SMM August 25 News:
Regarding the issuance of the "Shandong Province Industrial Renewable Resource Recycling and Comprehensive Utilization Standardized Management Measures (Trial)" (hereinafter referred to as the "Management Measures"), SMM understands that this "Management Measures" implemented by Shandong Province is a "local implementation version" of a series of central policy requirements, but it is not a simple transcription of a single central document. Instead, it integrates multiple policy lines from multiple central ministries and commissions over the past year or more to form the first provincial-level full-chain comprehensive management measure.
I. At the central level, it is not "a single document at the beginning of the year" but a gradual accumulation of multiple policy lines
| Time | Central Document/Requirement | Core Content |
|---|---|---|
| 2024.03 | State Council "Action Plan for Promoting Large-Scale Equipment Renewal and Trade-in of Consumer Goods" (Guo Fa [2024] No. 7) | First proposed promotion of "reverse invoicing" |
| 2024.04.29 | State Taxation Administration Announcement No. 5 of 2024 | "Reverse invoicing" officially implemented, specifying a limit of ≤5 million for individual sellers and a 0.5% individual income tax prepayment rate |
| 2025.01 | NDRC and Ministry of Finance "Notice on Intensifying and Expanding the Implementation of the Program of Large-Scale Equipment Upgrades and Consumer Goods Trade-ins in 2025" (Fa Gai Huan Zi [2025] No. 13) | Clearly required "accelerating the implementation of reverse invoicing and regulating the tax order in the resource recycling industry" |
| 2025.03 | MIIT General Office "Notice on Organizing the Application for the 2025 Annual Standard Conditions for the Comprehensive Utilization of Renewable Resources Industry..." (MIIT Jie Han [2025] No. 81) | Relying on six industry standard conditions including the "Standard Conditions for the Processing and Utilization of Waste Copper and Aluminum," organized enterprises across all provinces to conduct applications and in-process and post-event supervision |
| 2025.12.27 | State Council "Action Plan for Comprehensive Solid Waste Treatment" (Guo Fa [2025] No. 14) | First programmatic document on comprehensive solid waste treatment, clearly requiring "strengthening standardized management of the renewable resource comprehensive utilization industry" and "local governments at all levels to earnestly fulfill their main responsibilities" |
| 2025.12.23 | Seven departments "Action Plan for the Promotion and Application of Recycled Materials" (Fa Gai Huan Zi [2025] No. 1681) | By 2030, output of recycled non-ferrous metals to exceed 25 million mt, establishing a full-process traceability system |
II. "Integrated innovation" aspects of Shandong's measures
1. Upgrading from "Three-Flow Integration" to "Five-Flow Integration"
The State Administration of Taxation requires "Three-Flow Integration" (invoice flow, capital flow, and personnel flow) in the promotion of reverse invoicing—the reply letter from Ma'anshan Taxation Bureau in July 2025 explicitly mentioned that a pilot program for "Three-Flow Integration" was being conducted. On this basis, the Shandong measures added "contract flow" and "goods flow", forming a more complete digital supervision chain: contract flow + goods flow + invoice flow + capital flow + information flow = "Five-Flow Integration", which expands and intensifies the central government's "Three-Flow Integration" concept.
2. Building a Provincial-Level Smart Monitoring Platform
At the central level, the Ministry of Industry and Information Technology uses the "Industrial Energy Conservation and Green Development Management Platform" (green.miit.gov.cn) for industry standard enterprise management, while Shandong has specifically built theShandong Provincial Industrial Renewable Resources Recycling and Processing Smart Monitoring Platform, elevating platform registration, information filing, and data submission to management requirements for enterprises.
3. First Systematic Coverage of the "Waste Generation–Recycling–Processing–Waste Utilization" Full Chain
Previously, central policies were fragmented: the MIIT managed standard condition enterprise access, tax authorities managed reverse invoicing, and the NDRC managed the circular economy. The Shandong measures, jointly issued by eight departments (led by the Department of Industry and Information Technology, with the NDRC, Public Security Department, Finance Department, Ecology and Environment Department, Commerce Department, Market Supervision Bureau, and Taxation Bureau), bridged the regulatory gaps between departments.
III. Summary
1. Policy density is accelerating: from March 2024 to September 2026, in less than two years, a complete chain from "action plan → reverse invoicing → standard conditions → solid waste action plan → provincial comprehensive management measures" has been formed from the central to local levels, with a clear policy tightening stance.
2. "Five-Flow Integration" is stricter than "Three-Flow Integration": for the secondary copper industry, this means that the survival space of pure trading intermediaries (with no actual logistics or contract traces) will be further compressed, accelerating the industry's transformation towards substantiation and agglomeration.
3. Shandong, as the core national hub for industrial renewable resources, has taken the lead in issuing measures, which serves as a bellwether—other provinces are likely to follow suit, leading to a nationwide convergence of systems.
4. Tax Regulation Is the Core Lever: The measures specifically target "tax-related risks such as false invoicing and false empty-turn trading," which aligns with the data released by the State Taxation Administration in 2025 regarding "reverse invoicing amounts close to 900 billion yuan" and 14,800 recycling enterprises. This indicates that regulatory attention to tax compliance in the renewable resources industry has reached an unprecedented level.
