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China's Transition from Energy Dual Control to Carbon Emissions Dual Control

ENFORCEMENT TIMELINE

August 2, 2024

Enforcement: August 2, 2024

Overview

China's "dual control" system is undergoing a historic transition from "energy consumption dual control" -- which simultaneously manages the total volume and intensity (consumption per unit of GDP) of energy use -- to "carbon emissions dual control," which simultaneously manages the total volume and intensity of carbon emissions. The former energy consumption dual control regime contributed significantly to energy-efficiency gains from the 11th Five-Year Plan (2006-2010) onward, but because renewable energy consumption was subject to the same uniform controls, it also constrained economic growth and contributed to sudden power-supply restrictions (including blackouts). From the 14th Five-Year Plan period (starting 2021), the Chinese government adopted a policy of excluding renewable energy and energy used as raw material from total-volume and intensity controls, shifting instead toward directly restricting carbon emissions themselves. In August 2024, the General Office of the State Council formally issued the "Work Plan for Accelerating the Establishment of a Carbon Emissions Dual Control System," establishing a national transition roadmap. Under the new system, the evaluation axis fundamentally shifts from "energy consumption" (the means) to "greenhouse gas emissions" (the outcome). For companies, since the use of non-fossil energy (renewables and nuclear) is effectively excluded from emissions-cap regulation, it becomes possible to pursue economic development and decarbonization simultaneously. The plan is to build infrastructure such as carbon emissions statistics and accounting systems by 2025, move to full implementation during the 15th Five-Year Plan period (2026-2030) with carbon-intensity management as the primary approach supplemented by total-volume management, and after peaking in 2030, transition in stages to a system centered on total-volume management of carbon emissions.

Enforcement Timeline

- December 2021: The Central Economic Work Conference decided to exclude renewable energy and energy used as raw material from total energy consumption controls.

- November 2022: The National Bureau of Statistics, the National Development and Reform Commission (NDRC), and other bodies issued a notice excluding non-fossil energy consumption from energy consumption dual-control evaluation.

- August 2, 2024: The General Office of the State Council released the "Work Plan for Accelerating the Establishment of a Carbon Emissions Dual Control System."

- By the end of 2025: Basic infrastructure for carbon emissions measurement, reporting, and product carbon footprint standards is to be established, along with the start of a "carbon budget" management pilot.

- 2026-2030 (15th Five-Year Plan): Transition to a phase centered on carbon-intensity management, complemented by total-volume management.

- After 2030: Transition to a system centered on "total-volume management" of carbon emissions, promoting absolute reductions.

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Business Impact

For Japanese companies operating in China -- particularly power-intensive manufacturers in chemicals, metals, and electronics -- the shift from energy-volume constraints to carbon-emissions constraints represents a major business transformation. Companies must move quickly from traditional "energy saving" (reducing energy volume) to "decarbonization" (renewable procurement and process conversion). Installing on-site solar power at local plants and increasing the share of green power procurement become decisive means of avoiding restrictions on plant operations and energy sourcing. Pressure to calculate and reduce product-level carbon footprints (CFP) is also intensifying.

Official Sources & Reference Links