The plan’s stricter and more targeted requirements will impact a broader range of provinces, including the Fen-Wei Plains.

By Paul A. Davies and R. Andrew Westgate

China has released a new three-year action plan for 2018 to 2020 to combat air pollution. The previous air pollution action plan, published in 2013, has played a significant role in improving air quality in major cities. China’s updated plan, which was released on July 3, draws on additional information and research to provide more targeted requirements.

Success of the 2013 plan

The former plan set a coal cap across China with varying limits in different provinces. For example, the plan required Beijing to reduce its coal consumption by half from 2015 to 2018. The plan’s success was due in part to the state’s ownership of a large number of China’s worst polluters, making them easier to control. Furthermore, because half of China’s pollution comes from coal-burning power stations, the country needs a less varied range of policies to order to target pollution compared with other countries.

Key policies of 2020 action plan

PM2.5 limits

The 2013 plan set strict limits for fine particulate matter (PM2.5) at an estimated cost of US$38 billion. In Beijing, coal power stations were actually forced to shut down and inhabitants of nearby areas were prohibited from burning coal for heating. Although arguably drastic, these measures proved effective: Beijing’s PM2.5 levels fell by more than a third; and the Beijing-Tianjin-Hebei region, the Pearl Delta, and the Yangtze Delta all beat their PM2.5 reduction targets.

Yet despite these successes, no major cities in China meet the World Health Organization’s recommended annual average PM2.5 standard of 10µg/m³.

The new plan sets even stricter targets, requiring cities to achieve a decrease of a minimum of 18% in PM2.5 levels compared with a 2015 baseline in cities of prefectural or higher level, and where these targets have not yet been achieved. The new plan also goes much further in its scope than the 2013 action plan, which applied solely to the city clusters of Beijing-Tianjin-Hebei and the Pearl and Yangtze Deltas. The 2020 plan covers 82 cities throughout China (including Linfen in Shanxi) that will also need to initiate anti-smog measures.

Ozone exposure protection measures

High concentrations of ozone at ground level can harm people’s health by causing respiratory issues (among other problems), and its production has been increasing amid hotter conditions. In fact, ozone has become the main polluter in the Pearl River Delta. On an even broader scale, studies have shown that average ozone levels in China in June have increased by 11% compared with 2017.

Against this backdrop, the plan sets further targets for the reduction of volatile organic compounds (VOCs) by 10%, and for the reduction of nitrogen oxides by 15% by 2020 (based on a 2015 baseline).

New regional target for the Fen-Wei Plains

The new plan identifies the Fen-Wei Plains as China’s most problematic region. The Fen-Wei Plain area contains the country’s highest levels of sulphur dioxide pollution, as well as some of the highest levels of PM2.5 — which increased by more than a quarter between 2015 and 2017.

As a result, the local government of the Fen-Wei Plains will face greater scrutiny from China’s central government. On the other hand, the Fen-Wei Plains will benefit from increased financial and technical assistance to help achieve necessary changes under the action plan — including a significant decrease in coal consumption by 2020.


China’s new action plan represents notable progress in combatting climate change and air pollution, by requiring “large reductions in total emissions of major pollutants in coordination with reduction in emissions of greenhouse gases”. Under the stricter and more targeted requirements, a broader range of regions are likely to substantially cut PM2.5, VOC, and nitrogen oxide production, while decreasing coal consumption. As a result, the plan will likely shape how business is done in China’s manufacturing economy, both immediately and for the long-term.

This post was prepared with the assistance of Olivia Featherstone in the London office of Latham & Watkins.