Advocacy Actions
Comments to CBIRC on Interim Administrative Measure for Financial Leasing Companies
On 9th February, the European Chamber’s Consumer Finance and Non-Banking Financial Institutions Working Group submitted comments to the China Banking and Insurance Regulatory Commission (CBIRC) on Interim Administrative Measure for Financial Leasing Companies (Draft for Comment).
The Working Group addressed issues concerning financing costs, legal system related to financial leasing and after-sale leaseback, credit bureau system, business management, financial ratios, factoring and cross-border guarantees.
The Working Group gave detailed suggestions on how to improve operations for financial leasing companies:
• Banks are advised to provide medium-term financing, i.e. more than 5 years, to reduce pressure on customer cash flows with long-term assets (i.e., large machinery). In addition, we suggest that the concentration risk and transactions with affiliated parties to be soften in terms of the calculation method for concentration, point of time and average balances.
• The mortgage process for rental properties be improved to protect the ownership of the leasing company. In the after-sale leaseback transaction structure, the lessee is not required to issue a receipt (as a voucher to the bank) to the leasing company before making a payment to the bank. We recommend that customers who use a financial lease to complete their equipment purchase should receive a local government subsidy.
• A period to comply with rules for new start-ups in 2019-2020 would be welcomed.
• To facilitate financing for small and medium-sized enterprises, an easy-to-access and integrated credit bureau system should be open to equipment leasing companies to collect customer payment records and financial statements.
• Electronic signatures, direct debits and swipe with barcodes would be important measures to gather information and limit forgery and money laundering.
• The risk asset/equity ratio should be maintained at 1:10. Any reduction in this ratio change will have a significant impact on the ability of equipment leasing companies to finance small and medium-sized enterprises.
• Since European leasing companies are not allowed to obtain (i) cross-border corporate guarantees or (ii) cross-border bank guarantees (or even bank guarantees from their parent companies), the ability of TNCs to invest in new machinery and equipment in China is significantly limited. The Working Group recommends giving this situation a green light and a convenient process. It also recommends that the possibility of cross-border cash pooling to be explored further.
Overall, the Working Group welcome the CBIRC's efforts to strengthen the management of the financial leasing industry, and we can also feel some recent improvements in the financial leasing industry. We always believe that the financial leasing industry for China's economic development and financing of various industries can provide professional solutions, especially for small and medium-sized enterprises. Here, we are ready to spare no effort to share our international experience in all areas to help the Chinese economy further unlock its potential and momentum.
Meeting wiith DG Trade on Regulatory Updates of China's Food Sector and 2020 Activity Planning
The Paediatric Nutrition Working Group, Cheese Working Group, and Food for Special Medical Purpose Advisory Committee had a meeting with officials from the Directorate-General for Trade of the European Commission. They were briefed the latest regulatory updates of China's food sector and the current difficulty of the special food in China. Also, both sides exchanged ideas on EUCCC's activity planning for the year of 2020 and the proposal of having a training in the Europe in September was much welcome by the European side.
Read moreSubmitted comments to NDRC on Products Catalog of Energy Efficiency Label (15th Batch)
On 7th February, the European Chamber's Energy working group submitted comments to the NDRC on Products Catalog of Energy Efficiency Label (15th Batch).
Read moreEU Tour - Working lunch with Reinhard Buetikofer
On 4th February European Chamber Representatives met with the Chair of the European Parliament's Delegation for Relations with China, Reinhard Buetikofer.
Read morea briefing to COCIR Europe for meeting with SANTE
a briefing note on key issues and recommendations for medical device sector will be raised to DG SANTE
Read moreEUROPE CHINA HEATING INITIATIVE SENT LOBBY LETTER WITH REPORTS TO THE STATE ADMINISTRATION OF MARKET REGULATION ON CHINA COMPULSORY CERTIFICATE REGULATIONS
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Read moreComments to SAMR on the Draft Revisions to the Anti-monopoly Law
The Legal and Compliance WGs have submitted comments to the SAMR on the Draft Revisions to the Anti-monopoly Law.
Read moreComments to SAMR on Draft Revisions to the Anti-monopoly Law of the People's Republic of China (Draft for Comment)
The European Chamber very much welcomes the SAMR's decision to collect opinions on the "Draft Revisions to the Anti-monopoly Law of the People's Republic of China (Draft for Comment)". Upon careful study of the draft and consultation with its members, the European Union Chamber of Commerce in China, led by its Legal and Compliance Working Group, has collated all member inputs and submitted suggestions to the SAMR Anti-monopoly Bureau for their consideration.
Read moreComments to the NPC on the Deed Tax Law of the People's Republic of China (Draft for Comments)
Finance & Taxation Working Group submitted comments to the National People’s Congress of China on the Deed Tax Law of the People's Republic of China.
Comments to the NPC on the Urban Maintenance and Construction Tax Law (Draft for Comments)
Finance & Taxation and Construction Working Groups submitted comments to the National People’s Congress on the Urban Maintenance and Construction Tax Law of the People's Republic of China.