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Global Environment Facility "Improving Environmental Performance in the Foam Industry: ChinaHexabromocyclododecane (HBCD) Phase-out and Management Project

Final Overall Report

Guangzhou Fuda Insulation and Thermal Insulation Materials Co., Ltd.

May 2025

Contents

1Project Background1

2Company Profile2

2.1Headquarters and Production Base2

2.2Production Process4

2.3Project Team Composition6

3Project Design6

3.1Understanding of the Project6

3.2Technical Approach7

4Project Content and Implementation Status9

4.1Project Activity Implementation Status9

4.2Environmental and Social Management Implementation Status11

4.2.1Environment11

4.2.2Occupational Health12

4.2.3Occupational Safety12

4.2.4Social13

4.2.5Capacity Building13

4.3Industry Event Participation and Seminars17

4.3.1Invited to Attend the Press Conference on the Ban of HBCD in Building Energy Efficiency and Green Building17

4.3.2Attended the Press Conference on Compliance Work for Hexabromocyclododecane (HBCD) in the Plastics Industry and the HBCD Phase-out Technology Exchange………………………………………………………………………………………………………17

4.3.3Strategic Cooperation Signing Ceremony with Caizhu Platform -- Launch Ceremony of New Environmentally Friendly Flame Retardant Masterbatch18

4.3.4Invited to Participate in the Global Environment Facility-“Improving Environmental Performance in the Foam Industry: Phase-out and Management of Hexabromocyclododecane in China” Project2022Annual Summary Meeting20

4.4Women Leadership22

4.5Third-Party Supervision22

4.6Financial Execution24

5Project Acceptance26

Appendix 1Acceptance Opinions27

Appendix 2Ban on HBCD in Building Energy Conservation and Green Building FieldsHBCDPress Conference29

Appendix 3Plastic Industry Hexabromocyclododecane (HBCD) Compliance Work Press Conference andHBCDElimination Technology Exchange33

Appendix 4Audit Report40

Project Background

In May 2013, the Sixth Meeting of the Conference of the Parties (COP6) to the Stockholm Convention on Persistent Organic Pollutants (hereinafter referred to as the "Convention") reviewed and adopted an amendment to add hexabromocyclododecane (HBCD) to Annex A of the Convention, requiring Parties to gradually cease the production and use of HBCD within the exemption period. At the same time, the amendment provides a specific exemption for the use of HBCD in the manufacture of flame-retardant expanded polystyrene (EPS) and extruded polystyrene (XPS) insulation foam building boards. Parties are required to label EPS and XPS products that use HBCD under the exemption, and to identify and manage the waste and contaminated sites of HBCD in an environmentally sound manner. On December 26, 2016, the former Ministry of Environmental Protection, together with relevant ministries, issued the "Announcement on the Entry into Force of the Amendment Adding Hexabromocyclododecane".The announcement specifies that, starting from December 26, 2016, China prohibits the production, use, and import/export of HBCD except for specific exempted uses, and will terminate the specific exemption registration for EPS and XPS products on December 25, 2021 (five years after the amendment takes effect in China).

To protect the ecological environment and public health and to achieve China's convention compliance goals, the Ministry of Ecology and Environment's Foreign Cooperation and Exchange Center (FECO) and the United Nations Industrial Development Organization (UNIDO) jointly developed the "Global Environment Facility - Improving Environmental Performance in the Foam Industry: China HBCD Phase-out and Management Project." The project period is from 2021 to 2026, and its goal is to help China fulfill its obligations under the convention related to HBCD, achieving the substitution and phase-out of the specific exempted uses of this substance.

As a typical HBCD-using enterprise in China, Guangzhou Fuda Insulation Materials Co., Ltd. mainly produced HBCD-containing XPS boards before the phase-out of HBCD. In 2021, the Ministry of Ecology and Environment's Center for International Cooperation and Exchanges, together with the United Nations Industrial Development Organization, supported the project through a grant from the Global Environment Facility. Under the premise of complying with relevant management systems and technical standards, the project carried out HBCD phase-out and substitution demonstration work in large enterprises in the flame-retardant EPS and XPS building board industry, promoted environmentally sound management and disposal of HBCD-containing construction waste, sought suitable HBCD substitute products and conducted testing, shared technical knowledge on HBCD phase-out and substitution management, and facilitated the industry's smooth realization of HBCD phase-out and substitution.

2

Company Profile

Headquarters and Production Base

Guangzhou Fuda Insulation Materials Co., Ltd. (hereinafter referred to as "Fuda Company") is a professional company engaged in the research, development, production, and sales of new energy-saving insulation products, extruded insulation boards, and new composite boards. It was established in October 2006. Since its establishment in 2006, Fuda Company has been committed to the research and production of high-quality environmentally friendly insulation materials, providing customers with efficient and energy-saving system solutions. Whether in building insulation, cold storage cold chain, or municipal engineering, Fuda Company has won wide recognition with its excellent products and services.

At the beginning of 2017, Fuda Company successfully partnered with Oriental Yuhong, becoming a holding enterprise of Oriental Yuhong. Fuda Company is now the largest XPS board manufacturer in China and the only building environmental protection board manufacturer with a nationwide layout of XPS production bases. It has established a service network covering the whole country, with the vision of becoming the "most valuable enterprise in the global XPS industry," serving a better life. After years of product innovation and technological accumulation, Guangzhou Fuda has become the largest XPS board manufacturer in China and the only building environmental protection board manufacturer with a nationwide layout of XPS production bases.

Fuda has four XPS board production bases in China, all within the scope of this project: one base is operated by Guangzhou Fuda Insulation Materials Co., Ltd. (Guangzhou factory), and the other three are factories of Fuda’s 100% wholly-owned subsidiaries: Wuhu Fuda Insulation Materials Co., Ltd. (Wuhu factory), Deyang Fuda New Composite Materials Co., Ltd. (Deyang factory), and Tangshan Fuda Building Materials Co., Ltd. (Tangshan factory). These three subsidiary factories are managed uniformly by the headquarters in this project.

The predecessor of the Guangzhou factory was located at No. 100-101, Shibigang, Datang Village, Huadong Town, Huadu District, Guangzhou City100,101 (hereinafter referred to as "the Old Factory"). In 2021, Guangzhou Fuda built a new factory area on the east side of Hejin Avenue, Huadu District, Guangzhou City, Guangdong Province (hereinafter referred to as "the New Factory"), approximately 30 kilometers from the old factory area. Guangzhou Fuda began relocating all production lines from the old factory to the new factory in March 2022. The new factory covers an area of 63,839 square meters (m2).

WuhuFudawas established in2018,July, located in the SanshanEconomic DevelopmentZoneof Exi Road, No. 5, with a land area of 11,953 square meters, including a building area of 7,500 square meters. Wuhu Fuda leases part of the factory buildings of Wuhu Dongfang Yuhong Building Materials Co., Ltd. (hereinafter referred to as “Wuhu Yuhong”) for operations. In this demonstration project, Wuhu Fuda does not involve new land use or land acquisition.

DeyangFudais located atSection 3, Minshan Road, Deyang City, Sichuan Province, China56Sichuan OrientalYuhongBuilding Materials Co., Ltd. (hereinafter referred to as “SichuanYuhong”)park.Deyang Fuda leasesSichuan YuhongXPSworkshop for operations.

TangshanFuda is located inFengnan Economic Development Zone, Tangshan City, Hebei Province (formerlyFengnan Coastal Industrial Park”) in the Lingang Park, Rongsheng Street18, Tangshan Oriental Yuhong Waterproof Technology Co., Ltd. (hereinafter referred to as “Tangshan Yuhong”) park. Tangshan Fuda rents three workshops from Tangshan Yuhong:XPSworkshop,EPSworkshop, and the fifth workshop and its warehouse. The main area related to this demonstration project is theXPSworkshop and its warehouse. This demonstration project does not involve additional land area.

FudaXPS board production capacity reaches1.3 million cubic meters/year. The company'sXPS board production capacity summary table is shown below. The Wuhu factory has300,000 cubic meters/year; the Deyang factory has300,000 cubic meters/year; the Tangshan factory has350,000 cubic meters/year; the Guangzhou factory has100,000 cubic meters/year,after October 2021, an additional250,000 cubic meters/year was added.

Table 1 Fuda CompanyXPS Board Factory Capacity Summary Table

Factory

Annual capacity (10,000 cubic meters/year)

Wuhu

30

Deyang

30

Tangshan

35

Guangzhou (Old)

10

Guangzhou (New)

25

Summary

130

Note: The data in this table is sourced from the factory's environmental assessment report.

2

Production Process

This demonstration project mainly involves the elimination and replacement of raw materials forXPS board production, with no change to the production process. The production processes of the four factories are largely similar; the following is an overview of the production process using the Guangzhou factory as an example:

Feeding and Mixing:

Each of the three production lines in this project is equipped with a feeding system. Canned materials (polystyrene beads) are fed into the feeder by negative pressure air through pipelines. Bagged materials (flame retardants, color masterbatch, talcum powder) are manually transported to the workshop feeding storage bins, and the materials in the storage bins are pumped to the feeding system by a negative pressure air vacuum pump. Various materials are sent to the weighing device according to the set ratio. After weighing, the measured materials enter the main extruder. All equipment is closely connected.

Extrusion Molding:

The barrel is heated by a heating jacket (electric heating) outside the extruder barrel. The main extruder is heated to 200°C, and the secondary extruder is heated to 180°C. When the temperature rises to the set value, the material enters the main extruder and is heated inside the barrel until it gradually melts. Blowing agents (carbon dioxide and ethanol) are injected to ensure the blowing agents and materials are fully and evenly mixed.

There is a screen changer at the lower end of the main extruder to replace the screen. The two parts of the filter screen are closed and connected separately to the main extruder and the secondary extruder. After the main extruder heats the material to a molten state and filters it through the screen, the material is extruded and sent to the secondary extruder. The screen changer needs to be opened twice a day to replace the filter screen, which takes 20 to 30 seconds, and volatile organic compounds (VOCs) are generated during this process.

The melt containing the blowing agent is cooled and sent to the secondary extruder mold. The melt is immediately subjected to extrusion and expansion. Alcohol is used as the solvent and carbon dioxide as the blowing agent to uniformly fill the polystyrene plastic. Most of the alcohol and carbon dioxide remain in the closed-cell structure of the product, enabling physical expansion of the polystyrene foam material. After the melt containing the blowing agent is formed, it is molded into the product through various molds of different specifications. This process generates volatile organic compounds (including benzene series, ethanol, etc.).

Cooling:

The semi-finished product is flattened by a calibration shim, cooled, and then fed into the next process by the traction force of the traction machine and the guide roller frame.

Milling:

The two ends of the semi-finished product are reduced by a rough milling cutter, and the upper and lower sides are peeled by a peeling machine.

Inkjet Printing:

The printed finished product from the inkjet printer is installed on the extrusion board production line. The contractor's trademark information.

Packaging:

Pack qualified printed products through the packaging machine and place them in the finished goods warehouse.

Recycling: Recycled waste or defective products are used as raw materials.

The following is the recycling process:

Crushing: Put waste and defective products into the crusher for crushing.

Granulation: The barrel is heated by a heating cover (electric heating) outside the barrel of the recycling granulator. After electric heating control, the temperature of the heated recycling granulator is about200°C. The material is transported by airflow into a closed pipeline conveying system to the granulator material tank. After electric heating, the temperature of the hot melt process is controlled at180°C. The material in the tank naturally falls into the bucket, melts after heating, and the plastic becomes molten. Volatile organic compounds are generated during this process.

Extrusion Molding:After the molten material is shaped into strips, it enters the extrusion process through the granulator's extrusion port. This process generates volatile organic compounds.

Cooling: The strip-shaped semi-finished products are cooled with cooling water. The cooling water is recycled with no discharge. Tap water is regularly added to replenish evaporated water.

Cutting into Pellets:The strip-shaped semi-finished product enters the pelletizer and is cut into cylindrical pellets. The diameter of the cylindrical pellets ranges from1.5 millimeters to2 millimeters, and they are conveyed through closed pipelines to the material recovery tank in the extruded polystyrene workshop for production storage and reuse.

Project Team Composition

For thisHBCD phase-out demonstration project, our company attaches great importance and implements a general manager responsibility system in management, with the deputy general manager and production operations director assisting the general manager. The flame retardant division manager provides technical support for theHBCD phase-out. The general manager, deputy general manager, production operations director, marketing manager, flame retardant division manager,XPS production cost director, and the four factory directors of productionXPS jointly form the company'sHBCD phase-out leadership team, responsible for the overall work of the company'sHBCD phase-out and for formulating the company'sHBCD phase-out system.

Coordination withFECO or local project offices is mainly handled jointly by the company's marketing department and production operations director. The marketing department is responsible for non-technical coordination and communication of the project and the company'sHBCD phase-out publicity. The production operations director attends meetings organized byFECO or local project offices, is responsible for drafting environmental, social, and security plans, evaluating product process quality, reporting project progress, submitting relevant reports, and cooperating with other tasks required byFECO.

In the four factories, the factory manager is the primary person responsible for the HBCD elimination work in the factory, and the factory strictly implements the HBCD elimination system. The XPS team leader and production supervisor are responsible for XPS production and HBCD elimination process upgrades; quality inspectors are responsible for HBCD testing and quality inspection of XPS boards, cooperating with third-party testing laboratories; packaging operators are responsible for XPS board labeling; warehouse staff are responsible for XPS board inventory management and waste management; safety and environmental personnel are responsible for site environmental risk management, including HBCD construction waste environmental harmless management and disposal. The factory implements the HBCD elimination plan process and promptly provides feedback to the HBCD elimination leadership team.

Project Design

Understanding of the Project

Fuda Company, as the largestXPS board material manufacturer in China, has the responsibility to set an example in theHBCD phase-out and substitution within this industry, providing experience and reference for peers, actively sharing the company's technology and knowledge in theHBCD phase-out and substitution management process, promoting the smooth realization ofXPS board material industry'sHBCD phase-out and substitution, advancing the environmentally sound management and disposal ofHBCD-containing construction waste, and providing data and information for this project to facilitate theXPS board material industry'sHBCD phase-out.

In the process of the company proactively stopping the use ofHBCD inXPS board materials and applyingHBCD substitutes in the production ofXPS board materials, it will actively cooperate with this project, contributing the Fuda solution that benefits industry development and environmental harmony to theXPS board material industry'sHBCD phase-out..

Technical Route

Stop purchasing HBCD flame retardants on May 1, 2021; completely use up the inventory of HBCD-containing flame retardant masterbatch by July 1, 2021; start producing BLUEDGE™ (brominated SBS) flame retardant masterbatch from September 2021; completely phase out and stop selling XPS boards containing HBCD by December 1, 2021.

BrominatedSBS polymer-type flame retardant technology was developed specifically to replaceHBCD. As a safer innovative flame retardant, brominated SBS not only provides equivalent fire safety performance for XPS and EPS foam insulation materials but also has excellent EHS characteristics. The chemical name of brominated SBS polymer-type flame retardant is brominated styrene - butadiene copolymer, a high molecular weight copolymer of polystyrene and brominated polybutadiene.

(MW > 60,000 g/mole, bromine content 64-66%). This product contains no low molecular weight components and no reactive groups. Its flame retardant properties meet EU flame retardant standards: excellent thermal stability, flame retardant performance similar to HBCD. Brominated SBS is not bioaccumulative in animals or humans. The brominated SBS polymer-type flame retardant used in polystyrene insulation materials has excellent stability under normal conditions and does not decompose or degrade in the foam.

Brominated SBS can improve the flame retardancy of polystyrene foam and slow down the burning rate. In addition, it can meet the thermal stability requirements of XPS. Non-brominated SBS supports existing production processes, not only providing the expected performance but also maintaining the physical properties of the foam. Foam containing brominated SBS complies with (and in some cases exceeds) current fire safety and usage requirements, while having lower environmental and human toxicity, meeting all global regulatory guidelines (such as those in the EU, Japan, North America, China, and South Korea).

2

Project content and implementation status

Project activity implementation status

On December 6, 2021, the Ministry of Ecology and Environment Foreign Exchange Center signed the "Transfer Contract" with Guangzhou Fuda, officially launching the project. Due to the significant impact of the pandemic on Fuda's production activities and restrictions on personnel movement, the team underwent major adjustments. The project could not be carried out and completed according to the original contract schedule. After consultation between Guangzhou Fuda and FECO, a supplementary agreement was signed in October 2024 to appropriately extend the project. The agreement period was extended to December 31, 2024, with the main outputs and contract amount remaining unchanged.

The main activities and outputs of this demonstration project are:

Implementation of HBCD usage cessation work: Our company stopped purchasing HBCD on May 1, 2021, and completely phased out HBCD by December 2021, no longer selling XPS boards containing HBCD.

Strict implementation of the Environmental and Social Management Framework (ESMF): Entrusted a qualified third party to prepare the environmental and social management plan for this project in accordance with UNIDO environmental and social management standards and relevant domestic environmental and social laws and regulations, conduct regular environmental and social management monitoring, submit environmental and social safeguard reports, and complete an environmental and social management closing report at the end of the project.

Process Testing and Product Performance Testing:From July to November 2021, during the complete replacement of HBCD flame retardant with brominated SBS, all factories cleaned the original equipment and conducted lab-scale, pilot-scale, and production line trials using the environmentally friendly brominated SBS to produce XPS boards. During the trial production, the main focus was on tracking the flame retardant attenuation of the boards, testing board performance, and HBCD content, etc. The trial-produced board products were sent to qualified third-party testing agencies for HBCD content and board performance testing, with the conclusion being “HBCD free,” and the product performance met relevant industry standards. Additionally, the “Trial Production Report and Product Quality Report for Producing XPS Using HBCD Substitutes” and the “XPS Board Process Adjustment Test Report” were compiled.

Harmless Treatment of Materials ContainingHBCD: Harmless disposal of flame retardant raw materials containingHBCD, XPS boards and their scraps containingHBCD, and residualHBCD materials in the production line, with a report prepared. During this harmless treatment process, there were no pollutant non-compliant emissions, noHBCD leaked into the external environment, and no impact on the external environment.

Adding Different Flame Retardant Labels: Guangzhou Fuda, Wuhu Fuda, Tangshan Fuda, and Deyang Fuda factories fulfilled the demonstration work of labeling alternative flame retardants for XPS board products containingHBCD during the project, and prepared a report. This labeling activity covered the four factories labeling products made with alternative flame retardants as “ECO series environmentally friendly polystyrene boards” and labeling products tested to be free ofHBCD with “HBCD-free” labels.

Assisting Subproject Monitoring and Effectiveness Evaluation: Through testing and evaluation, assessments were conducted on brominated SBS environmentally friendly flame retardant production XPS boards, waste management, and site environmental risks. Proactively cooperating withFECO, local project offices, Guangdong Solid Waste and Chemicals Environmental Center, and Zhongke Testing.

The schedule for this demonstration project is as follows:

Table 1: Key Project Milestones

Time

Item

May 2021

Stop purchasing raw materials containing HBCD

July—November 2021

Apply for this demonstration project and conduct process tests for HBCD alternative raw materials (brominated SBS)

November 2021

HBCDRaw material consumption completed

December 2021

Signed the "Transfer Contract" for this demonstration project with the Center for External Cooperation and Exchange of the Ministry of Ecology and Environment, completed cleaning and updating of production units and equipment, and sold the last batch of boards containing HBCD

January 2022

Demonstration project enters normal production and operation phase

2022 year4 month—May

Conduct environmental and social review according to the Environmental and Social Management Framework (ESMF),prepare theEnvironmental and Social Management Plan

May 2024

Preparation and Submission of Environmental and Social Security Report

July 2024

Preparation of the "Assessment Report on Harmless Management of Waste XPS Boards Containing HBCD", "XPS Board Process Adjustment Test Report", and "Report on the Identification of Different Flame Retardants Added".

July 2024

Writing the Environmental and Social Management Completion Report

April 2025

Writing and submitting the overall completion report for this demonstration project

April 16, 2025

On-site Acceptance of the Project

Implementation of Environmental and Social Management

The Environmental and Social Management Plan (ESMP) to be implemented during this project was completed in May 2022 and approved by the Center for International Cooperation and Exchanges of the Ministry of Ecology and Environment.ESMP requires the enterprise to comply with relevant domestic laws and regulations, environmental and social safeguard policies, and the environmental and social management framework of this demonstration project, as well as to carry out capacity building during project implementation.In May 2023, Meihua Environmental Engineering (Shanghai) Co., Ltd. (Meihua) conducted the first monitoring of the projectESMP, periodically reviewed the implementation of the projectESMP and the corrective actions proposed in theESMP, and prepared and submitted the environmental and social safeguard report. In January 2024, Meihua audited the implementation and corrective actions of the project and completed the Environmental and Social Management Completion Report in May 2024, concluding that the project was basically managed in accordance with the projectESMP during the implementation of this demonstration project, with capacity building well carried out.

Environment

Fuda's four production bases generate environmental impacts during the production and operation phase of the demonstration project, mainly including wastewater, noise, exhaust gas, and solid waste. The wastewater generated during the operation period of this demonstration project mainly includes domestic sewage and circulating cooling water. Domestic sewage comes from daily office life.This demonstration project's exhaust gas mainly includes dust generated from crushing operations during the grinding and recycling processes, and volatile organic compounds (VOCs) produced during extrusion and granulation processes. Noise mainly comes from extruders, milling cutters, and crushers, with noise levels around 70~85 dB (A). Solid waste generated during the operation phase mainly includes general waste such as defective products, waste packaging bags, and domestic garbage; as well as hazardous waste such as waste activated carbon, waste lubricating oil, and waste conductive oil. During the implementation of the demonstration project, Fuda's various factories entrust qualified third-party testing agencies to conduct regular monitoring of pollutants generated in the park as required, and dispose of related waste accordingly.

During the operation of the project, the main environmental risks are the discharge of untreated exhaust gas and wastewater, as well as chemical leaks caused by improper handling during operation and transportation or equipment rupture. Fuda has developed an environmental accident emergency plan, which includes a series of anti-leakage measures. Throughout the entire project period, Fuda has not experienced any sudden environmental incidents.

According to the third-party monitoring and the environmental and social management completion report, Fuda's environmental management during the execution of this demonstration project complies with relevant laws, regulations, and the management requirements of this demonstration project.

Occupational Health

The new material bromide SBS is a harmless chemical with no special health hazards to humans. Therefore, during the operation of this demonstration project, Fuda's main occupational hazard factors are consistent with those of the original production line, mainly including: XPS dust, talcum powder, chemical factors (carbon dioxide, toluene, ethylbenzene, styrene, xylene, cyclohexanone, acetone, ethyl acetate, butyl acetate), raw material and finished product warehouses, noise and high temperature in the XPS workshop. To prevent these hazards, Fuda has installed protective equipment such as dust hoods, ventilation ducts, centrifugal fans, bag dust collectors, exhaust systems, centrifugal fans, and activated carbon adsorption devices. Fuda has established an occupational disease hazard prevention plan and implementation scheme, occupational health management system and operating procedures, and has set up an occupational health management organization and full-time personnel management. During the demonstration project, Fuda formulated an annual occupational disease prevention plan, provides occupational health examinations for employees every year, and regularly monitors occupational hazard factors within the plant area. At the same time, personal protective equipment (PPE) is regularly provided monthly to employees in different positions, mainly including gloves, dust masks, filter cotton, filter boxes, soap, work clothes, earplugs, etc.

According to the third-party monitoring and environmental and socialmanagement completion report,Fuda completed occupational health rectification items duringthe project implementation period, and occupational health complies with relevant laws, regulations, and the management requirements of this demonstration project.

Occupational Safety

Fuda'sfourproduction baseswere managedunder the original safety risk control system during the operation of this demonstration project.Fuda'sXPSfactoryworkplace safety hazards mainly include explosion, fire, poisoning and suffocation, burns, electric shock, mechanical injuries, falls from height, object strikes, vehicle injuries, lifting injuries, noise, high temperature, and dust hazards.During the project implementation,Fudaat eachbase organizedvarioussafety trainings for employees, covering topics such asXPSworkshop fire safety, production safety, forklift management, and special equipment operation safety.The factoryconducts annual emergency drills for production safety accidents, with drill records showing that all employees are required to participate.Dedicated personnel conduct daily inspections and regular maintenance of production line equipment and special equipment, and keep inspection records.At the same time,Fuda ensuresthat operators of special equipment holdvalid and qualifiedoperation certificates.

According to the third-party monitoring and environmental and socialmanagement completion report,Fuda completed occupational safety-related rectification items duringthe implementation of this demonstration project, and occupational safety complies with relevant laws, regulations, and the management requirements of this demonstration project.

Society

Project Land

Fuda’s fourproduction basesdo not involve any new landin this demonstration project, and no land-related issues were found during the project implementation.

Labor and Working Conditions

During the execution of the demonstration project,Fuda’s fourproduction basesdid not experience significant changes in the number of employees,and all employeesaredirectworkers. All workershavesigned labor contracts with the respective factories, and the contracts show that the workers’ basic wages follow the company’s wage system.During the project period, noexternal personnel were hired, so no additional environmental risks were imposed on the surroundingcommunities. Thisproject did not receive any internal or external social dissatisfaction.

Ethnic Minorities

Among the employees at Fuda’s fourproduction bases, there is a small number of ethnic minority employees. The living habits and ideological concepts of ethnic minority employees and Han employees show no significant differences, and the company does not discriminate against ethnic minorities. During the execution of this demonstration project, no complaints related to ethnic minorities occurred, and the company treats ethnic minorities the same as Han employees.

Complaint Mechanism

Fuda’s fourproduction baseshave established internal and community complaint mechanisms, and no internal or external complaints were received during the project implementation.

Capacity Building

During the project implementation process,Fuda's four production bases conducted various training sessions for project related management and operational personnel, including topics on environment, health, safety, as well as the HBCD elimination project theme. The four production bases trained more than 120 people, among whom female employees accounted for over 30%.

Table 2 Guangzhou Fuda Training Situation

Serial Number

Training Topic

Training Date

Training Time

Training Audience

Training Method

1

Safety Production and Environmental Safety

2022.1.27

15h

Workshop Personnel

Internal

2

Forklift Management and Special Equipment Safety

2022.5.14

1h

Special Operations Personnel

Internal

3

Firefighting and Safety Production

2022.5.27

2h

Personnel from all departments

Internal

4

Firefighting and Safety Production

2022.10.10

2.5h

Personnel from all departments

Internal

5

HBCDPhase-out Project Environmental and Social Safeguard Policy

2022.10.28

/

Key Personnel of the Demonstration Project

External

Table3 WuhuFuda TrainingSituation

Serial Number

Training Topic

Date

Target Audience

Internal/External

1

Confined Space Asphyxiation Accident Drill and Rescue

2022.4.8

XPS Workshop

Internal

2

Job Safety Training

2022.5.8

XPS Workshop

Internal

3

Hazard Identification

2022.7.6

XPS Workshop

Internal

4

Safety Emergency Incident Handling

2022.7.17

XPSWorkshop

Internal

5

Equipment Injury Accident Rescue Drill

2022.11.11

XPSWorkshop

Internal

6

Hexabromocyclododecane (HBCD) Hazards and How to Identify Environmentally Friendly Flame Retardant Products on Company Packaging

2023.3.14

All Employees

Internal

7

Fire Drill

2023.4.27

XPSWorkshop

Internal

8

Hazard Factors and Protective Equipment for Each Position

2023.6.12

XPSWorkshop

Internal

9

Heatstroke Prevention and Cooling Safety Training

2023.7.3

XPSWorkshop

Internal

10

Hazardous Waste Leakage Accident Drill

2023.9.25

XPSWorkshop

Internal

Table4 DeyangFuda TrainingSituation

Serial Number

Training Topic

Date

Internal/External

Number of Participants

1

Confined Space Education and Training

2022.6.11

Internal

10

2

Safety Production Study

2022.9.14

Internal

11

3

HBCD Importance and Vision of Phase-out

2023.3.5

Internal

16

4

Fire Safety, Production Safety Training, and Emergency Drills

2023.4.25

Internal

16

5

Confined Space, Emergency Rescue Training and Drills

2023.4.25

Internal

16

6

Environmental Safety Training

2023.5.12

Internal

16

7

Occupational Health Training

2023.7.13

Internal

16

Table 5 Tangshan Fuda Training Situation

Serial Number

Training Topic

Date

Time

Target Audience

Internal/External

Number of Participants

1

Occupational Health Knowledge

2022.3

1hour

All Employees

Internal

38

2

Dual Control Safety Training

2022.4

2hours

Production Department

Internal

22

3

Fire Drill

2022.5

1hour

All Employees

Internal

38

4

Confined Space Training

2022.5

1hour

Production Department

Internal

22

5

Confined Space Emergency Drill

2022.5

2hours

Production Department

Internal

22

6

Occupational Health

2022.7

1hour

All Employees

Internal

38

7

Chemical SpillEmergency Drill

2022.8

1hour

All Employees

Internal

31

8

Occupational Disease Emergency Response

2022.9

1hour

All Employees

Internal

38

9

Occupational Disease Prevention

2022.11

1hour

All Employees

Internal

38

10

HBCDimportance and promotion of elimination

2023.2

1hour

All Employees

Internal

28

11

Environmental Safety Training

2023.5

1hour

All Employees

Internal

25

12

Occupational Health Training

2023.7

1 hour

Workshop Employees

Internal

19

2

Training and Drill Photos

2

Participation in Industry Events and Seminars

During the project, our company participated in seminars and training sessions organized by FECO and the local project office as required by the project, attended routine meetings organized by FECO or the local project office, and reported project progress as required. The main meetings or activities attended are as follows.

Invited to attend the press conference on the ban of HBCD in the field of building energy efficiency and green buildings

On the morning of March 1, 2021, in order to thoroughly implement national policies, ensure the healthy and stable development of the building insulation industry, and establish and improve the industry's long-term self-regulation mechanism, the China Building Energy Conservation Association and the China Real Estate Association jointly held a press conference in Beijing on the HBCD ban and the application of environmentally friendly flame retardant alternatives in the field of building energy conservation and green buildings. Fuda Company was invited to attend this press conference and deliver a speech (detailed news see Attachment 2).

Photos from the press conference site

Attended the plastics industry hexabromocyclododecane (HBCD) compliance work press conference and HBCD elimination technology exchange

On April 9, 2021, under the guidance of the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment and the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, and hosted by the China Plastics Processing Industry Association, with support from Shandong Xurui New Materials Co., Ltd. and Shandong Dongxin New Materials Technology Co., Ltd., the "Plastic Industry Hexabromocyclododecane (HBCD) Compliance Work Press Conference and HBCD Compliance Work Exchange Meeting" was successfully held at the Beijing Wuhuan Hotel.

Attending the press conference were leaders and experts from the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment, the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, the Science and Industrialization Development Center of the Ministry of Housing and Urban-Rural Development, the Tianjin Fire Research Institute of the Ministry of Emergency Management, the Ecological Environment Research Center of the Chinese Academy of Sciences, the Flame Retardant Materials Professional Committee of the China Petroleum and Chemical Federation, Beijing Technology and Business University, and other units; media including China Chemical Reporter, China Environment News, China Building Materials News, China Quality News, China Industry News, Consumer Daily, China Plastics magazine, Plastics magazine, Tencent Video, Sohu.com, People’s Daily Online, as well as HBCD manufacturers, EPS and XPS board manufacturers, EPS bead manufacturers, flame retardant masterbatch manufacturers, related testing units, university research institutes, and more than 100 representatives attended the meeting. (For detailed news, see Attachment 3)

Photos from the press conference site

Strategic Cooperation Signing Ceremony with Caizhu Platform – Launch Ceremony of New Environmentally Friendly Flame Retardant Masterbatch

In recent years, low carbon and energy saving have become the mainstream trends of social development. At the ninth meeting of the Central Financial and Economic Affairs Commission held this year, Xi Jinping proposedto incorporate carbon peakingand carbon neutrality into the overall layout of ecological civilization construction. China's building sector has also taken an important step towards low-carbon transformation: sinceDecember26,2021,China has fully stoppedthe production, use, andimport and export ofHBCD.Hexabromocyclododecane (also known asHBCD) is widely used as a flame retardant in polystyrene foam. Research has found that it poses many potential long-term hazards to humans and the environment, and it has been globally banned under the Stockholm Convention on Persistent Organic Pollutants by the United Nations.

Photos from the launch ceremony-1

The Caizhu platform and Fudacompany have alwaysadhered to theconcept of mutual benefit and mutual achievement in close cooperation. This year, onJune24,Fuda company and Caizhureached a strategic cooperation;onJune25, Fuda company's new environmentally friendly flame retardant masterbatch was launched for the first time on the Caizhu Mall, comprehensively promoting the use of brominatedXPSboards withSBSenvironmentally friendly flame retardant masterbatch to replaceHBCD, deeply cultivating upstream raw materials for environmentally friendly flame retardants, providing green and environmentally friendly flame retardant raw materials to the insulation building materials industry, fully building a stable and sustainable green value chain, bringing more environmentally friendly and high-quality products to China's real estate procurement, government procurement, and consumers, accelerating the elimination ofHBCDin the building energy-saving insulation industry, and becoming a new benchmark leading green materials in the building energy-saving insulation industry.

Photos from the launch ceremony-2

Since its establishment, Fuda companyhas focused on the research and development of environmentally friendly insulation materials, adoptingCO2foaming to replaceHCFCfoaming in a comprehensive technical transformation, and has received the Montreal Multilateral Fund Organization’s honorary certificate recognizing its protection of the ozone layer. It is the first company in China to provide dry-type floor heating panels free ofHBCD, and promotes to the whole society the use of green raw materials and foaming technology in environmentally friendly cold chain logistics insulation systems and other high-quality environmentally friendly products. It is also the first insulation industry material green building product in China certified by the National Construction Federation credit institution.Fuda companywill always adhere to the purpose of “creating a lasting and safe environment for humanity and society,” advancing the green building industry through product quality improvement, energy consumption reduction, and carbon emission reduction.

Invited to attend the Global Environment Facility - "Improving Environmental Performance in the Foam Industry: Elimination and Management of Hexabromocyclododecane (HBCD) in China" 2022 Annual Summary Meeting

October 28, 2022, the Ministry of Ecology and Environment's Center for International Cooperation and Exchanges organized the 2022 annual summary meeting of the Global Environment Facility (GEF)-Improving Environmental Performance in the Foam Sector: China's Hexabromocyclododecane (HBCD) Phase-out and Management” project (hereinafter referred to as the HBCD project) in Beijing through a combination of online and offline methods. Deputy Director Xiao Xuezhi of the center, Deputy Director Guan Yanming of the Shandong Provincial Department of Ecology and Environment, Mr. Smail Alhilali, Director of the Materials and Chemicals Division of the United Nations Industrial Development Organization (UNIDO), and Dr. Reinhard Zeitler, Director of the Bavarian State Ministry for the Environment and Consumer Protection, Germany, attended and spoke at the meeting.

Photo of the online meeting

Fuda Company, as a participatingXPSboard enterprise in the project, had its Deputy General Manager Xiong Shaobo report at the meeting on the progress of the "Global Environment Facility - Improving Environmental Performance in the Foam Industry: China Hexabromocyclododecane (-HBCD) Phase-out and Management Project XPS Board Enterprise Demonstration Project, specifically the Guangzhou Fuda Insulation Materials Co., Ltd. Demonstration Subproject". Since2018, Fuda Company has been exploring the use of environmentally friendly flame retardants to replaceHBCDin the production of extruded polystyrene (XPS) boards. InJune 2021, it confirmed a strategic cooperation with DuPont to produce green and environmentally friendly macromolecular flame retardants, brominatedSBSflame retardant masterbatch, used for producing eco-friendlyXPSboards. Starting fromJuly 2021, the use of hexabromocyclododecane (HBCD) as a flame retardant was discontinued. A dedicatedHBCDphase-out leadership team was established to effectively manage the procurement of flame retardant raw materials, incoming inspection, and outgoing inspection processes, ensuring control from the source to guarantee the elimination ofHBCD. Additionally, "Meihua Environmental Engineering (Shanghai) Co., Ltd." was hired as the project consultant to participate throughout the project implementation period in environmental and social monitoring and evaluation, issuing third-party monitoring and evaluation reports to further verify the achievements of theHBCDphase-out work.The factory has now completed a comprehensive transformation of the XPS board production line, achieving a fully green and environmentally friendly process from raw materials to product application. Fuda Company adheres to a low-carbon and energy-saving sustainable development path, taking environmental protection and greenness as its development direction, guided by the national green manufacturing strategic action plan, contributing to the dual carbon goals.

Female Leadership

It is worth mentioning that the work of this demonstration project is led by female leader Ms. Li Ya. She shared that during the participation in this demonstration project, they benefited greatly. They not only significantly improved their project management and communication skills but also systematically mastered professional knowledge in environmental management and social management within enterprises and production processes. More importantly, their self-respect awareness was strengthened, deeply recognizing the extraordinary value of female power, which injected firm confidence into their future career development and personal capability advancement. The smooth progress of this project serves as an important milestone, vividly demonstrating the key role women play and the outstanding achievements they have made in the foam industry, while also pressing the "accelerate button" for gender equality development in the XPS industry and the entire foam sector, strongly promoting the in-depth practice and implementation of gender mainstreaming in this field.

Third-Party Supervision

The Guangdong Solid Waste and Chemical Environmental Center, in collaboration with Zhongke Testing, conducted the following supervision and effectiveness evaluation of this demonstration enterprise during the project process: 1) the compliance, legality, and execution progress of enterprise activities; 2) evaluation of the costs of enterprise technological transformation; 3) effectiveness evaluation of demonstration activities; 4) experience summarization and promotion of demonstration results.

Third-party monitoring results show that this demonstration enterprise has achieved significant results in waste gas treatment and product quality control, with various pollutant indicators and HBCD content in products meeting relevant standard requirements.

Economic benefits: UsingHBCD substitutes to produceXPS is economically feasible,and in 2023, the company's sales reached137 million yuan, bringing considerable economic benefits to the company.

Social benefits: During the project implementation, no internal employee complaints occurred, and no additional environmental risks were posed to the surrounding community.

Environmental benefits: During the project implementation, all environmental pollution emission indicators met the standards, no environmental or occupational health and safety accidents occurred, and theelimination of HBCD was completed.

The sources ofHBCD substitute materials are extensive and stable: currently, multiple companies are producing brominatedSBS, which already meets the supply conditions for industrialized substitution. BrominatedSBS features high molecular weight, no frosting, high thermal stability, migration resistance, environmental friendliness, and good compatibility withXPS.

Third-party supervisory units believe that the successful implementation of the project provides valuable experience and data support for the elimination and management ofHBCD in Guangdong Province and nationwide. It helps promote related enterprises to better fulfill their international convention obligations, reduce the potential risks ofHBCD to the environment and human health, and promote sustainable development.

Third-party testing on-site sampling

2

Financial execution status

At the end of the project execution,Guangdong Solid Waste and Chemicals Environmental CentercommissionedGuangdong Yuexin Certified Public Accountantsto conduct a special fundauditof this projectand issue averificationreport.Guangzhou Fuda's totalexpenditureof the grantamounted to1,918,700yuan.The expenditure items were: environmental technology service feesof 465,000yuan; testing and inspection equipmentof 1,453,730yuan, mainly including: energy dispersiveXray fluorescence spectrometer, building material monomer combustion test device, thermogravimetric analyzer, etc., totaling18units. Detailed expenditure can be found in the "Guangzhou Fuda Insulation Materials Co., Ltd. HBCD Project Grant Fund Usage Verification Report" (Yuexin[2024]Special No.24684) in the "HBCD Project Grant Fund Usage Expenditure Details Table" and the "HBCD Project Grant Fund Equipment Purchase Details Table".(Audit report see Attachment 4)

According to the requirements of the transfer contract, our party needs to provide project matching funds not less than 160 million yuan, of which the cash matching funds shall not be less than 40 million yuan. As of the end of January 2024, Guangzhou Fuda has invested a total of 175.2721 million yuan in project matching funds, mainly invested as follows:

Project Name

Investment amount (ten thousand yuan)

Production Line Equipment and Construction

1,658.85

Alternative Production Line Workshop Construction

2,259.80

Raw materials for trial production of substitute products (including working capital)

10,312.14

Technology Introduction Fee

97.65

Related Engineering Construction Costs

3,198.77

Total Supporting Investment

17,527.21

(The expenditure on raw materials for trial production of substitute products includes the originally budgeted working capital of 40 million yuan. Details can be found in the "Inspection Report on the Use of Grant Funds for the HBCD Project of Guangzhou Fuda Thermal Insulation Materials Co., Ltd." (Yuexin [2024] Special No. 24684) in the "Detailed Statement of HBCD Project Matching Fund Expenditures.")

The verification opinion indicates that our side's use of the grant and the activity budget in the implementation plan of this demonstration project are basically consistent, the use of the requested grant funds for activities is reasonable, and complies with the provisions of the project contract. The project execution complies with the requirements of the project contract and other relevant regulations, does not containHBCD, and the production and sales of substitutes are performing well, achieving good economic and social benefits.

2

Project Acceptance

On April 16, 2025, the Center for International Cooperation and Exchange of the Ministry of Ecology and Environment held an on-site project completion acceptance meeting for this demonstration project inGuangzhou, Guangdong Province. The project completion was evaluated. The expert group reviewed relevant documents, listened to the project report, conducted on-site inspections,and through questioning and discussion,the expert group agreed that the project consortium passed the acceptance (acceptance opinion see Attachment One).

The following opinions were formed:

1. The project undertaking unit completed all tasks required by the contract,the project funds revenue and expenditure comply with relevant financial management regulations,and it is agreed that the project passes the completion acceptance;

2. It is recommended to improve the comparative analysis between the project budget and actual expenditure, and further improve the report text.

Regarding the final report, our company has made supplements and revisions according to the opinions of the acceptance expert group, and finally formedthis final report, which was officially submitted to the Center for International Cooperation and Exchange of the Ministry of Ecology and Environment inMay, 2025.

On-site photos

2

Attachment 1: Acceptance Opinions

List of Acceptance Expert Group Members

Name

Unit

Position/Title

Liu Jianguo

Peking University

TenuredAssociate Professor

Liu Wenbin

University of Chinese Academy of Sciences

Professor

Zhang Haijun

Dalian Institute of Chemical Physics, Chinese Academy of Sciences

Researcher

LiShen

Daxin Accounting Firm

Certified Public Accountant

WangMujie

Center for International Cooperation and Exchanges, Ministry of Ecology and Environment

Senior Project Manager

Attachment IIPress Conference on the Ban of HBCD in the Field of Building Energy Efficiency and Green Buildings

On March 1, 2021, in the morning, to thoroughly implement national policies, ensure the healthy and stable development of the building insulation industry, and establish and improve a long-term self-regulation mechanism for the industry, the China Building Energy Conservation Association, together with the China Real Estate Association, jointly held a press conference in Beijing on the ban of HBCD and the application of environmentally friendly flame retardant alternatives in the field of building energy efficiency and green buildings. Fuda Company was invited to participate in this conference and deliver a speech.

This press conference was guided by the Standard Quota Department of the Ministry of Housing and Urban-Rural Development, the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment, and the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment. Relevant government authorities and various enterprises were invited to participate, with reporters from more than a dozen authoritative media outlets such as Xinhua News Agency, Guangming Online, Phoenix Net, and Global Times attending.

Yu Lifeng, Deputy Director of the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, introduced the background related to China's ban on HBCD and put forward relevant suggestions. He proposed researching and formulating product standards limiting the HBCD content in building insulation materials, increasing the research, demonstration, and promotion of alternatives and substitute technologies, and issuing policy measures. He emphasized that all parties across the entire industry chain should raise their awareness, enhance their sense of urgency and mission, deeply understand the development situation of this industry, and, in accordance with the spirit of the Fifth Plenary Session of the 19th Central Committee, base themselves on the new development stage, implement the new development philosophy, build a new development pattern, and coordinate the economic development of the industry.

Ni Jiangbo, First-Level Inspector of the Standard Quota Department of the Ministry of Housing and Urban-Rural Development, explained from three aspects that after the comprehensive ban on HBCD, the entire organic insulation material industry will face new challenges and opportunities. He proposed that everyone should attach great importance to this, accelerate the technological progress of insulation and energy-saving products, speed up the research and development of systematic energy-saving technologies, actively embrace new historical development opportunities, and make greater contributions to achieving carbon peak and carbon neutrality in China's construction sector.

Fuda CompanyDeputy General Manager Xiong Shaobo representingEPS/XPSinsulation material manufacturing enterprises shared relevant experiences, explaining the production and application practices of HBCD alternative flame retardant insulation materials in the building insulation industry.HBCDAt the press conference, he mentioned thatFuda Companyhas focused on the research and development of environmentally friendly insulation materials since its establishment in2006, and in2020, Fuda Companysigned a technology agreement with DuPont,Fuda Companyobtained the qualification to produce flame retardant masterbatch technology from the American DuPont company in China, dedicated to serving the insulation industry'sHBCDelimination efforts.Fuda Companyinsists on innovating products from the industry's high ground and pain points, developing an environmentally friendly macromolecular flame retardant to replaceHBCD, which fully meets the flame retardant and physical performance requirements of insulation materials.

He called on insulation enterprises to continuously improve their independent innovation capabilities, increase investment in technology, strengthen scientific research collaboration, enhance self-discipline, and proactively ban the use ofHBCD, jointly assume industry responsibilities, and promote the progress of the entire industry through open, fair, and just market competition, never allowing products containingHBCDto enter the building insulation market.

During the meeting, the China Building Energy Conservation Association, together with the China Real Estate Association, initiated a call to all real estate development enterprises to immediately ban the use ofHBCD. The China Building Energy Conservation Association, together with relevant local associations nationwide, jointly launched a united action to banHBCD, fulfilling China’s international commitment to banHBCDand implementing national regulations to build a healthy and environmentally friendly livable environment. Enterprises and units actively responded, jointly promoting the green development of the industry.

Annex III Plastics IndustryHexabromocyclododecane (HBCD) Compliance Work Press Conference and HBCD Elimination Technology Exchange

On April 9, 2021, under the guidance of the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment and the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, hosted by the China Plastics Processing Industry Association, and supported by Shandong Xurui New Materials Co., Ltd. and Shandong Dongxin New Materials Technology Co., Ltd., the "Plastics Industry Hexabromocyclododecane (HBCD) Compliance Work Press Conference and HBCD Compliance Work Exchange Meeting" was successfully held at the Beijing Wuhuan Hotel.

Attending the press conference were leaders and experts from the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment, the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, the Science and Industrialization Development Center of the Ministry of Housing and Urban-Rural Development, the Tianjin Fire Research Institute of the Ministry of Emergency Management, the Ecological Environment Research Center of the Chinese Academy of Sciences, the Flame Retardant Materials Professional Committee of the China Petroleum and Chemical Industry Federation, Beijing Technology and Business University, and other units; media including China Chemical Industry News, China Environment News, China Building Materials News, China Quality News, China Industry News, Consumer Daily, China Plastics Magazine, Plastics Magazine, Tencent Video, Sohu.com, People’s Daily Online, as well as HBCD manufacturers, EPS and XPS board manufacturers, EPS bead manufacturers, flame retardant masterbatch manufacturers, related testing units, university research institutes, and more than 100 representatives from these organizations attended the meeting.

Leaders and experts from the Solid Waste and Chemicals Department of the Ministry of Ecology and Environment, the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, the Science and Industrialization Development Center of the Ministry of Housing and Urban-Rural Development, the Tianjin Fire Research Institute of the Ministry of Emergency Management, the Ecological Environment Research Center of the Chinese Academy of Sciences, the Flame Retardant Materials Professional Committee of the China Petroleum and Chemical Federation, Beijing Technology and Business University, and other units attended the press conference; media including China Chemical Industry News, China Environment News, China Building Materials News, China Quality News, China Industry News, Consumer Daily, China Plastics magazine, Plastics magazine, Tencent Video, Sohu.com, People’s Daily Online, and HBCD manufacturers, EPS, XPS board manufacturers, EPS bead manufacturers, flame retardant masterbatch manufacturers, related testing units, university research institutes, and other unit leaders totaling about 100 representatives attended the meeting.

1. Leaders at all levels from various sectors attached great importance, attended the press conference, and delivered guiding speeches

1. Yu Lifeng, Deputy Director of the Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment, attended the meeting and gave a brief introduction on China’s achievements in fulfilling the Stockholm Convention on Persistent Organic Pollutants and the compliance coordination mechanism. Deputy Director Yu emphasized the importance and urgency of China’s ban on HBCD from the perspectives of implementing ecological civilization thought and maintaining China’s responsible major country image. He focused on introducing the industry’s compliance obligations and national policy requirements for banning HBCD, and expressed hope that enterprises related to HBCD such as EPS beads, flame retardant masterbatch, EPS boards, and XPS boards would use regulatory pressure as motivation to actively research, apply, and promote HBCD alternatives and replacement technologies, implement the new development philosophy, and enhance the international influence of new green flame retardant products and foam industry plastic insulation materials markets.

2, Chairman Zhu Wenwei of the China Plastics Processing Industry Association attended the meeting and delivered a speech, pointing out that as the organization of China's plastics industry, the China Plastics Processing Industry Association has always adhered to properly handling theHBCD phase-out issue, ensuring a smooth transition for theEPS,XPS industries, which is a firm foundation for the healthy development of both sectors. The China Plastics Association pays close attention to the progress ofHBCD phase-out and substitution efforts, establishing a special working group led by the main leaders of the association. Under the guidance of the Ministry of Ecology and Environment's Foreign Cooperation Center, research and guidance work related toHBCD phase-out and substitution have been carried out in the fields of flame retardants,EPS,XPS, grasping the industry's development status, analyzing key difficulties in phase-out and substitution work, facilitating government-enterprise dialogue, and promoting the orderly advancement of related work.

The press conference was hosted by Wang Zhanjie, Vice Chairman and Secretary-General of the China Plastics Processing Industry Association.

3, Liu Jingjiang, Director of the Green Building Materials Division of the Science and Industrialization Development Center of the Ministry of Housing and Urban-Rural Development, attended the meeting and delivered a speech. Organic insulation material companies face the substitution ofHBCD, and developing green building materials is an inevitable choice. Unlike traditional building materials, green building materials require that products reduce consumption of natural resources and ecological environmental impact throughout their entire lifecycle. The "Technical Guidelines for Green Building Material Evaluation" explicitly include "not using hexabromocyclododecane flame retardants" in the scoring system, forming an effective combination ofHBCD phase-out and green building material evaluation, promoting enterprises to eliminateHBCD while achieving sustainable development. Enterprises should balance green development and economic benefits while developing alternative technologies and products.

4 Researcher at the Tianjin Fire Research Institute of the Ministry of Emergency Management, Director of the Testing Center, Chair of the ISO Sub-Technical Committee on Fire Extinguishing Agents and Equipment, and Secretary-General of the National Fire Standardization Committee’s Sub-Technical Committee on Fire Extinguishing Agents, Zhuang Shuang used the water-based film-forming foam extinguishing agent containing PFOS substances, which has the greatest impact in the field of fire extinguishing agents, as an example to explain the various workflows for eliminating POPs substances under the Convention in fire prevention and control, particularly emphasizing the profound impact of the Stockholm Convention on firefighting in China. He stated that the next step for the Tianjin Fire Research Institute of the Ministry of Emergency Management will be to continue focusing on and conducting a series of research projects including basic performance evaluation and verification of new flame retardants, flame retardant performance studies of EPS, XPS with added new flame retardants, the effect of new flame retardants on the oxygen index of EPS, XPS, and rapid on-site detection of HBCD content. Through the efforts of the government, enterprises, and research institutes, future replacement EPS, XPS products will become safer, more environmentally friendly, and greener insulation materials, contributing to the protection of people's lives and property and supporting China’s "carbon peak, carbon neutrality" goals.

2. Policy, standards, and technology promote HBCD compliance, elimination, and substitution work

1Deputy Director Ren Yong from the POPs Convention Office of the Center for International Cooperation and Exchanges of the Ministry of Ecology and Environment gave a keynote report titled "Compliance Requirements, Progress, and Action Plan for the Elimination of HBCD." The report introduced the background of HBCD being listed under the Stockholm Convention and the Convention's control requirements for HBCD, with a focus on emphasizing our country's compliance obligations to eliminate HBCD. It presented the current stage policies and measures jointly formulated by various ministries, as well as the overall plan and program of the grant project supported by the Global Environment Facility. The project will actively assist in achieving compliance goals in four areas: enhancing supervision and law enforcement capabilities related to HBCD, promoting enterprises to eliminate HBCD through BAT/BEP upgrades, strengthening harmless management of HBCD containing waste, and establishing information dissemination and knowledge platforms, ensuring the smooth progress of elimination and substitution work.

2. Professor Liu Wenbin, a researcher at the Ecological Environment Research Center of the Chinese Academy of Sciences, introduced the development of the group standard for “Determination of Hexabromocyclododecane in Molded Polystyrene Foam and Extruded Polystyrene Foam by Gas Chromatography-Mass Spectrometry”. This includes the background, purpose, and significance of the standard development project, as well as the processes of formulation, approval, and publication. The establishment of this group standard will help EPS and XPS companies strengthen the management of HBCD content, provide services for ecological environment, quality inspection, and other related departments in controlling EPS and XPS HBCD, and also offer a basic analytical method for detecting HBCD waste when EPS and XPS are decommissioned in the future.

3 Professor Qian Lijun, Deputy Secretary-General of the Flame Retardant Materials Professional Committee of the China Petroleum and Chemical Industry Federation and a professor at Beijing Technology and Business University, systematically introduced HBCD alternative flame retardants development and current usage status, including production history and current status, production status of the alternative methyl octabromodiphenyl ether, production status of the alternative brominated SBS , and application technology research of HBCD alternatives. Through application experiments of HBCD alternative flame retardants in enterprises, Professor Qian concluded the following: the two HBCD alternatives, methyl octabromodiphenyl ether and brominated SBS , can achieve equivalent substitution for HBCD by adjusting the processing technology of polystyrene foam boards and modifying the form of flame retardant usage. However, since the prices of these two alternatives are still higher than HBCD at present, it is expected that after these two alternatives reach mass production in the future, they will be able to simultaneously replace HBCD in terms of application effect and cost in foamed polystyrene boards.

3. Upstream and downstream of HBCD work together in unity to effectively implement the elimination and substitution efforts

Dr. Wang Liangmin from Shandong Xurui New Materials Co., Ltd. stated: Xurui Company attaches great importance to HBCD compliance work, strictly controls the destination of HBCD, and ensures that the product is used in exempted fields; actively participates in the demonstration activities of production enterprises in China’s HBCD elimination and management project, and has formulated a complete shutdown and conversion plan; at the same time, jointly develops usage methods for alternatives with downstream customers, guiding and recommending the use of new alternatives. Xurui Company actively undertakes the social responsibility of HBCD elimination and substitution, participates in the formulation of the standard "Detection Method of Hexabromocyclododecane in Expanded Polystyrene and Extruded Polystyrene - Gas Chromatography-Mass Spectrometry"; participates in the formulation of the CECS standard "Durability Test Method for External Wall Insulation Materials of Buildings" organized by Tianjin Fire Research Institute and other related work.

Guo Xinqi, Chairman of Nanjing Faninge Energy-saving Technology Co., Ltd., stated that as a representative of enterprises, full preparation should be made, and research on potential problems after substitution should be carried out early. Consideration should be given not only to the R&D status of flame retardant manufacturers in the upstream industry chain but also to the production readiness of midstream manufacturers, with emphasis on the equivalence verification of downstream building energy-saving projects. The company’s preparation measures before and after the HBCD ban and the impact on domestic and international business should be evaluated. At the same time, the environmental performance, economic performance, and engineering usability of HBCD alternatives should be comprehensively considered.

Engineer Zhang Benrong from Wuxi Xingda Foam New Materials Co., Ltd. introduced the progress of the company's HBCD replacement work. He stated: As early as 2015, Xingda Foam began developing non-hexabromocyclododecane (non-HBCD) EPS products. Currently, non-HBCD flame retardant products can be customized according to customer requirements to achieve B2 or B1 grade. In terms of mechanical properties, there is no significant difference compared to hexabromocyclododecane flame retardant products, and the company has the capability to stably supply large quantities to downstream manufacturers. Next, the company will actively cooperate with relevant environmental protection departments to prepare in advance for the elimination of HBCD. Products containing HBCD that are prone to slow sales will be reprocessed in advance, and production of HBCD-containing products will be controlled according to actual customer demand to avoid inventory backlog after elimination.

Chairman Guo Shaojun of Shandong Dongxin New Materials Co., Ltd. stated: The company will actively respond to the HBCD elimination and replacement policy. On one hand, it will properly handle the harmless transformation of the existing HBCD production line, properly arrange related personnel, and strictly formulate the next phase of HBCD production and inventory plans to gradually reduce and stop the production of HBCD products; on the other hand, it will further carry out performance research on HBCD replacement products, actively cooperate with downstream enterprises to conduct trials of alternative flame retardants on EPS and XPS, and prepare well for the elimination and replacement of HBCD.

To fulfill the commitments of international conventions, implement the spirit of the National People's Congress Standing Committee documents, and ensure a smooth transition in the EPS and XPS industries away from HBCD flame retardants before December 25, 2021, the China Plastics Processing Industry Association and the Foam Plastics (EPS, XPS) Special Committee issued the "Proposal to Gradually Cease the Production and Use of HBCD" at a press conference. The proposal calls on enterprises and units in the foam plastics (EPS, XPS) and related upstream and downstream industries to fulfill international convention obligations, join hands to protect the earth, and stop the production and use of HBCD before the specified date. Leaders, guests, and enterprise representatives attending the meeting jointly took the stage to witness the release of the "Proposal."

Attachment 4 Audit Report