China’s National Development and Reform Commission (NDRC) has issued revised “Measures for Energy Conservation Review and Carbon Emission Evaluation of Fixed-Asset Investment Projects”, effective from 1 September 2025. The new measures mark a shift from the former dual control of energy consumption – total energy use and energy intensity per GDP – to a dual control of carbon emissions – total carbon emissions and carbon intensity per GDP. It aims to prohibit the delegation of energy review to agencies at the county-level, especially for high-energy-consuming and high-emission projects.
Background
The update follows the “Work Plan for Accelerating the Construction of a Dual Control System for Carbon Emission (2024)“, which sets a phased approach:
- During the 15th Five-Year Plan, the dual control system will focus on carbon intensity control, with total emissions control as a supplement.
- After carbon peaking, it shall reverse the focus. The total emissions control becomes primary, while intensity control being supplementary.
What the new measures add
Carbon emission evaluation forms part of the energy conservation review for fixed-asset projects. This involves:
- Assessing a project’s carbon emissions, expected impacts, and mitigation measures against dual control targets.
- Integrating the results directly into the project’s energy conservation review opinion.
- Review agencies must prioritise carbon evaluations for projects with high emissions or potential adverse effects on regional carbon peaking and carbon neutrality targets.
Roles and responsibilities
NDRC shall develop review management measures, technical standards, and guidelines, conduct training, and supervise subnational reviews. NDRC has established a dynamic adjustment mechanism according to demands of industrial development, energy conservation and emission mitigation. NDRC implements energy conservation reviews for projects with an annual comprehensive energy consumption of 500,000 tons of standard coal or more (or an annual coal consumption of 500,000 tons or more).
Provincial energy conservation departments shall coordinate with other agencies to control fossil fuel use, prevent approval of high-energy, high-emission, low-value projects, and advance carbon peaking and carbon neutrality. Provincial energy conservation departments hold accountable for and implement energy conservation reviews for projects with an annual comprehensive energy consumption between 10,000 and 500,000 tons of standard coal (or an annual equivalent coal consumption).
No energy conservation review is envisioned for projects with an annual comprehensive energy consumption of less than 1,000 tons of standard coal and an annual coal consumption of less than 1,000 tons, or projects related to national security.
Review criteria
Authorities assess:
- Whether projects comply with relevant laws, regulations, and standards of energy conservation and carbon emission reduction.
- Whether their products and equipment meet mandatory energy efficiency requirements.
- Whether projects include effective, feasible energy conservation and carbon emission reduction measures and whether energy management systems are complete.
- Whether the calculations and analysis of energy consumption and carbon emission data are objective and accurate, whether the methods are scientific, and whether the conclusions are valid.
- Whether the project affects the national and regional carbon emissions, whether it affects the achievement of the regional carbon emissions intensity reduction target, whether the carbon emissions per unit of product and output comply with national and industrial standards, and whether advanced and applicable technologies are used to tap into carbon reduction potential.
Implications
According to the National Energy Conservation Center, the new measures strengthen not only energy scrutiny but also carbon management, targeting reduced coal and fossil fuel use and laying the groundwork for effective dual-carbon control during the 15th Five-Year Plan.
Original policy:
