ESG Gazette, China- September 2025

Summary

• The Ministry of Finance (MOF), in collaboration with nine ministries and commissions, has formally issued the Application Guide for the Corporate Sustainability Disclosure Standards - Basic Standards (Pilot), offering a practical operational framework for corporate sustainability information disclosure.
• The EU Data Act  has been officially implemented, reshaping the global data governance landscape.
• The Ministry of Commerce issues the Guidelines on Integrity and Compliance for Enterprises Operating Overseas, to bolster "Go Global" enterprises building a solid compliance defense line.
• To solidly advance the green and low-carbon transformation of industry and promote synergistic improvements in pollution reduction and carbon mitigation, the Ministry of Ecology and Environment, the National Development and Reform Commission, and the Ministry of Industry and Information Technology have jointly formulated the Action Plan for Controlling Industrial-Sector Nitrous Oxide (N₂O) Emissions.
• Aiming to strengthen the top-level design of China’s climate change response standard system, fully leverage the foundational, normative, and guiding roles of standards in climate action, accelerate the establishment of a scientifically robust, systematically structured national climate change standard framework, and support the development of new quality productive forces, the green and low-carbon transformation of economic and social development, and the construction of a Beautiful China, the Ministry of Ecology and Environment and 14 other departments has jointly gazetted the Construction Plan  of National  Standard System for Responding to Climate Change.
• The Law of the People's Republic of China on the Prevention and Control of Infectious Diseases is a milestone in China's public health legal framework. It is a significant measure to adhere to the principle of putting people and lives first, to strengthen the legal assurance of public health, and to improve the construction of relevant laws and regulations in the field of public health. This revision aims at preventing and resolving major risks in the field of public health, improving the mechanisms for major epidemic prevention and control, effectively coordinating epidemic prevention and control with economic and social development, and improve the system in a targeted manner.
• The publication and implementation of General Specification for Safety Production Standardization of Hazardous Chemical Enterprises will provide a standard basis for the construction of safety production standardization in hazardous chemical enterprises. It will play an important role in consolidating the grassroots foundation of enterprises, improving their intrinsic safety level of enterprises, enhancing the ability to prevent and control major safety risks, and effectively preventing and containing major and particularly serious accidents.
• To strengthen judicial guidance, unify legal application, implement China's labor employment and social security system, and actively promote the construction of harmonious labor relations, the Supreme People's Court has formulated and issued the Interpretation (II) on Issues Concerning the Application of Law in the Trial of Labor Dispute Cases.
• The Shanghai Municipal Human Resources and Social Security Bureau, along with four other departments, has officially issued the Notice on Implementing Social Insurance Subsidies for Employers During Female Employees' Maternity Leave and Childbirth Leave, introducing a significant new maternity support policy.
• Updated Minimum Wage Standard of Beijing and Tianjin Municipality. 

Contents

Comprehensive

• < Application Guide for the Corporate Sustainability Disclosure Standards - Basic Standards (Pilot) >
• EU < Data Act >
• < Guidelines on Integrity and Compliance for Enterprises Operating Overseas >

Environment

• < Action Plan for Controlling Industrial-Sector Nitrous Oxide (N₂O) Emissions >
• < Construction Plan of National Standard System for Responding to Climate Change >

Health and Safety

• < Law of the People's Republic of China on the Prevention and Control of Infectious Diseases > 
• < General Specification for Safety Production Standardization of Hazardous Chemical Enterprises >

Labour

• < Interpretation (II) on Issues Concerning the Application of Law in the Trial of Labor Dispute Cases >
• < Notice on Implementing Social Insurance Subsidies for Employers During Female Employees' Maternity Leave and Childbirth Leave > of Shanghai Municipality

Minimum Wage Standard Update

• Beijing Municipality , Tianjin Municipality

Summary of Law Updates:

Comprehensive

1. < Application Guide for the Corporate Sustainability Disclosure Standards - Basic Standards (Pilot) > (2025-09-03)

The Application Guide for the Corporate Sustainability Disclosure Standards - Basic Standards (Pilot) (hereinafter referred to as the Guide) was jointly released by the MOF and the nine ministries on 3^rd September 2025. Serving as a complementary document to the Basic Standards, the Guide sets forth four fundamental requirements:

1) Dynamic Value Chain Management: Enterprises should define the scope of their value chain based on " critical information impacting future prospects," adhering to the principle of proportionality. They are obligated to re-evaluate risk coverage in the event of value chain restructuring, business model alterations, or significant changes in ESG risks.

2) Disclosure of Information Relevance: It underscores the necessity of establishing quantitative correlations between sustainability information and financial statements (e.g., fluctuations in assets, liabilities, and cash flows), while requiring logical connections with non-financial sections in annual reports, such as "Management Discussion & Analysis," to unveil strategic synergies.

3) Standardized Materiality Assessment: The Guide introduces a four-step assessment process encompassing dimensions such as risk probability, financial impact severity, scale of influence, and irremediability. It introduces tools such as scenario analysis and stakeholder surveys to bolster the assessment process.

4) User-oriented Design: It clearly identifies investors and creditors as primary users, requiring that disclosed information fulfills their investment decision-making and risk assessment requirements. Simultaneously covering a diversifying group, including government regulators, business partners (suppliers/clients), and social partners (NGOs/communities).

Voluntarily implemented from the date of its release, the Guide takes a crucial step in China's transition from policy formulation to practical implementation in sustainability disclosure, facilitating enterprises to achieve the transformation from "compliance-driven disclosure" to "value-driven creation."

2. EU < Data Act > (2025-09-12)

On 12^th September 2025, the EU Data Act (hereinafter referred to as the Act) officially came into effect. As the world's first comprehensive legislation targeting the circulation of data from the Internet of Things (Internet of Things, IoT), the Act aims to break data monopolies, promote fair sharing, and inject new impetus into the EU's digital single market. Its influence is rapidly extending from the EU to the global industrial chain.

The Act  focuses on three core areas: 

• In terms of user data sovereignty, it grants consumers and enterprise users absolute control over the data generated by their connected devices (such as smart cars and industrial sensors), requiring data holders to provide free, real-time data access interfaces and support secure transfers to third parties. This enables users to independently determine the flow of data, thereby breaking the previous situation where data was monopolized by platforms. 

• In terms of public data access, governments are allowed to mandatorily obtain private sector data in emergencies such as public health crises and natural disasters, however, usage must be strictly limited with non-essential data subsequently destroyed to safeguard public interests while preventing misuse.

• In terms of corporate competition rules, large technology platforms (e.g. gatekeeper enterprises) are prohibited from acquiring non-personal data. Simultaneously, protecting small and medium-sized enterprises (SMEs) from unfair contractual terms through standard contractual clauses, fostering a fair competitive market environment.

The Act  has far-reaching implications for the global industrial chain. As an important trading partner of the EU, China's IoT device exporters and cloud service providers need to prioritize adjusting their data compliance strategies, such as strengthening default data openness features in devices and establishing cross-border data transfer risk assessment mechanisms. Furthermore, enterprises should enhance cooperation with local EU data compliance service providers and proactively deploy data storage and processing architectures that meet the requirements of the Act to mitigate trade risks and market access barriers arising from non-compliance.

3. < Guidelines on Integrity and Compliance for Enterprises Operating Overseas > (2025-06-13)

On 13^th June 2025, the Ministry of Commerce issued the Guidelines on Integrity and Compliance for Enterprises Operating Overseas (hereinafter referred to as the Guidelines), providing systematic compliance guidance for "go global" enterprises in overseas operations. The Guidelines explicitly require enterprises to establish a comprehensive compliance system covering organizational structure, management systems, integrity culture, and oversight and accountability. They stress integrating anti-bribery standards into business processes and emphasis independently setting up integrity and compliance management bodies to ensure the separation of internal control mechanisms from business decision-making.

The Guidelines specifically point out that enterprises need to conduct rigorous reviews of major projects, partners, and contractual terms, strengthen accounting audits and risk assessments, and implement regular rotation of key personnel such as heads of overseas branches and financial personnel. Concurrently, enterprises are required to incorporate integrity and compliance into corporate culture building, enhance compliance awareness among Chinese and foreign employees through regular training, and establish whistleblowing mechanisms to safeguard the supervisory rights of employees, clients, and third parties.

In response to cross-border compliance risks, the Guidelines clarify that enterprises must adhere to both Chinese and host-country laws and regulations, as well as international rules such as the United Nations Convention against Corruption, to avoid international sanctions due to non-compliance. Notably, the Guidelines represent the first ministerial-level recommendation for enterprises to refer to the ISO 37001 anti-bribery management system standard when building their compliance frameworks, providing a practical pathway to enhance global competitiveness.

The release of the Guidelines signifies the Chinese government's deepened commitment to promoting integrity construction in the Belt and Road Initiative and provides robust institutional safeguards for enterprises engaging in international operations.

 

Environment

1. < Action Plan for Controlling Industrial-Sector Nitrous Oxide (N₂O) Emissions > (2025-08-27)

The Action Plan for Controlling Industrial-Sector Nitrous Oxide (N₂O) Emissions (hereinafter referred to as the Action Plan) has been jointly gazetted by the Ministry of Ecology and Environment, the National Development and Reform Commission, and the Ministry of Industry and Information Technology on 27^th August 2025. The main contents are as below:

1) The Overall Requirements of the Action Plan

• By 2030, significantly enhance technological innovation capabilities in emission reduction and emission management abilities through the further refinement of relevant control policies. This will effectively improve the control and recycling of nitrous oxide emissions in the industrial sector, driving a continuous decline in nitrous oxide emissions per unit of product in the adipic acid, nitric acid, and caprolactam industries.

2) The Key Tasks of the Action Plan

• Promote nitrous oxide (N₂O) emission reduction. Promote enterprises producing adipic acid, nitric acid, and caprolactam to implement measures for reducing N₂O emissions, such as utilizing treatment equipment and installing catalysts, to minimize N₂O discharges. Additionally, encourage adipic acid producers to recover and purify N₂O tail gas, and encourage the recycling and utilization of nitrous oxide. Encourage adipic acid producers to recover and purify the tail gas of nitrous oxide and encourage the recycling and utilization of nitrous oxide.

• Improve supporting policies for nitrous oxide (N₂O) emission control. Explore the utilization of relevant funding channels to support the construction of N₂O recovery and purification facilities, as well as emission reduction installations in the adipic acid,nitric acid, and caprolactam industries. Encourage the development of climate investment and financing initiatives and recommend projects with N₂O emission reduction benefits for inclusion in the ecological and environmental protection financial support project repository and climate investment and financing pilot project repository. Accelerate the adoption of market-based mechanisms, such as voluntary greenhouse gas emission reduction trading, to incentivize N₂O emission reductions in the industrial sectors.

• Strengthen technological innovation. Continuously advance research and development of key technologies in source and process controls, resource reutilization, monitoring, and emissions reduction. Implement demonstration projects for NO emissions control technologies. Support the inclusion of industrial-sector N₂O emissions control technologies into the National Catalogue of Key Low-Carbon Technologies for Promotion. Promote the development and application of catalysts for N₂O emissions reduction in the industrial sector. Accelerate the integration and industrialization of N₂O emissions control equipment and technologies in key sectors. Promote the establishment of an industry-academia-research alliance for industrial N₂O emissions control to enhance industrial N₂O reduction capabilities effectively.

• Strengthen synergistic control of N₂O in the industrial sectors. Enhance coordinated management of N₂O alongside nitrogen oxides, volatile organic compounds (VOCs), and other pollutants in industrial processes. Explore the establishment of a synergistic control framework and conduct research on the mechanisms for green ammonia co-firing[-related] N₂O emissions. Conduct policy research on the synergistic control of industrial-sector N₂O emissions and protection of the ozone layer. Investigate the incorporation of N₂O emissions assessment into environmental impact assessments for construction projects in key industries, including the adipic acid, nitric acid, and caprolactam industries, etc., and propose synergistic pollution control and carbon emissions reduction measures.

• Strengthen the system construction of monitoring, reporting, and verification for industrial-sector N₂O emissions. Advance the establishment of an N₂O emissions reporting system for key enterprises, research and formulate monitoring standards and related emission standards for industrial-sector N₂O and explore the implementation of automated monitoring of industrial-sector N₂O emissions sources. Enhance the quality management of industrial-sector N₂O emissions data and continuously improve professional capabilities.

• Strengthen international exchanges and cooperation. Uphold multilateralism and leverage the primary role of the United Nations Framework Convention on Climate Change. Adhere to the principles of common but differentiated responsibilities, equity, and respective capabilities. Actively participate in global exchange, dialogue, and cooperation on industrial-sector N2O emissions control in the industrial sector.

2. < Construction Plan of National Standard System for Responding to Climate Change > (2025-05-28)

The Construction Plan of National Standard System for Responding to Climate Change (hereinafter referred to as the Construction Plan) has been jointly gazetted by the Ministry of Ecology and Environment and 14 other departments, on 28^th May 2025. The main contents are as below:

1) Main Objectives of the Construction Plan

• Adhering to the principle of 'urgent needs first, gradual improvement,' the Construction Plan will facilitate the phased and batch-based development and revision of a series of critical standards covering all fields, elements, and links, enhance the forward-looking nature and operational feasibility of standards, thereby fully leveraging their foundational supporting and normative guiding roles in climate change response efforts.

• Strengthen inter-departmental coordination to promote the alignment and integration of standards across all levels and all sectors, fostering synergistic standards system.

• Actively participate in the formulation of relevant international standards, enhance the global influence of Chinese standards, and advance international mutual recognition and convergence of standards.

2) The Construction Plan establishes a framework of standard system for responding to the climate change from three dimensions: foundational capabilities, climate change mitigation, and climate change adaptation, which is further subdivided into 15 categories of secondary standards and 45 categories of tertiary standards. It also elaborates on the functional positioning of each secondary subsystem and outlines key tasks for the development and revision of standards.

• The foundational capability support standard system primarily comprises four categories of standards: general foundations, greenhouse gas (GHG) accounting, GHG verification, and GHG monitoring.

• The climate change mitigation standard system comprises six categories of standards: climate change mitigation action standards, market-based mechanism management norms, GHG emission standards, technical specifications for coordinated management of GHG and pollutants, climate change mitigation evaluation standards, and climate change mitigation technology management norms.

• The climate change adaptation standard system comprises five categories of standards: climate change observation and projection standards, climate change impact and risk assessment standards, climate change adaptation action standards, climate change adaptation technology standards, and effectiveness evaluation standards for climate change adaptation actions.

3) Specific Measures for Implementing the Construction Plan

• Strengthen organizational implementation, with the Ministry of Ecology and Environment and the State Administration for Market Regulation enhancing overall coordination and work scheduling, while relevant departments advance implementation in line with their respective responsibilities and provide strengthened guidance for the development of the standardization system.

• Refine working mechanisms, strengthen coordinated oversight of standards in key sectors, and enhance the evaluation and updating of climate change adaptation standards.

• Strengthen capacity building, with relevant departments enhancing technical support for system development, reinforcing work guarantees through multiple channels, and effectively promoting the dissemination and implementation of standards.

• Promote international cooperation, tracking and studying developments in relevant international standards, actively participating in their formulation, conducting international standard training programs, and strengthening international alignment and mutual recognition of standards.

 

Health and Safety

1. < Law of the People's Republic of China on the Prevention and Control of Infectious Diseases > (2025-09-01)

The Law of the People's Republic of China on the Prevention and Control of Infectious Diseases (hereinafter referred to as the Prevention and Control Law) was amended for the second time at the 15^th meeting of the Standing Committee of the 14^th National People's Congress on 30^th April 2025. It has been effective since 1^st September 2025. The main revisions to the Prevention and Control Law are as follows:

1) The Prevention and Control Law explicitly classifies "novel coronavirus infection" in the management of Class B infectious diseases and has added "monkeypox" as a Class B infectious disease; Newly added "Hand-Foot-Mouth Disease" in Class C infectious diseases; The procedure has been adjusted more detailed, and sudden infectious diseases can be temporarily managed as Class A diseases.

2) The Prevention and Control Law has added a "multi-point triggering, intelligent monitoring and early warning system" to integrate data sharing among multiple departments.

3) The newly added provisions of the Prevention and Control Law clarify the compliance requirements for personal information processing in the prevention and control of infectious disease, such as prohibiting excessive collection and ensuring security.

4) The Prevention and Control Law specifies that "online direct reporting" is a mandatory requirement and adds reporting obligations for inspection and testing institutions.

5) The Prevention and Control Law has added content to strengthen the integration of traditional Chinese and Western medicine, emphasizing the role of traditional Chinese medicine in the prevention and control of infectious diseases.

6) The Prevention and Control Law further clarifies the penalties of fines and license revocation for the behaviors such as refusing to cooperate with prevention and control measures and intentionally spreading infectious diseases.

2. < General Specification for Safety Production Standardization of Hazardous Chemical Enterprises > GB45673-2025 (2025-11-01)

The General Specification for Safety Production Standardization of Hazardous Chemical Enterprises (hereinafter referred to as the Specification) was jointly issued by the State Administration for Market Regulation and the National Standards Administration on 25^th April 2025, and will come into effect on 1^st November 2025. The Specification proposes the following management requirements:

1) Safety leadership. This includes safety production policy objectives, safety commitments, organizational structure, safety production investment guarantee, safety production informatization and intelligence construction, responsible leadership, and safety culture construction.

2) Safety production responsibility system. This includes the establishment, implementation, inspection, and improvement of the safety production responsibility system.

3) Safety production information and compliance audit. This includes safety production information, laws, regulations, standards, and other requirements, safety production rules and regulations, and compliance audits.

4) Safety education and training. This includes education and training management, job competency standards, practitioners, external personnel, assessment and improvement, and training space construction.

5) Construction of safety risk management and dual prevention mechanism. This includes the construction of safety risk assessment, safety risk control and monitoring, and the construction of dual prevention mechanisms.

6) Operational safety. This includes operating procedures, normal operations, start-up and shutdown management, alarm management, handling of abnormal working conditions, and on-site standardized management.

7) Work safety. This includes work permit management, work safety risk analysis, and safety control during the work process.

8) Chemical safety and major hazard sources of hazardous chemicals. This includes identification classification and registration, chemical safety data sheet and safety labels, storage safety, major hazard sources of hazardous chemicals, and safety in analytical laboratory (laboratories).

9) Emergency preparedness and response. This includes emergency rescue organizations, emergency plans, emergency resources, emergency drills, and emergency rescue.

10) Performance evaluation and continuous improvement. This includes performance indicators and continuous improvement.

 

Labour

1. < Interpretation (II) on Issues Concerning the Application of Law in the Trial of Labor Dispute Cases > (2025-09-01)

The Supreme People's Court issued the Interpretation (II) on Issues Concerning the Application of Law in the Trial of Labor Dispute Cases on 31^st July 2025, which officially came into effect on 1^st September 2025, and addresses key issues in labor relations including employer liability, contract renewal, and non-compete restrictions, thereby providing judicial safeguards for harmonious labor relations.

Key Highlights:

1) Clarifies subcontracting liability: Lawful contractors subcontracting to unqualified entities shall be liable for unpaid wages and work-related injury compensation when such subcontracting occurs, to curb the chaos of wage arrears.

2) Strengthens protection for open-ended contracts: Where contracts are extended for a cumulative period of one year or more or liability is evaded through entity changes, such actions shall trigger the recognition of two consecutive fixed-term contracts, thereby curbing short-term employment practices.

3) Optimize non-compete restrictions: Such restrictions shall be deemed invalid if employees have not accessed to trade secrets; such restrictions remain enforceable during employment for executives and technical personnel.

4) Severely punish violations of social insurance obligations: Deny the validity of the "abandonment of social insurance commitment". The employees can determine the labor contract with economic compensation when employers fail to fulfill such obligations.

Comprising 20 articles, the interpretation strikes a balance between employee rights and corporate development, contributing to China’s goal of achieving high-quality and sufficient employment.

2. < Notice on Implementing Social Insurance Subsidies for Employers During Female Employees' Maternity Leave and Childbirth Leave > of Shanghai Municipality (2025-07-18)

The Shanghai Municipal Human Resources and Social Security Bureau, together with four other departments, has officially issued the Notice on Implementing Social Insurance Subsidies for Employers During Female Employees' Maternity Leave and Childbirth Leave (hereinafter referred to as the Notice). The new policy aims to establish a cost-sharing mechanism for childbirth expenses involving the government, society, and enterprises, further promoting a "childbirth-friendly" value orientation. Through the coordinated policies of "childbirth-friendly positions" and "maternity leave social insurance subsidies," it seeks to minimize employment barriers for women and facilitate their high-quality and full employment.

The Notice stipulates that starting from 1^st January 2025, if a female employee gives birth while employed and her employer provides her with maternity leave and childbirth leave in accordance with the law and pays social insurance premiums, the employer may apply for a maternity leave social insurance subsidy. The subsidy will cover 50% of the employer's actual contributions to the female employee's basic endowment insurance, basic medical insurance (including maternity insurance), unemployment insurance, and work-related injury insurance during the maternity leave and childbirth leave periods, with the subsidy being provided for six months starting from the month of childbirth.

The Notice clarifies that the maternity leave social insurance subsidy shall be administered according to the principle of " local jurisdiction, with payment preceding subsidy," and shall be distributed in a bundled manner upon a single application. Employers can apply to the local human resources and social security department within one year after the end of the female employee's maternity leave and childbirth leave. Upon approval, a six-month subsidy will be issued in a lump sum.

The Notice has come into force on 18^th July 2025, and remain valid until 17^th July 2030.

China Minimum Wage Standard Update- September 2025

Area	Minimum Wage Standard (RMB/month)
Beijing Municipality: Effective from 1 September 2025
Beijing	2540
Tianjin Municipality: Effective from 1 September 2025
Tianjin	2510