China's Comprehensive Resource Conservation Plan: What It Actually Says About Steel, Scrap and the 'Second Resource' Agenda

The notice that wasn't the policy

On 5 November 2026, MIIT's energy-saving and comprehensive utilisation department posted a short transmittal notice for the Action Plan for Implementing the Comprehensive Resource Conservation Strategy (《实施全面节约战略行动方案》), document number 发改环资〔2026〕1424号. The page contained only the cover letter: five ministries, three sentences of purpose, a list of provincial addressees. Several trade outlets and aggregators picked it up as though the plan's contents were contained within it. They were not.

The full text sits as a PDF/OFD attachment on NDRC's policy-release page (published 4 November, signed 29 September), and NDRC simultaneously released a Q&A and a set of expert commentaries. That is where the steel-relevant material lives. The gap between the transmittal and the substance matters, because the plan is not a steel document at all — it is a cross-cutting framework spanning energy, water, grain, land, minerals and materials (能水粮地矿材) — and steel's role in it has to be read out of individual articles rather than a dedicated chapter.

The fifth signatory is worth noting. 国管局 is the public-institution (公共机构) administration, not an industrial ministry — which is why the plan carries a strong public-sector conservation chapter alongside its industrial provisions. Implementation runs through five parallel provincial hierarchies, not a single steel regulator.

The 2030 targets and what they imply

Against a 2025 baseline, the plan sets four headline outcomes, independently reported by Xinhua:

Sub-targets in the text sharpen this: energy consumption per unit of value-added in industry above designated size down more than 10%; energy-saving and carbon-reduction retrofits in key sectors delivering at least 150 Mtce of savings; water use per RMB 10,000 of industrial value-added −10%; new construction land capped at 26 million mu over the 15th Five-Year Plan; bulk industrial solid-waste utilisation of roughly 450 Mt/yr by 2030; and combined-utilisation rates of co-associated minerals in major nonferrous deposits up 2–3 percentage points.

The 510 Mt secondary-resource figure is the one to watch. China's Material Recycling Association put 2025 recovery across 11 major categories at 417 Mt, up 4.1%, with scrap steel the largest single stream at roughly 60% — around 250 Mt on the association's own arithmetic (the exact share is reported variously as 60.8% and 60.9% in different releases; treat the tonnage as an estimate derived from those percentages, not a directly published number). Getting from ~417 Mt to 510 Mt in five years implies roughly 4% compound growth — close to the recent trend, so the target is best read as a floor to be defended rather than a stretch goal. The policy weight lies in how the volume is to be captured, not the headline number.

Where steel actually appears

The plan contains no scrap-ratio target, no EAF share, no crude-steel output cap. Any such figure circulating in trade coverage is not from this document. What it does contain is a set of binding constraints and enabling measures that touch steel at four points.

1. Steel leads the retrofit list. Article 2 (大力推进重点领域节能) names steel first among 钢铁、有色、石化、化工、建材 for "one sector, one policy" (一行一策) energy-saving and carbon-reduction retrofits. This is the article that carries the >10% industrial energy-intensity cut and the 150 Mtce savings figure. For mills, the operative question is not whether retrofits are expected — they already are under the 2024 steel-sector action plan — but that steel's position at the head of the list signals priority in the allocation of central support and in provincial performance assessment.

2. The project-approval gate tightens. Article 1 requires new, expanded and retrofitted high-energy, high-emission industrial projects to implement carbon-emission equivalent-or-reduced substitution (碳排放等量或减量置换), with strict enforcement of the fixed-asset investment project energy-review and carbon-assessment rules. In national air-pollution key regions, new or expanded coal-using projects face equivalent-or-reduced coal substitution; coal-fired boilers of 10 t/h or below are to be eliminated outright, and old low-efficiency coal units and boilers phased out. This is the layer with real capital-allocation consequences: it governs whether a new EAF shop, a DRI plant, a coal-based process line or captive boiler capacity can be permitted at all, and where.

3. Scrap becomes strategic. Article 14 names 废钢铁 first among "urban mine" streams — ahead of end-of-life vehicles and waste electrical and electronic products — and calls for stronger recovery of tailings, bulk industrial solid waste, battery/PV/wind "new three" waste and precious and rare metals. Article 15 goes further, permitting orderly imports of high-quality overseas secondary resources on the premise of zero solid-waste imports, reforming inspection and supervision of secondary raw materials, and studying the siting of overseas secondary-raw-material collection-and-processing hubs. NDRC's expert commentary frames this explicitly as turning the "urban mine" into a "second resource" for national resource security.

That import clause is the most commercially significant sentence in the plan for steel. It extends a direction already set in the 2024 steel-sector energy-saving and carbon-reduction action plan, which backed expanding imports of recycled steel raw material (再生钢铁原料). The addition here is the hub concept — a possible offshore processing layer for scrap destined for Chinese mills, which would address the quality and contamination problems that have historically limited ferrous scrap imports under the 再生钢铁原料 standard.

4. Demand-pull for recycled content. Article 15 also launches a "recycled materials application upgrade action" in autos, appliances and daily chemicals, led by backbone enterprises. For steel this is a downstream pull mechanism: appliance and auto supply chains specifying recycled content translate into preference for scrap-fed steel, and potentially into traceability requirements that favour integrated recyclers over informal collectors.

Rounding out the package: Article 19 pushes revisions to the Energy Conservation Law, the Circular Economy Promotion Law and the public-institution energy rules, plus tighter energy/water/material-consumption standards and metering audits; Article 20 offers differentiated electricity pricing for high-energy industries and green credit and green bonds for conservation projects. Neither creates new process mandates for steel, but both change the compliance and financing environment around existing ones.

Analytical read-across

The framing matters more than any single measure. NDRC's Q&A presents demand-side reduction as buying space for supply-side transition — a sequencing argument that has become standard in Chinese resource policy and that implicitly concedes industrial output will not be cut to meet intensity targets. The practical effect for steel is that the pressure falls on how tonnes are made (energy per tonne, carbon per new project, scrap share in the burden) rather than on how many.

The one genuine novelty is the import-and-hub language. If it moves from "研究" (study) to pilot, it would create a formal offshore supply channel for ferrous scrap and begin to normalise a trade flow that Chinese mills have wanted for years and that exporters in Japan, Europe and North America have been slow to build at scale. That is a multi-year development, not a 2027 one, but it is the clause worth tracking in follow-up implementing documents.

For now, the operative near-term items are the carbon-substitution gate for project approvals and the provincial allocation of retrofit support to steel under the 一行一策 rubric. Mills with capex plans in the pipeline should read Article 1 before Article 2.

References

• NDRC, 关于印发《实施全面节约战略行动方案》的通知 (发改环资〔2026〕1424号), with full-text attachments: https://www.ndrc.gov.cn/xxgk/zcfb/tz/202611/t20261103_1408504.html
• NDRC, 答记者问 on the Action Plan: https://www.ndrc.gov.cn/xxgk/jd/jd/202611/t20261103_1408528_ext.html
• NDRC expert commentary (城市矿山 as "second resource"): https://www.ndrc.gov.cn/xxgk/jd/jd/202611/t20261103_1408527.html
• Full plan text via China Petroleum and Chemical Industry Federation platform: https://www.pcp.org.cn/detail.php?ClassCode=10&token=998640a916169656
• MIIT transmittal notice (cover letter only): https://www.miit.gov.cn/xwfb/gxdt/sjdt/art/2026/art_9b0c3adacea742ed84f6851c9d139622.html
• Xinhua, 多部门联合印发《实施全面节约战略行动方案》: https://www2.xinhuanet.com/politics/20261104/841d4ec9090c47988ddf1fec8fbab9b1/c.html
• NDRC, 去年我国再生资源回收规模达4.17亿吨: https://www.ndrc.gov.cn/fggz/hjyzy/zyzhlyhxhjj/202604/t20260428_1404935_ext.html
• 《中国再生资源回收行业发展报告（2026）》 summary: https://www.zgzszyhs.cn/mobile/news/show.php?itemid=3198
• 钢铁行业节能降碳专项行动计划 (2024), State Council: https://www.gov.cn/zhengce/zhengceku/202406/P020240608361880883927.pdf
• Mysteel morning briefing, 5 Nov 2026: https://m.mysteel.com/a/26110507/8F541262C49AEE41_abc.html