Mulch Film Pollutes Farmland as Supervising Departments Wage Absurd “Duel of Laws”
I. A “Film” Calamity Flies In
All Li can do is gather a few workers to pick up the mulch film fragments from the cow shed. “This film is so light and brittle—it looks like ultra-thin substandard mulch film.”
If left untreated, the mulch film will be worked into the soil during ploughing. Not only will this hamper the growth of this season’s crop, but the film can never be fully recovered and barely decomposes—it only shatters extremely slowly in the soil into plastic fragments, or is even absorbed by crops as microplastics.
How has Li, who does not use mulch film at all, become a victim of mulch-film pollution? It turns out that, since 25 December last year, a temporary processing plant has been set up 100 metres from the edge of his field. This small factory, occupying no more than a few dozen square metres, buys up large quantities of peanut haulm from neighbouring farmers, shreds it, and processes it into roughage to feed livestock. Because the mulch film was not removed when the peanut haulm was purchased, the film—tangled in the haulm—was fed into the shredder alongside it. The shattered film then swept on the wind over to surrounding farmland, including Li’s.
This processing plant was put up only after the peanut harvest, and the site it occupies was originally permanent basic farmland belonging to the village. With such primitive conditions, no additional protective measures were in place at the processing site, and the mulch film blew everywhere.
On 1 January 2025, Li called the 12345 Mayoral Hotline to report the pollution. He has since submitted written complaints to the local sub-district office, the Bureau of Ecology and Environment, the Bureau of Agriculture and Rural Affairs, and other departments.
More than two months have passed since the problem began. The season for sowing spring wheat is nearly upon him, and Li also plans to sow peas, garlic, rapeseed, pak choi and other vegetables, which, once ripe, will be the main source of his annual income. But the mulch film in the soil has prevented him from sowing, and the sowing window is about to pass—costing him a year’s livelihood.
Li was once a supplier of agricultural inputs and had seen first-hand how pesticides, chemical fertiliser and plastic film harm both people and the land. Fifteen years ago, he took a land-transfer lease on farmland in his hometown of Nuomizhuang Village and adopted ecological agriculture—growing grain and vegetables without pesticides, chemical fertiliser or herbicide. These 70 mu of farmland represent a patch of clean land he has spent years protecting. It is precisely for this reason that he is deeply pained by the mulch-film pollution that many farmers have long grown accustomed to.
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The processing plant refused to take any measures, so Li had no choice but to pay out of his own pocket, giving 2,000 yuan to the village Party secretary, who passed it on to the other party. A simple screen was then erected at the edge of Li’s field. The processing plant also agreed to cover the cost of hiring village-collective workers to pick up the mulch film that blew into Li’s field, but after just a few days it stopped, with the excuse that “picking it up every day is simply unaffordable”. The company is unwilling to halt production, yet as long as it keeps processing, more mulch film blows over every day. Left with no way forward, Li has continued to file complaints with the government.
II. A “Duel of Laws” from Afar Between the Agriculture and Environment Departments
Both stated in their responses that the pollution caused by mulch film fell outside their scope of responsibility, and therefore they could not take enforcement action against the company involved, suggesting the matter be handed over to the other department to resolve.
The Bureau of Agriculture and Rural Affairs, however, quoted only the fourth clause: “Ecological environment departments at or above the county level shall be responsible for supervising environmental pollution prevention and control during the recycling and reuse of agricultural film.”
In other words, in the chain of events where inadequate mulch film recycling led to pollution, each side saw only the other’s dereliction of duty while turning a blind eye to its own.
Second, a key point in their point-counterpoint argument was this: Is the mulch film that blew into Li’s field still, legally speaking, “mulch film”?
The Bureau of Ecology and Environment suggested handling the matter under Article 88 of the Law on the Prevention and Control of Soil Pollution: “Where producers, sellers, or users of agricultural inputs fail to promptly collect packaging waste or agricultural film in accordance with regulations… the agricultural and rural affairs department of the local people’s government shall order rectification.”
But the Bureau of Agriculture and Rural Affairs responded that a feed-processing company is not a producer, seller, or user of mulch film, and therefore “our department has no legal basis for enforcement.” They instead cited Article 102 of the Law on the Prevention and Control of Environmental Pollution by Solid Waste, arguing that the case constituted “solid waste pollution” and should be penalised by the ecological environment department.
In other words: in this case, what blew into Li’s field is no longer mulch film in the legal sense—it is solid waste.
“Solid waste” refers to materials generated during production, daily life, or other activities that have lost their original use value, or which, while not yet having lost use value, have been abandoned or discarded.
But the Bureau of Ecology and Environment “played a cleverer move,” using the Solid Waste Law to outmanoeuvre the Solid Waste Law itself, citing Article 64: “The agricultural and rural affairs departments of people’s governments at or above the county level shall be responsible for guiding the development of the recycling and reuse system for agricultural solid waste, encouraging and guiding relevant units and other producers and operators to lawfully collect, store, transport, utilise, and dispose of agricultural solid waste, strengthening supervision and management, and preventing environmental pollution.”
In plain terms: Solid waste is my responsibility, but agricultural solid waste is still the Bureau of Agriculture and Rural Affairs’ business.
Li, having received these two responses, was left too grief-stricken to weep. He continued to raise the issue through government website messages, telephone hotlines, and other channels. So far, there has been no progress whatsoever.
III. Who Should Really Be Responsible for Agricultural Solid Waste?
But discarded mulch film can only appear in a processing setting as the inevitable result of inadequate mulch film recycling in the fields. In 2023, the procuratorate in Chengde, Hebei, ordered a local agricultural and rural affairs department to fulfil its supervisory duties over mulch film use and recycling, after widespread mulch film use in a village had caused farmland pollution.
The logic of recycling and pollution is simple enough: recycle, and there is no pollution; do not recycle, and pollution follows. Yet at the government level, recycling is the responsibility of the agriculture department while pollution falls to the environment department—their powers and duties are like two sides of the same coin. When a pollution incident occurs, the stages each department oversees have necessarily both failed; both bear a share of responsibility and both have grounds to intervene.
Yet the reality is that “both should manage it” has become “neither will manage it”. Although the state has enacted a series of laws and regulations—the Solid Waste Law, the Law on the Prevention and Control of Soil Pollution, the Administrative Measures for Agricultural Film, and so on—it seems that the more provisions there are, the more readily the departments in question find excuses to shift responsibility.
A scholar who researches solid waste observes that the Solid Waste Law’s provisions on managing agricultural solid waste are relatively vague, leaving the agricultural solid waste management system, in practice, still a blank.
Agricultural film, including mulch film, is the fourth-largest category of agricultural inputs after seeds, pesticides, and chemical fertiliser. Due to a long-standing emphasis on use over recycling, China’s mulch-film pollution problem is severe—nearly 300 million mu of farmland are mulch-covered each year, with annual usage approaching 1.45 million tonnes, accounting for roughly 75% of global mulch film consumption.
Due to various constraints in recycling technology and equipment, China’s agricultural film recycling rate has long remained below two-thirds. In 2017, the former Ministry of Agriculture issued the Action Plan for Agricultural Film Recycling, launching the establishment of 100 mulch-film governance demonstration counties in northwestern China and proposing that, within two to three years, the same-season mulch film recycling rate in these demonstration counties should exceed 80%.
Although mulch-film governance finally took concrete action, this only covers “same-season” recycling. China’s cumulative mulch film residue over the years already exceeds one million tonnes.
According to 2016 Ministry of Agriculture monitoring data, mulch film residues of varying degrees have been found in all mulch-covered farmland soils across China. In some areas, the average residue reaches 4–20 kg per mu, and in individual plots it can exceed 30 kg—equivalent to six layers of mulch film. Residual mulch film destroys soil structure, impairs seedling emergence, hinders root growth, and causes crop yield losses. No authoritative statistics yet exist on the direct economic losses to agricultural production caused by years of accumulated mulch film nationwide.
Furthermore, a 2019 article by Zhang Bin and colleagues at the Rural Economic Research Centre of the Ministry of Agriculture and Rural Affairs noted that mulch film residue is a particularly acute problem in areas outside national project zones, ultra-thin mulch film remains widely available on the market, and farmers have little incentive to collect residual mulch film.
Yan Changrong, a researcher at the Chinese Academy of Agricultural Sciences, once estimated in an article that removing mulch film from peanut haulm for use as livestock feed costs approximately 30–50 yuan per mu. Often, however, no one bears this cost, which means mulch film escapes into the environment, becoming a major source of plastic pollution.
When mulch film is mixed into animal feed, it has numerous adverse effects on the animals’ health; in severe cases it can even be life-threatening, while also causing economic losses to livestock farmers.
Plastic mulch film not only harms the soil and agriculture itself—wind-borne film also endangers public infrastructure. During the 2021 May Day holiday, a high-speed train on the Beijing–Guangzhou railway line was halted as it passed through Dingzhou in Hebei because mulch film had caught on the catenary, and more than a dozen other high-speed trains were suspended or delayed as a result.
Stories like “mulch film halts a high-speed train” are merely the tip of the iceberg the public can see. Staff from both the sub-district office and the Bureau of Agriculture and Rural Affairs have told Li that there are far too many incidents of mulch-film pollution in the area to possibly manage them all.
Li’s main demand at present is for an assessment of the pollution on his and neighbouring farmers’ land, followed by soil remediation based on a scientific assessment—addressing not only the visible fragments of mulch film but also the invisible microplastics.
He said: “I have been doggedly raising this issue, not only for myself but also for the surrounding villagers, and for the wellbeing of future generations. Our generation should not leave the next nothing but a scarred landscape.”
For Li, turning to the internet for help is an act of desperation after exhausting every other avenue. But recent developments have made him increasingly anxious: ever since he turned to government departments for help, the company involved has accelerated its processing, and ever more mulch film is drifting over. He suspects the company is rushing to finish this batch of raw materials before absconding. Because the processing plant was temporarily set up on farmland, they could simply pack up and leave.
Addressing mulch-film pollution requires not only clear delineation of powers and responsibilities among government departments, but also sensible solutions and detailed management measures.
Who will take charge? What will be done? Li needs an answer, and the polluted land needs an answer too.
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Thanks to Zhang Miao, Liu Jinmei, and Tian Jing
for their assistance during the writing of this article
Edited by: Foodthink