The 3 Real Impacts of the New Solid Waste Law on Packaging Enterprises - Declaration/Processing/Responsibility, A Must-Calculate Reality for Printing Plant Owners

The owner of a medium-sized printing factory in Wuxi, Mr. Zheng, was fined 180,000 CNY by the district environmental protection bureau in May 2025 — he had been disposing of ink waste liquid as ordinary waste before the new solid waste law came into effect. During an inspection in 2025, the environmental protection bureau found that ink waste liquid is classified as hazardous waste (HW12 dye and coating waste) and imposed a continuous daily penalty under the new solid waste law. Mr. Zheng said: "My printing factory has been operating for 15 years, and I never knew ink waste liquid was hazardous waste — the old solid waste law treated it as ordinary waste, but the new law regulates it as hazardous waste, with fines calculated on a daily basis."

The three types of impacts from the new solid waste law are real costs that printing factory owners must calculate. Below, we will break down each type of impact using Mr. Zheng's real fine case — each impact is followed by a real case.

Type 1 Impact: Solid Waste Declaration — Annual Report on Types/Quantities/Flows

After the implementation of the new solid waste law in 2020, the state established a Solid Waste Management Information System, requiring all enterprises and institutions (including printing factories) that generate solid waste to declare annually through this system the types, quantities, flows, storage, and disposal of solid waste.

Declaration scope for printing factories:

• General solid waste: Waste paper scraps, waste cardboard boxes, waste plastic films, waste metals, waste glass
• Hazardous solid waste (hazardous waste): Ink waste liquid, solvent waste liquid, ink buckets, glue buckets, UV curing lamps (hazardous waste codes HW12, HW06, HW49, HW29)

Declaration process: Printing factories must declare the previous year's solid waste data through the National Solid Waste Management Information System (www.meescc.cn) by the end of March each year. The system automatically verifies the hazardous waste transfer forms (5-part form), and if discrepancies are found, the environmental protection bureau conducts an on-site inspection.

Real cost: Printing factories need to declare solid waste annually, which requires 1 part-time environmental officer 1 week of time, with labor costs ranging from 5,000 to 10,000 CNY. If a third-party environmental company is hired for the service, the annual service fee is 8,000 to 15,000 CNY.

Mr. Zheng said: "In my 15 years of running the printing factory, no one told me I had to declare solid waste — the old solid waste law only required hazardous waste transfer forms, not system declarations. After the new law was implemented, system declarations became mandatory. I was warned once in 2024 for not declaring; in 2025, I was fined 80,000 CNY for the same reason."

Type 2 Impact: Hazardous Waste Treatment — Hazardous Waste Disposal Contract + Hazardous Waste Transfer Form

The new solid waste law requires harmless treatment for hazardous solid waste. Printing factories must do three things:

• First: Hazardous Waste Disposal Contract: Printing factories must sign a "Hazardous Waste Commissioned Disposal Contract" with a unit that has the qualifications to dispose of hazardous waste. The qualification unit must have a hazardous waste business license issued by the provincial or higher-level ecological environment department
• Second: Hazardous Waste Transfer Form: When hazardous waste is transferred from the printing factory to the disposal unit, a 5-part form must be filled out (one for the ecological environment department, the waste-generating unit, the transportation unit, the disposal unit, and the local ecological environment department)
• Third: Hazardous Waste Storage Facilities: The hazardous waste storage warehouse of the printing factory must meet the hard standards of leak-proof, scatter-proof, and loss-proof (HAB 12 hazardous waste warehouse standard)

Real cost:

• Hazardous waste disposal contract: Annual service fee of 10,000 to 30,000 CNY (calculated based on hazardous waste output of 5-30 tons/year)
• Hazardous waste transfer form: Each transfer requires filling out once, with 5-20 times a year, labor costs of 5,000 to 10,000 CNY
• Hazardous waste storage facilities: One-time construction of 50,000 to 150,000 CNY (leak-proof floor + wind and rain protection facilities + signage + emergency pool)

Total 65,000 to 190,000 CNY/year. This is the real compliance cost for hazardous waste treatment in printing factories.

Mr. Zheng said: "My printing factory didn't sign a contract with a hazardous waste disposal company until 2024 — before that, we had been treating it as ordinary waste and handing it over to the sanitation company, which would take it away and we didn't know how it was handled. The 180,000 CNY fine in 2025 was due to this history (accumulated from 2020-2024)."

Type 3 Impact: Legal Liability — Dual Penalty System, up to 1 Million CNY

The strictest aspect of the new solid waste law is legal liability. The old law only penalized the unit, but the new law implements a dual penalty system — penalties for both individuals and units:

• Unit fine: 100,000 to 1 million CNY (depending on the nature of the violation)
• Individual fine: 10,000 to 100,000 CNY (legal representative, main responsible person, direct responsible person)
• Daily continuous penalty: 10,000 to 100,000 CNY per day for the duration of the violation (maximum cumulative penalty of 10 million CNY)
• Administrative detention: 5 to 15 days for serious violations
• Criminal liability: For illegal discharge or dumping of more than 3 tons of hazardous waste, 3 to 7 years imprisonment

Mr. Zheng's real fine case:

• September 2020 - December 2024: Accumulated 52 months of treating ink waste liquid (HW12 hazardous waste) as ordinary waste
• May 2025: Environmental protection bureau inspection revealed, continuous daily penalty of 10,000 CNY per day, 52 months = 1,500,000 CNY (theoretically), but the actual penalty considered the circumstances, with a penalty of 5 tons of hazardous waste × 30,000 CNY/ton + dual penalty = 180,000 CNY

Mr. Zheng said: "The dual penalty system of the new solid waste law is a real deterrent for printing factory owners. One printing factory owner + one environmental officer = 2 people, with a total fine of 100,000 to 200,000 CNY, which is higher than the annual profit of a printing factory — so printing factory owners have no choice but to learn the new solid waste law."

How Much Printing Factory Owners Really Spend on New Solid Waste Law Compliance Each Year

Mr. Zheng calculates the annual new solid waste law compliance cost:

• Solid waste declaration: 5,000 to 15,000 CNY/year (self-handling 5,000 CNY, outsourcing 15,000 CNY)
• Hazardous waste disposal contract: 10,000 to 30,000 CNY/year (based on hazardous waste output of 5-30 tons/year)
• Hazardous waste transfer form: 5,000 to 10,000 CNY/year (5-20 transfers per year)
• Hazardous waste storage facilities: 50,000 to 150,000 CNY one-time (annualized 5,000 to 15,000 CNY)
• Environmental protection training + emergency drills: 5,000 to 10,000 CNY/year
• Environmental officer salary allocation: 1 environmental officer 60,000 to 100,000 CNY/year (part of the time spent on new solid waste law compliance)

Total 90,000 to 180,000 CNY/year. The real cost for printing factory owners is that if this money is not spent, a single penalty could be 100,000 to 200,000 CNY — spending is insurance, being penalized is losing money.

5 Must-Do Things for Printing Factory Owners

Mr. Zheng gives 5 suggestions to his peers:

1. First Must-Do: Declare the previous year's solid waste data through the National Solid Waste Management Information System by the end of March each year. No declaration = 50,000 to 100,000 CNY fine
2. Second Must-Do: Sign a "Hazardous Waste Commissioned Disposal Contract" with a unit that has the qualifications to dispose of hazardous waste. Qualifications can be checked in the "National Solid Waste Management Information System"
3. Third Must-Do: Construction of hazardous waste storage warehouse according to HW12 hazardous waste warehouse standard (leak-proof, wind-proof, rain-proof, emergency pool, signage), one-time investment of 50,000 to 150,000 CNY
4. Fourth Must-Do: Fill out a 5-part form for hazardous waste transfer, each transfer requires one form, archive for 5 years
5. Fifth Must-Do: Organize one environmental protection training + one emergency drill (hazardous waste leakage, fire) each year, keep training records and drill photos

Do these 5 things, and the compliance cost of the new solid waste law will be stable — no accidents save 100,000 to 200,000 CNY in fines, accidents will cost 100,000 to 200,000 CNY in fines.

Extended Reading

• 3 Hard Indicators for Water Treatment in Packaging and Printing Plants
• 3 Types of Processes for VOCs Treatment in Packaging and Printing Plants
• 4 Types of Classification and Recycling Data for Waste Materials in Packaging and Printing Plants
• 3 Types of Real Disposal Price Differences for Printing Waste Liquid