China’s ETS is the world’s largest, regulating over 3,500 companies in the power, steel, cement, and aluminium sectors. Whilst not directly linked to any other ETS, China’s ETS has marked similarities with other ETSs, including the EU’s (see here for further details).
The ETS builds on the success of the seven regional carbon markets ("Regional Schemes") introduced from 2011. The Regional Schemes continue to operate in parallel, covering entities not included in the ETS, although the ETS Regulations clarify that no new regional schemes will be established in the future.
Under the ETS Regulations, the MEE is the primary agency responsible for supervising carbon allowance trading, and is responsible for developing a carbon emission allowance cap-setting and allocation plan in line with state requirements. Various other agencies share responsibilities including:
- China’s State Administration for Market Regulation ("SAMR"), the People’s Bank of China ("PBOC"), and the National Financial Regulatory Administration ("NFRA"), which jointly oversee the national carbon allowance tracking system and trading platform.
- The National Development and Reform Commission ("NDRC"), which is responsible for defining the categories of greenhouse gases ("GHGs") and the industry sectors included in the system.
- Local MEEs, which will manage carbon trading activities, including preparing annual lists of covered entities, allocating the free allowances in line with the allocation plan, verifying annual emissions reports, and conducting on-site inspections.
Key Emitting Entities are required to prepare annual GHG emissions reports in accordance with the technical guidelines issued by the MEE, which local MEEs will then verify with the assistance of technical service agencies if needed. Key Emitting Entities must then surrender their annual carbon emission allowances ("CEAs") to the MEE, totalling no less than their verified amount of GHG emissions for the previous year, by the deadline set by the MEE.
Under the legislation, there are two methods of allocating CEAs:
- Free allocation using a benchmarking approach:
- In the power sector, allocation is based on output-based benchmarks using the following categories: (i) conventional coal plants; (ii) unconventional coal plants; and (iii) natural gas plants. Allowances are pre-allocated annually and then adjusted after the compliance year to reflect actual production.
- In the steel, cement, and aluminium sectors:
- In 2024, these sectors received free allowances equal to their verified emissions.
- From 2025 onward, allocation is output-based and intensity-controlled.
- Auctioning: the Interim Regulations include a commitment to introducing auctioning of carbon allocations, albeit with no specific deadline.
CEAs can then be traded on the Shanghai Environment and Energy Exchange through contract transfer, one-way bidding, or other methods that comply with the regulations. ETS regulators, registry and trading platform operators, and verification service agencies and their staff are prohibited from engaging in trading.
Alongside the ETS, China re-launched its voluntary carbon market with the issuance of the Administrative Measures on Voluntary Greenhouse Gas Emission Reduction Transaction (Trial Implementation) (2023) (the "CCER Regulation"). Key Emitting Entities are allowed to use Chinese Certified Emission Reductions ("CCERs") to offset up to 5% of their annual carbon emission allowances that otherwise would be surrendered under the ETS.
Penalties and enforcement:
Key Emitting Entities that fail to report GHG emissions or falsify data, face fines starting at CNY 500,000 (≈USD 70,000) and up to ten times any illegal gains.
Non-compliance with allowance surrender obligations can result in fines of five to ten times the market value of the shortfall, higher than the previous maximum fine of CNY 30,000 under the Trial Measures. Persistent refusal to surrender allowances after warnings can lead to deductions from next year’s allocation and production suspension.
Technical service providers involved in reporting and verification fraud can be fined up to ten times their illegal gains and disqualified from practice.
Market participants engaging in manipulation face fines starting at CNY 500,000 and up to ten times their illegal gains.
Next steps
Currently, the ETS operates on a carbon intensity-based model, creating an upper limit for GHG emissions based on emissions per unit of economic output. Above this upper limit, allowances are required in order to continue to emit. From 2027, the upper limit will become an absolute one, with the allowances system continuing to function in the same way.
China has also recently announced that it will expand the sectors covered by the ETS by 2027; we will update this entry with information as soon as there is more clarity on the point.