Carbon impact analysis required for all new projects

From 1 May, Chinese governments and enterprises must produce a carbon impact analysis for all new investment projects located in China, the National Development and Reform Commission (NDRC) has stated.

In the analysis, governments and enterprises will need to: “predict and calculate the total annual carbon emissions of the project and the carbon emission intensity of major products, propose a carbon emission control plan, clarify the path and method to be adopted to reduce carbon emissions, and analyse the impact of the project on the realisation of the carbon peaking and carbon neutrality target in the region.”

The analysis will feature in the feasibility study report, which is a prerequisite for obtaining government approval, bank loans, and hence implementing a project in China. 

The NDRC stated the requirement in a document published this month – “Outline and Instructions for Compiling the Feasibility Study Report of Investment Projects”.

Prior to this, the only normative document for investment project feasibility studies in China was “Guidelines for the Feasibility Study of Investment Projects (Trial Version)” promulgated in 2002.

NDRC explained that, compared with the Guidelines, the Outline brings in new requirements, like the carbon impact analysis, which will better align feasibility studies with “high-quality development” and make them more “scientific” and “standardised”.

Analysts from China International Engineering Consulting Corporation said the impact of a project on the relevant industry’s total carbon emissions and intensity targets should also be evaluated, likewise the carbon reduction effect of the project’s whole lifecycle.

The Outline is not the first document to require carbon impact analysis of projects. The Ministry of Ecology and Environment (MEE) began to assess the carbon emissions of construction projects in key industries back in 2021.

An expert on carbon management found recently that while the MEE focuses on carbon management and monitoring of projects in isolation, the Outline has a broader scope, requiring an analysis of a project’s impact on regional carbon peaking and neutrality goals. This is a new topic that “may be complex and require new assessment guidelines,” the expert wrote.

Read China Dialogue’s article on the evolution of China’s carbon policies.