Starting September 1, 2025, China enforces mandatory carbon-emission evaluations for all new, expanded, or upgraded projects. The project approval framework moves beyond a single "energy-saving review" to a dual constraint of "energy efficiency plus carbon emissions control," a key measure supporting China's 2030 carbon emissions peaking target and the nationwide shift toward a carbon dual-control mechanism.
Key Policy Changes
Centralized review for high-energy projects: Projects with annual energy use ≥500,000 tonnes of standard coal (or ≥500,000 tonnes of coal) will now be reviewed at the national level, closing previous gaps in provincial discretion. Approval for energy- and emission-intensive projects is prohibited at county level, ensuring that even borderline projects are subject to rigorous oversight.
>>> Industries such as steel, chemicals, cement, and nonferrous metals will see higher entry thresholds, pushing low-efficiency capacity out and concentrating resources in low-carbon leaders.
Simplified approval procedures for low-carbon projects: Projects consuming <1,000 tonnes of standard coal annually may be exempted from review, encouraging investment in green innovation, including renewables, zero-carbon technology manufacturing, and carbon-management services.
Implications for Companies
- Rising compliance costs: Enterprises must accurately calculate full lifecycle carbon emissions, rigorously meet energy and emission targets, and prioritize carbon accounting, energy efficiency, and green electricity usage.
- Review results tied to credit and financing: Projects failing review cannot start; non-compliant firms face credit supervision, affecting future financing and policy support.
- Regional risk becomes a key investment factor: Companies need to evaluate local energy saving and carbon reduction progress to avoid areas with restrictive approvals and project uncertainty.
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Our full report provides an in-depth analysis of the 2025 "Measures for Energy Conservation Review and Carbon Emission Evaluation of Fixed-Asset Investment Projects":
- Key changes compared with previous review methods
- Impacts on corporate compliance and investment strategy
- Historical evolution of China's energy-saving review system
The above content is the major conclusions and highlights extracted from China (Energy Transition) Policy Perspective. To get detailed full text, send an email to glconsulting@mysteel.com.
