The nature of this notice issued by the Ministry of Environmental Protection is a normative document, which is different from laws and regulations. Its effectiveness is weaker than laws and regulations, and it must not conflict with laws and regulations. Can play a role, not conflict. However, administrative punishment shall not be imposed on normative documents. But in fact, in practice, enterprises may still punish according to the documents, which is generally acceptable.
Laws cannot be traced back to the past. If the document is released after the leakage accident, then the leakage should not be regulated. However, if the state of disclosure continues until the document is issued, it can still be punished according to this.