The hottest policy helps open a new era of recycli

In recent years, with the further deepening and popularization of General Secretary Xi's concept of "green water and green mountains are golden mountains and silver mountains", the country has carried out many blue sky defense operations. During the operations, it was found that the environmental problems in the transit and temporary storage of waste lead-acid batteries have become increasingly prominent, which has been highly valued by relevant national departments and gradually put on the national key management and control agenda. The Ministry of environmental protection, the national development and Reform Commission, the Ministry of industry and information technology, and the Ministry of housing and urban rural development have introduced a series of measures from the perspective of their respective control, such as the solid waste law, the implementation plan of the extended producer system (GBF [2017] No. 99), the implementation plan of the domestic waste classification system (GBF [2017] No. 26), and the pilot work plan of the waste lead battery collection and transfer management system. The implementation results show that, "The ideal is perfect, and the reality is skinny". The reality is quite different from the system. The method of treating headache and foot pain makes the market more at a loss

in view of this, from the perspective of practitioners, on the basis of years of practice and operation, the author combed out the "two cruxes" of the recycling process of waste lead-acid batteries and the corresponding solutions for reference

I. recycling status of waste lead-acid batteries

as we all know, China has an annual scrap of about 6million tons of lead-acid batteries, showing an increasing trend year by year, and China is also one of the few countries with 100% recycling of waste lead-acid batteries. The drawback is that in the process of recycling, storage, disposal and utilization, there has been a large number of environmental pollution, which has aggravated the wear and tear of cutting equipment, Such as acid pouring, unauthorized disassembly, unauthorized smelting and other problems in the recycling process of waste lead-acid batteries. The fundamental reason is that the collection and temporary storage of waste lead-acid batteries are outside the system, without supervision and restriction

at the same time, in the process of waste lead-acid batteries entering the market, due to the particularity of waste lead-acid battery products, 85% of them are produced in the private sector, and there is no input tax. Although the other 15% comes from waste production units such as China Mobile and China Unicom, most enterprises can only issue ordinary VAT invoices, which is also outside the VAT tax chain, resulting in the gray interest chain. Waste lead-acid batteries regulate that renewable lead enterprises pay a tax of about 2000 yuan per ton of lead metal, which is relatively heavy. However, illegal recycling enterprises have no tax and environmental protection costs. An increase of 200 yuan is enough to pry the whole market of other auto parts, directly creating a disordered and vicious competitive environment

there are two main sticking points that lead to the recycling chaos of waste lead-acid batteries. One is that the storage facilities are not complete, the original records are not standard, the account details are not comprehensive, and the transfer slip is not handled due to the non-standard collection, transfer and temporary storage, resulting in a series of environmental pollution problems, such as a large number of acid pouring, disassembly, flow disorder, illegal smelting and so on; Second, the gray interest chain caused by the incomplete tax chain, resulting in problems such as tax evasion, false Invoicing, bid up prices and so on

II. Analysis of two cruxes of waste lead-acid battery recycling and suggested solutions

crux 1: the transfer and temporary storage of waste lead-acid batteries are not standardized

at present, 100% of domestic waste lead-acid batteries are recycled, of which 85% are recycled by professional recycling enterprises or teams of waste lead-acid batteries, 10% are recycled by renewable lead enterprises, and 5% are recycled by battery enterprises. After the issuance of the No. 99 document of the State Council in 2016, battery manufacturers misinterpreted the policy, believing that waste lead-acid batteries can only be collected by production enterprises, while ignoring the labor output, resource control methods, awareness of hazardous wastes and flow control of professional recycling enterprises. They blindly publicized that "they can only be collected by production enterprises, which can help them exempt storage sites, transportation vehicles and transfer receipts, etc.", Intimidate professional recycling enterprises to cooperate with them and receive waste lead-acid batteries at a low price, with little effect, but at the same time, a series of chaos appeared in the market. Most of the standardized recycling companies gradually figured out ideas in the chaotic market, accelerated the construction of waste lead-acid battery standardization transfer temporary storage base, and effectively carried out the standardization. In addition, the technical conditions at that time were not enough to overcome the shortcomings of hydraulic transmission itself. The new mode of recycling system played a template role in the development of the market, mainly in Sichuan, Shaanxi, Zhejiang, etc, Its waste lead-acid battery collection, transit, temporary storage standards, clear warehouse in and warehouse out account details, strict transfer receipt control, transportation vehicles meet the requirements, and products flow in an orderly manner to standardize renewable lead enterprises, showing a virtuous cycle

however, due to the lack of unified policy support, most provinces can only interpret the original policy according to their own. The support is different, the implementation standards are diverse, and the transfer and temporary storage control of waste lead-acid batteries is still outside the system, which is at stake

on November 7, 2017, vice minister zhaoyingmin of the Ministry of environmental protection presided over a ministerial Symposium. The measures for the administration of hazardous waste business licenses (Revised Draft) (Draft for comments), which was reviewed and approved, was like a thunderbolt on the ground, allowing practitioners and practitioners to get rid of the dense fog and find the crux of the problem. The draft management measures include waste lead-acid batteries into the category of hazardous waste business licenses for the first time, clarify that the business activities of waste lead-acid batteries need to be licensed, and stipulate the scope of use of licenses and the basic requirements for licensing. This plays an important role in the current recycling status of waste lead-acid batteries. After subdivision, the following three advantages are listed:

advantage 1: the government has the basis for law enforcement

before waste lead-acid batteries were not included in the scope of hazardous waste business license, the recycling of waste lead-acid batteries in many provinces, cities and cities was basically all underground activities, and recycling could be carried out anywhere free and hidden, It is difficult for the government to control from the source. The draft gives support to the policy documents of local and municipal governments, requiring waste lead-acid battery recycling enterprises to obtain all certificates for operation. After obtaining the certificates, their business sites are standardized, the transportation vehicles meet the requirements, and the flow direction is controlled by transferring the invoice. The project has been under institutional supervision in an all-round way. The project has been issued with 6 patents at home and abroad, which is easy to control from the source

advantage 2: practitioners have the policy support of obtaining evidence.

with the increasing awareness of citizens and the increasingly strict requirements of environmental protection, professional recycling companies of waste lead-acid batteries urgently need standardized operation, but they suffer from the lack of appropriate policy support. The issuance of the draft is undoubtedly like a long drought and rain, so that practitioners' ideas of standardized operation can be truly implemented. A person in charge of a professional recycling company once said, "we also want to standardize the operation, but without policy support, the government usually does not respond. While we are doing environmental protection, we are worried. This is really not a permanent plan."

advantage 3: the draft clarifies the concept of using the market to manage the market, and provides the correct way and method

after the waste lead-acid battery recycling activities are licensed and operated, the licensed enterprises can operate according to law, curb illegal recycling, and let them naturally withdraw from the historical stage; At the same time, licensed enterprises and licensed enterprises can also mutually supervise the flow of waste lead-acid batteries, so that the market can develop in a standardized and orderly manner

the recycling of waste lead-acid batteries is a part of national urban minerals. There are many practitioners. It is relatively difficult to rely on the personnel of the government environmental protection department to centralize control. Only by using the market to manage the market, can we clearly judge the shortcomings of the industry, find out the crux of the problem, and prescribe a prescription for the disease

to sum up, the crux of the waste lead-acid battery collection and temporary storage specification has successfully found the applicable policy document - the measures for the administration of hazardous waste business license (Revised Draft) (Draft for comments). It is suggested that the Ministry of environmental protection of the people's Republic of China issue an official document as soon as possible to make the waste lead-acid battery recycling market move towards an orderly, environmentally friendly and benign development direction as soon as possible

crux 2: the tax collection chain of waste lead-acid batteries is incomplete

the "tax Crux" of waste lead-acid battery recycling lies in the unique product characteristics of waste lead-acid batteries. 85% of waste lead-acid batteries are produced in the private sector, and there is no input tax. Although the other 15% comes from waste production units, such as China Mobile and China Unicom, most enterprises believe that the scrapped lead-acid batteries belong to the sales of their fixed assets, and they only issue ordinary VAT invoices, which cannot be deducted, resulting in the suffering of the whole renewable lead enterprises. At present, the tax payment level of domestic general industrial enterprises is between%, while the standard renewable lead enterprises are as high as 11.9% (this is the tax payment level after the immediate levy and refund of 30%), that is, for each ton of recycled lead recovered and disposed, a tax of about 2000 yuan is required. The direct result of the high tax payment level is that the standardized renewable lead enterprises are at a disadvantage in the market competition, and the phenomenon of "bad money expelling good money" is prominent

what's more, in order to gain competitive advantage, he came up with a "unique trick". He "made full use of the invoice that should have been given to the dealer or the individual who bought the new battery when selling the new battery", and deducted the invoice of the new battery as the input of selling the old battery. It seems reasonable. In fact, it is a change of concept, a violation of the tax law, and a tax evasion. According to the current 17% tax payment for each ton of lead recovered from waste lead-acid batteries by renewable lead enterprises, the annual average lead price of 2.2 million tons of renewable lead is 16500, and the state will lose about 5.3 billion yuan of tax each year

in view of this, it is suggested that the state should set up tax points for the renewable resources industry from the top-level design, levy taxes in the recycling process, and cover the recycling process within the scope of system management. While strengthening supervision, there are laws to follow to fully connect all links in the industrial chain of circular economy. First, adopt a fixed low tax rate support policy for waste lead-acid battery recycling enterprises, and pay value-added tax at 3%; The second is to implement the support policy of immediate collection and refund for waste lead-acid battery disposal enterprises, namely renewable lead production enterprises. It is allowed to make input deduction according to the recovered enterprise sales invoice (i.e. 3% input tax). After deduction, the tax support policy of 80% immediate levy and refund shall be implemented according to the actually paid value-added tax

pulling through the value-added tax chain of waste lead-acid battery recycling has the following three advantages:

advantage 1: it not only improves the tax burden of waste lead-acid battery recycling enterprises, stabilizes the tax source, but also realizes the unification of tax rates in the national waste lead-acid battery recycling industry, with fair tax burden, avoiding false opening, facilitating supervision, giving consideration to enterprises, and conducive to development

advantage 2: it reduces the excessive tax pressure of regulating renewable lead production enterprises, and makes a strong contribution to the national emission reduction of heavy metal pollutants and the improvement of comprehensive utilization of resources

advantage 3: establish a complete tax chain system of value-added tax, which reflects the state's intention to encourage recycling of renewable resources, promote energy conservation and emission reduction, give consideration to fairness, stabilize tax sources, and is conducive to the benign development of renewable resources industry. That is, after the low tax rate is pulled through, it not only solves the problem of lead renewable resources, but also solves the problems of all domestic renewable resources industries, which is of great and far-reaching significance

from the perspective of practitioners, I believe that the state can completely control the recycling of waste lead-acid batteries. If the state can issue and implement the measures for the administration of hazardous waste business licenses (Revised Draft) as soon as possible, legislate and supervise the recycling of waste lead-acid batteries from the perspective of policy, and adopt the 3% low tax rate support policy, it is reasonable from the perspective of taxation