals, including the endocrine disruptor Nonylphenol and phthalates, which are widely used across different industries. This makes the PRTR extremely necessary.

Having a PRTR (Pollutant Release and Transfer Registers) system in place will push the factories to disclose information to the public, help the authority to collect data on the pollutants, enhance the implementation of the environmental regulations and public participation in monitoring of the pollution, and thereby promoting voluntarily industrial actions to reduce and eliminate toxic chemicals from the source.

Greenpeace is calling for The Chinese government to implement the “Measures for the Registration of Dangerous Chemicals for Environmental Management” as soon as possible, and urge the factories to submit Release and Transfer Report of Priority Chemicals for Environmental Management in time.

The pollutant release and transfer information should be disclosed to the public on a centralized platform which is easily accessible for the general public, so that under public monitoring the industry can reduce and eliminate the discharge of toxic chemicals.

PRTR (Pollutant Release and Transfer Registers) in other countries PRTR (Pollutant Release and Transfer Registers) is already in force in over 40 countries including all EU members, US, Norway, Turkey, Japan, Korea, Chile and many other nations. It is a significant contribution to information transparency and public participation in environmental decision-making.

A PRTR successfully pushes facilities to voluntarily reduce the usage of hazardous chemicals. For example, between 1988 and 2008, or a span of 20 years in which the US carried its own Toxic Releases Inventory (TRI), manufacturing facilities in the US decreased their disposal and release of toxic chemicals by 65%40.

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http://www.zhb.gov.cn/gkml/hbb/bl/201210/t20121016_238481.htm On Jan 30th 2013, China MEP issued the 2013 version of the Inventory of Existing Chemical Substances in China (IECSC 2013) in PDF. The IECSC 2013 contains 45,612 substances. http://www.crc-mep.org.cn/M006/M006_C1.aspx 39

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http://nepis.epa.gov/Exe/ZyNET.exe/P1005POG.txt?ZyActionD=ZyDocument&Client=EPA&Index=2006%20Thru%202010&Docs=&Qu ery=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&Use 8

The Japanese PRTR, which was introduced in 2001 and covers 462 designated chemical substances (Class I) in 23 sectors and 34,830 facilities, showed a reduction of 24.5% in total annual releases (and waste transfers) of hazardous substances between 2001 and 2008. However, there was no significant reduction for facilities releasing smaller quantities of designated chemical substances (Class II), and which are not required to disclose their releases publicly.41 E-PRTR The European Pollutant Release and Transfer Register (E-PRTR) is the PRTR system for European Union Member States, as well as Iceland, Liechtenstein, Norway, Serbia and Switzerland. It contains chemical data reported annually by more than 30,000 industrial facilities, and covers 65 different economic activities across Europe42, including wastewater treatment plants, plants for pre-treatment (operations such as washing, bleaching, mercerisation) or dyeing of fibers or textiles.

Any facility that falls under the 65 economic activities and releases any of the 91 pollutants beyond threshold, must report this under the E-PRTR. For different pollutants there are different thresholds. For example, nonylphenol and nonylphenol ethoxylates (NP/NPEs) has a release threshold of 1 kg/year to water or land.43 Some industry leaders have set a good example for information disclosure The public’s "Right to Know" about the chemical-by-chemical discharge from an individual supply chain facility used by big brands is becoming a reality. Since 2011, the Greenpeace44 Detox campaign has challenged the textile industry to eliminate toxic chemicals and disclose factory level discharge information. With the support of hundreds of thousands of consumers around the globe, the Detox campaign has secured commitments from 18 leading companies in the industry. Among them, Including Mango, Fast Retailing(Uniqlo), Inditex, H&M, Benetton, Valentino, G-Star, M&S, Limited Brands, C&A, Puma, Coop, Canepa and Esprit – have ensured they begin the publication of data from their suppliers about discharges of hazardous chemicals, on the global online platform IPE45. By December 31, 2013, there have already been more than 80 facilities46 that have begun disclosing data related to their chemical discharges, proving that transparency is not only desirable but also achievable.

QField=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5CZYFILES%5CINDEX%20DATA%5C06THRU10%5CTXT%5C000000 13%5CP1005POG.txt&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C-&MaximumDocuments=1&FuzzyDegree=0&I mageQuality=r75g8/r75g8/x150y150g16/i425&Display=p%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc= Results%20page&MaximumPages=1&ZyEntry=1&SeekPage=x# 41 Nakachi S (2010). The Pollutant Release and Transfer Register (PRTR) in Japan and Korean Toxic Releases Inventory (TRI) – an evaluation of their operation, Tokyo: Toxic Watch Network http://www.toxwatch.net/en/pdf/PRTR_JAPAN_1206.pdf 42 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:033:0001:0017:EN:PDF#page=8 43 http://prtr.ec.europa.eu/docs/Summary_pollutant.pdf 44 Only in this sentence, “Greenpeace” refers to “Greenpeace International”.

45 The IPE online platform (in China) is an existing well known and independent relational, and publicly accessible, database including a section that provides voluntarily disclosed data on company emissions, consumptions and pollutant discharges and also discharges and emissions of hazardous chemicals searchable by facility name, activity, date, location and/or individual pollutant. The Internet platform will be direct data entry with the necessary procedures for security and data verification. The IPE disclosure platform is used to ensure the discharges data of various supplier facilities are easily accessible, centralized and searchable via consistent credible content and form. These data may additionally be shared via the brand and supplier’s website. But, these additional forms of data distribution will not be a substitute/replacement for China supplier disclosure via the IPE platform. IPE is an independent non-profit, non-governmental organization that, on occasion, may also work on similar issues as Greenpeace.

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http://www.ipe.org.cn/pollution/discharge_detox.aspx

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