China Updates Soil Contamination Risk Screening Standards: 5 Key Takeaways for Foreign Enterprises

On 28 March 2025, China’s Ministry of Ecology and Environment (MEE) released the revised Soil Environmental Quality Risk Control Standard for Soil Contamination of Development Land (GB 36600-2025, 土壤环境质量标准, tǔrǎng huánjìng zhìliàng biāozhǔn), expanding the list of priority screening pollutants from 85 to 127 specific parameters. This is the first major revision since the original standard took effect in 2018, and it applies to all industrial and commercial sites undergoing land-use change or redevelopment across 31 provinces. For foreign-invested enterprises operating manufacturing, warehousing, or chemical facilities in China, the update introduces stricter baseline requirements for soil investigations and remediation, directly affecting site acquisition, lease renewal, and exit liabilities.

What Changed in the 2025 Soil Risk Screening Update

The revised standard replaces GB 36600-2018 and introduces 42 new screening parameters, including 36 organic compounds and 6 inorganic pollutants. Key additions include polychlorinated biphenyls (PCBs), perfluoroalkyl and polyfluoroalkyl substances (PFAS), and several pesticides previously unregulated in development-land soil screening. The screening values — the contaminant concentrations above which a site must undergo detailed risk assessment — have been tightened for 11 substances already covered in the 2018 version. For example, the screening value for benzo[a]pyrene (a polycyclic aromatic hydrocarbon) was reduced from 1.5 mg/kg to 0.8 mg/kg, reflecting more conservative health-risk thresholds.

The standard also clarifies the scope of “development land” to explicitly include brownfield sites, former industrial zones, and land converted from agricultural use to commercial or residential purposes. A new appendix provides regional adjustment factors for 6 geographic zones (e.g., North China Plain, Yangtze River Delta), allowing local authorities to apply site-specific screening values based on background soil concentrations. This change means that a site in Shanghai may face different screening thresholds than an identical site in Sichuan, adding complexity for multi-site enterprises.

Why This Matters for Foreign-Invested Manufacturing and Industrial Sites

The updated standard directly impacts three critical compliance events for foreign enterprises: (1) new site acquisitions where environmental due diligence is required, (2) lease renewals or extensions for existing industrial facilities, and (3) site exit or land return to local government upon closure. Under China’s Soil Pollution Prevention and Control Law (2019, 土壤污染防治法, tǔrǎng wūrǎn fángzhì fǎ), the party responsible for soil contamination — often the current occupant or the party that caused the contamination — bears cleanup liability regardless of property ownership. The expanded parameter list means that many sites previously “cleared” under the 2018 standard may now trigger new investigation obligations.

For foreign companies with older industrial sites (pre-2018 construction), the risk is particularly acute. Sites in chemical, metal processing, textile dyeing, and electronics manufacturing are most likely to encounter newly regulated pollutants such as PFAS (used in firefighting foams, coatings, and electroplating) and PCBs (common in old transformers and hydraulic fluids). A 2024 survey by the China Soil Alliance found that 34% of industrial sites in the Yangtze River Delta tested positive for at least one PFAS compound at concentrations above the new screening values. Without proactive assessment, foreign enterprises may face remediation costs ranging from 500 to 5,000 RMB per metric ton of contaminated soil, depending on pollutant type and site size.

Implementation Timeline and Transition Deadlines

The revised standard takes effect on 1 June 2025, but the transition rules contain critical nuances for ongoing projects. For site investigations already submitted to local environmental authorities before 1 June 2025, the 2018 standard applies. However, any investigation report submitted after that date must comply with GB 36600-2025. For remediation projects currently under construction, the responsible party must complete a gap assessment by 1 September 2025 to determine whether the new screening values require additional remediation scope.

Separately, the MEE has indicated that local environmental bureaus (EPBs) in 10 pilot provinces — including Jiangsu, Zhejiang, Guangdong, and Shandong — have been directed to prioritize enforcement on sites where land-use change applications are filed after 1 January 2026. This provides a de facto grace period for enterprises to conduct updated soil investigations before the peak enforcement window begins. Foreign companies should budget for site assessment costs of approximately 80,000–200,000 RMB per 10,000 square meters for a Phase II investigation covering all 127 parameters, compared to 50,000–120,000 RMB for the 85-parameter scope under the 2018 standard.

Compliance Actions for Enterprises Operating on Former Industrial Land

For foreign enterprises with existing operations on development land, the first step is to conduct a desktop gap analysis comparing your site’s existing soil investigation data against the new 127-parameter list. If your most recent Phase II investigation only covered the original 85 parameters, you need to determine which of the 42 new substances are likely to be present based on your industry and historical operations. The MEE has published guidance tables — available in Chinese only — that map industrial sectors to the newly added pollutants. For example, Surface Treatment and Coating (C3360 in China’s industrial classification) is flagged for PFAS and organophosphates; Transformer Manufacturing and Repair (C3821) is flagged for PCBs.

Where gaps are identified, enterprises should prioritize sampling for those specific parameters at a subset of locations (e.g., near historical waste storage areas, chemical handling zones, and drainage points). The up-front cost of targeted gap sampling (15,000–40,000 RMB per site) is far lower than full re-screening, and regulators generally accept gap reports as interim documentation. For sites undergoing land-use change (e.g., converting an industrial plot to mixed-use development), full 127-parameter screening is mandatory — no shortcuts are allowed.

Decision Framework for Soil Compliance Strategy

If your site is on development land transferred or acquired before 2018, choose a full Phase II investigation covering all 127 parameters, because historical records are often incomplete and legacy contamination is likely. If your site was built after 2018 on greenfield land with documented clean-background soil data, choose a targeted gap analysis limited to industry-flagged pollutants, which saves approximately 40–60% of investigation costs while still satisfying due diligence requirements. If your site is undergoing land-use change (e.g., industrial to residential), choose a comprehensive investigation plus a quantitative risk assessment (QRA) for any parameters exceeding screening values, because local EPBs typically require QRA for land-use changes regardless of the standard version.

Key Takeaways for Your Environmental Compliance Strategy

The GB 36600-2025 update signals a clear regulatory trend: China is aligning its soil screening standards with international best practices, particularly for emerging contaminants like PFAS and PCBs. For foreign enterprises, this means that soil liability is no longer limited to “traditional” heavy metals and VOCs but extends to a broader chemical footprint. Budgeting for environmental due diligence should increase by 20–40% over 2024 levels to account for expanded laboratory testing, regional adjustments, and longer review cycles. Proactive compliance — conducting gap assessments before regulators require them — remains the most cost-effective approach, as remediation costs after enforcement action are typically 2–3 times higher than voluntary cleanup under a remediation plan approved by the EPB.

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