Operations exceeding EIA approval limits

Hong Kong IPO disclosure precedents · 2 companies, 2 items

Project operations exceeding load or capacity limits set out in the EIA approval, and whether this constitutes a material change requiring re-approval or gives rise to penalties.

Compliance matters are read from filings since 24 August 2026.

2026-09-21ProspectusCompliance confirmed
Red Avenue New Materials Group Co., Ltd.彤程新材料集团股份有限公司09607.HK

During the Track Record Period, the Sino Legend factory and BAE (Hubei) factory did not engage in over-capacity production exceeding 30% of the approved production capacity, over which could constitute a violation of laws or regulations or subject to administrative penalties.

Business · p. 125

Therefore, as advised by the PRC Legal Adviser, our Sino Legend factory and BAE (Hubei) factory were not required to undertake renewed environmental impact assessment procedures as a result of their over-capacity productions there.

Business · p. 125
The company's explanation, the adviser's view and the page in the filing: see Matters
2026-09-13PHIPNon-compliance
Hunan Junxin Environmental Protection Co., Ltd.湖南军信环保股份有限公司

During the Track Record Period, some of our Group's projects have operated above their legal overloading limit when measured by the incineration input volume.

Business · p. 136

On this basis, our PRC Legal Advisor considers the legal risks arising from such overloading to be minimal and not expected to have any material adverse impact on our Group's operations.

Business · p. 137
The company's explanation, the adviser's view and the page in the filing: see Matters

Tell us