Strategic transparency under authoritarian environmentalism: information disclosure and the role of environmental NGOs in China’s national emission trading scheme

Figures & data

Figure 1. Overview of C-ETS disclosure process and the various actors involved (Source: authors).

Figure 2. Price of carbon allowance in the C-ETS (Source: authors).

Figure 3. Key Emission Entity List Disclosure in Different Provinces (as of January 2022). Source: authors.

Table

Code	Type	Role and function	Date
A1	Academia	Associate professor, Netherlands	2021-09-24
A2	Academia	Associate professor, China	2021-10-07
A3	Academia	Associate professor, China	2021-10-12 2021-10-26 2021-11-19
A4	Academia	PhD research, United States	2021-10-15
C1	Consultancy	Former Manager in international NGO, Manager in consultancy company	2021-11-04
C2	Consultancy	Senior Manager in research institution and international consultancy company, with ENGO background	2021-12-03
C3	Consultancy	Former verifier in international verification company, Director in consultancy company in China	2022-06-14 2022-06-28
C4	Consultancy	Trader in national and provincial ETS	2023-11-16
E1	Environmental non-governmental organization	Senior Manager in international NGO, Beijing Office	2021-10-29 2022-06-20
E2	Environmental non-governmental organization	Project Manager in international ENGO, Beijing Office	2021-11-03
V1	Third-party Verification	Senior Analyst in one Chinese ETS well-known verification and consultancy agency	2022-06-16
V2	Third-party Verification	Verifier in national official verification agency	2022-07-18
V3	Third-party Verification	Verifier in provincial verification agency, with close relationships with entities	2023-11-21
V4	Third-party Verification	Verifier in provincial verification agency, previously work with domestic ENGO	2023-11-28

Table

Issued time	Name	Issue institution
2015 September	U.S.-China Joint Presidential Statement on Climate Change	State of Council
2017 December	Work Plan for Construction of the National Emissions Trading Scheme (Power Sector)	NDRC
2019 March	The National Measures for the Management of Third-Party Verification Agencies for Carbon Emissions Trading (Trial)	MEE
2019 March	Measures for the Administration of Greenhouse Gas (GHG) Emission Reporting by Key Emission Entities (Trial)	MEE
2020 December	Implementation Plan for the 2019–2020 national carbon emission trading allowance setting and allocation (power sector)	MEE
2021 February	National Measures for the Administration of Carbon Emission Trading (Trial)	MEE
2021 March	Guideline on Enterprises GHG Emissions Accounting and Reporting – Power Generation Facilities	MEE
2021 March	Guidelines for Enterprises GHG Verification (Trial)	MEE
2021 May	Rules for the Administration of Carbon Emission Trading (Trial)	MEE
2021 May	Rules for the Administration of Carbon Emission Registry (Trial)	MEE
2021 June	Announcement on Matters Relating to National Carbon Emissions Trading	Shanghai Environment and Energy Exchange (SEEE)
2021 July	Announcement on the Release of Information on National Carbon Emissions Trading	SEEE
2021 December	Measures for the Administration of Legal Disclosure of Environmental Information of Corporations	MEE
2022 January	Guidelines on the Legal Disclosure Format for Corporate Environmental Information	MEE
2022	Implementation Plan for the second compliance period of national carbon emission trading allowance setting and allocation	MEE
2022	Provisional Regulation on the Administration of Carbon Emission Trading	MEE

Table

	C-ETS	EU-ETS
Policy objectives	Using cap and trade mechanism and market-based approach to facilitate the adjustment of energy structure, and achieve national emission reduction goals	Using cap and trade mechanism and market-based approach to facilitate the adjustment of energy structure, and achieve EU emission reduction goal and sustainability transition
Coverage	Cover only the power sector, but plan to include more soon	Cover many sectors, including power, industrial, aviation, etc
Allowance Allocation	Combination of free allocation and auction, mainly free allocation	Combination of free allocation and auction, mainly auction
Compliance Mechanism	Entity submit the allowance of the previous year in the prescribed time	Entity submit the allowance of the previous year in the prescribed time
Market Type	Single market	Cross-national market
Price Mechanism	Government-guided prices and market-based pricing	Determined by the market
Market stability	Plan to establish market stability reserve mechanism, currently is monitored by trading institutions	Established market stability reserve mechanism, also measures like price upper and lower limits, and circuit breakers system
Monitor, Report and Verification	Require entities to monitor and report carbon emissions and conduct third-party verification	Require entities to monitor and report carbon emissions and conduct third-party verification
Offset Mechanism	Allow domestic offset mechanism (China Certified Emission Reduction)	Allow domestic offset project and new international offset projects
Penalty	Low penalty (e.g.fines) by MEE	Penalty (e.g.fines) by member state
Supervision	Regulated by NDRC and MEE	Regulated by European Commission and financial and environmental department of each member state
Linkage	No linkage	Linkage with Swiss ETS
Legislation base	Built under national policies	Based on EU legal framework
Information Disclosure	Address information disclosure, demand entity to disclose emission data and trading information	Address information disclosure, demand entity to disclose emission data and trading information

Table

Name	Pilot Experience	Key Entity List Disclosure (until 2022/01)	Compliance Status Disclosure (until 2022/09)	Non-compliance List Disclosure (until 2022/09)
Anhui	–	None	98.6% (1/69)	Yes
Beijing^a	●	Full	–	–
Chongqing	●	Partial	89.3% (3/28)	Yes
Fujian	●	Full	95.0% (2/40)	Yes
Gansu	–	None	100% (19)	Yes
Guangdong^a	●	Full	100% (8)	–
Guangxi	–	Partial	93.0% (3/43)	Yes
Guizhou	–	Partial	96.9% (1/32)	Yes
Hainan	–	Partial	100% (7)	–
Hebei	–	None	92.0% (7/87)	Yes
Henan	–	Partial	89.6%(12/115)	Yes
Heilongjiang	–	None	73.5% (13/49)	Yes
Hubei	●	Full	100% (46)	–
Hunan	–	None	93.5% (2/31)	Yes
Jilin	–	Partial	93.3% (3/45)	Yes
Jiangsu	–	Partial	96.7% (7/209)	Yes
Jiangxi	–	Partial	97.8% (1/45)	Yes
Liaoning	–	Partial	86.4% (9/66)	Yes
Inner Mongolia	–	None	90.1% (17/172)	Yes
Ningxia	–	None	79.3% (6/29)	Yes
Qinghai	–	Partial	91.7% (1/12)	Yes
Shandong	–	Full	95.6%(14/320)	Yes
Shanxi	–	None	92.4% (8/105)	Yes
Shaanxi	–	Partial	93.7% (4/63)	Yes
Shanghai	●	Full	100% (23)	–
Sichuan	–	Full	95.8% (2/48)	Yes
Tianjin^a	●	Full	–	–
Tibet^a	–	None	–	–
Xinjiang	–	None	85.7% (11/77)	Yes
Xinjiang (Bingtuan)	–	None	–	–
Yunnan	–	None	94.7% (1/19)	Yes
Zhejiang	–	None	97.9% (3/144)	Yes
Macao	–	–	–
Hong Kong	–	–	–
Taiwan	–	–	–

^a For the first compliance cycle, Tibet did not have any key emission units that met the inclusion criteria. Beijing, Tianjin, and Guangdong (excluding Shenzhen) participated in the allocation and settlement of allowances for 2019 and 2020 within their respective local pilot carbon markets and thus did not participate in C-ETS.