Buildings lacking planning or construction permits
Hong Kong IPO disclosure precedents · 4 companies, 4 items
Self-built auxiliary facilities constructed without prior planning/construction approvals, or buildings built by predecessors before acquisition where the planning and construction permit status cannot be confirmed, resulting in no title certificate.
Compliance matters are read from filings since 24 August 2026.
We constructed three ancillary structures at our Kunshan production base, comprising two water-recycling equipment rooms as well as an air-compressor equipment and power-distribution equipment room, with an aggregate gross floor area of approximately 2,087 square meters (the “Relevant Structures”), without completing the applicable environmental impact assessment, construction project planning, construction permit and other approval procedures. Accordingly, we have not obtained real estate ownership certificates for the Relevant Structures.
Risk Factors · p. 34
our Directors and our PRC Legal Advisor are of the view that the lack of real estate ownership certificates for the Relevant Structures will not have a material adverse effect on our Group’s overall production and business operations.
Risk Factors · p. 34
On May 11, 2023, the Comprehensive Administrative Enforcement Bureau of the Kunshan Economic and Technological Development Zone agreed in writing that demolition of the relevant equipment rooms could be deferred.
During the Track Record Period, we had not obtained the requisite construction planning permit (建設工程規劃許可證), construction commencement permit (施工許可證) and/or acceptance of completed construction project prior to the commencement of construction and/or operations of certain production facilities, which may subject us to administrative penalties under the applicable PRC laws and regulations.
Risk Factors · p. 39
Due to the lack of relevant records, we were unable to ascertain whether the Pre-acquisition Properties had obtained the relevant construction planning permit and construction commencement permit prior to their construction.
Business · p. 144
our PRC Legal Adviser is of the view that, barring any material change in the PRC policies and regulations and the implementation and regulatory requirements of the local governments, the risk that the relevant government authority would impose administrative penalties on RA Zhenjiang with respect to the above non-compliances is remote, and such non-compliance incidents would not have any material adverse effect on the normal use and operation of the properties of RA Zhenjiang.
In addition, as of the Latest Practicable Date, we had constructed a temporary storage shed (with an aggregate gross floor area of approximately 875 sq.m.) and a foundry ancillary room (with an aggregate gross floor area of approximately 520 sq.m.) (collectively, the ''Ancillary Facilities'') for which no prior approval had been obtained from the Yulin Natural Resources Bureau, the competent local authority.
As of the Latest Practicable Date, we had obtained the relevant construction land planning permit (建設用地規劃許可證), construction planning permit (建設工程規劃許可證) and construction permit (建築工程施工許可證) from the government authorities for such property under construction.