3.3 Comparative studies

1. The legal basis of PAP of China’s policy includes laws, ordinances and measures at both national and local level.

National level	The Revised Law of the People's Republic of China on the Prevention and Control of Environmental Pollution Caused by Solid Waste (2005) The Measures on Administration of Import of Solid Waste (2012) The Measures on Implementation of Registration of Foreign Suppliers (2009)
Provincial level	The Revised Law of Guangdong Province of the People's Republic of China on the Prevention and Control of Environmental Pollution Caused by Solid Waste (2005) The Measures on Administration of Import of Solid Waste of Guangdong Province (2012) The Measures on Implementation of Registration of Foreign Suppliers of Guangdong Province (2009)
Municipal level	The Measures on Administration of Import of Solid Waste of Taizhou City (2012) The Measures on Implementation of Registration of Foreign Suppliers of Taizhou City (2009)

The legal basis of PAP of Germany’s policy includes European law, German federal law, the regional laws of the federal states and the statutes of the local authority waste management services. It is also based on the precautionary principle, the polluter-pays principle and the principle of co-operation. The main pillar is the Closed Substance Cycle and Waste Management Act. This act will be further developed by the end of 2010 on the basis of the new EU Waste Framework Directive in order to strengthen waste prevention and recovery.

2. PAP of China’s policy is a framework program with diverse implementation. Such regimes enable the development of very different implementation approaches at local levels; it is also a centralized PAP, as the essential part of the PAP will be assigned at national level. In a word, the PAP of this policy corresponds to a mixed PAP, which combines concrete objectives, evaluative element, operational elements, and a concrete definition of the organization and procedure.

In contrast, PAP of Germany’s policy is a detailed program with homogeneous implementation. The PAP of this policy tends to be corresponded to the substantive model, as it clearly articulates the objective, operational element, as well as procedure, but leave local level to decide the competent authority.

4. PAAs

   1. China’s paAs

China’s PAA of licensing the enterprise using solid waste

The paa of licensing the domestic consignees

The enterprise using imported solid waste shall submit a written application attached by the environmental assessment report and related documents to the local environmental protection department.

The local environmental department shall examine the application documents concerning the completeness and contents. After the examination, the local environmental protection department sends their decision and all the documents to the provincial level of environmental department, who shall then examine the decision and documents and send their decision and the documents to the Waste Import Registration Management Center.

In the Waste Import Registration Management Center, all the decisions and documents will be carefully examined according to related laws, regulations and ordinances. After the examination, the center shall put their decision on the official website of the ministry of environmental protection. After three days of public notification, the center shall then send their decision and public opinion to the ministry of environmental protection, where the final decision will be made.

The ministry of environmental protection shall issue the permit to the Waste Import Registration Management Center, who shall then mail the permit and charge bill to the enterprise directly or to the provincial level of environmental protection department, who will then send the permit and charge bill to the enterprise.

From above analysis, China’s PAA of licensing the domestic consignees is PAA of multiple actors. The main responsibility, including the horizontal and vertical cooperation falls on the shoulder of Inspection and Quarantine Bureau at provincial level. Therefore, it is a centralized PAA.