Dear Wot.
Extract from your post:
"...NDRC isn't required on 100m.
NDRC"
unquoted
Please do not keep misleading us by saying that China's NDRC approval is not required. You did not read well the regulation. The new regulation suggests that CENTRAL government (Beijing) approval is only required for US$300 million and above but for the amount less than US$300 million and in this case of WAPRC i.e. A$100 million, it requires regional government's approval i.e., NDRC Shanghai office.
I suggest that you read ANS announcement on 25 Sep 2018, Schedule 4 on page 26
"Monetary thresholdAustSino understands that proposed investments below US$300 Million require approval by theregional office of NDRC, rather than by the Beijing office of NDRC.AustSino also understands that because WAPRC is established/located in Shanghai and the valueof the Proposed WAPRC Transaction is A$100 Million, WAPRC’s application for ODI approval isbeing considered by the Shanghai office of NDRC.Status and indicative timing of WAPRC’s ApplicationAustSino understands that WAPRC has prepared, but has not yet formally lodged, its applicationwith the Shanghai office of NDRC....
WAPRC anticipates formally lodging its completed ODI application around the endof September and that its ODI application will take approximately 4-6 weeks to be considered"