_Environmental Impact Assessment,_ require environmental impact assessments and plan environmental impact assessment (otherwise known as strategic environmental assessments) for plans which affect the environment within China. The _Environmental Protection Law_ was strengthened in 2014 and enforcement and monitoring has been substantially increased since then (Leung et al. 2013). However, these laws do not apply to foreign investments outside China. Following the example of many developed countries that have extended their national environmental standards to foreign investments, the NGO community has been pressing for Chinese firms to be required to operate under the same regulations for foreign projects that they must follow within China. At a minimum, some analysts feel habituation of these firms to regulation at home will affect their work abroad. Other critics suggest that, without strict regulations, Chinese firms are likely to “outsource” their polluting industries to other countries as domestic environmental laws tighten (Moran et al. 2018).

Though generally Chinese domestic environmental regulations do not apply to overseas investments, environmental regulations specific to Chinese firms investing abroad have been expanded in recent years. The key policy that relates to Chinese overseas infrastructure construction projects, _Guidelines on Environmental Protection for Overseas Investment and Cooperation,_ was released in 2013 by the Ministry of Commerce (MOFCOM) and the former Ministry of Environmental Protection (now the Ministry of Ecology and Environment—MEE). These guidelines encourage but do not require Chinese companies to complete environmental impact assessments (EIAs), develop environmental mitigation measures, and work with local communities to identify potential negative environmental and social impacts when overseas (Leung et al. 2013; Shinn 2016). What would require those steps is not clear.

In addition to environmental and social policies addressing foreign direct investment, there is a growing body of policies that are specific to the Belt and Road Initiative. The initial vision for a Green Belt and Road was released in 2015, followed in 2017 by a guidance document and cooperation plan. All three documents are ambitious and paint a picture of the BRI being able to, “...promote ecological progress in conducting investment and trade, increase cooperation in conserving eco environment, protecting biodiversity, and tackling climate change, and join hands to make the Silk Road an environment friendly one.” (Chinese National Development and Reform Commission, Chinese Ministry of Foreign Affairs, and Chinese Ministry of Commerce, 2015) All three documents are still high‐level and lack critical details on implementation, monitoring, and enforcement (Chun 2017). These policies do depict, however, how BRI projects with appropriate environmental mitigation mechanisms and enforcement could serve as a model of good development practices throughout the region. On the other hand, it is quite clear that positive statements without enforced implementation achieve little. Again, the question is raised concerning how compliance with related promises should be enforced.

# D. Industry and Nonprofit Standards

Firms engaged in BRI projects may voluntarily adhere to best practice environmental standards – typically stricter than those prescribed by lenders or governments – from industry associations or nonprofit organizations. Firms might elect to follow these guidelines because they calculate that it is in their financial interest to invest sustainably or because they receive external pressure – from their customers, governments, or the general public – and reputational benefit from adopting these criteria.

One useful reference concerning such voluntary standards, codes of conduct, and audit protocols relating to sustainability in supply chains is the Standards Map database (www.standardsmap.org), created by the International Trade Centre (Booth 2017). Again, their impact is another question in light of the fact that many positive and well‐intentioned statements are made that do not shift outcomes.

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