The energy conservation review and carbon emission assessment for fixed-asset investment projects are crucial systems aimed at enhancing the energy efficiency and reducing carbon emissions of newly launched projects from the very outset. They constitute an important component of China’s comprehensive system for energy conservation and carbon reduction. China established and implemented the energy conservation review system in 2010, playing a significant role in improving the energy efficiency of new projects and promoting the transformation and upgrading of industrial structures. In accordance with the decisions and deployments of the Party Central Committee and the State Council, the National Development and Reform Commission recently revised and issued the “Measures for Energy Conservation Review and Carbon Emission Assessment of Fixed-Asset Investment Projects” (Order No. 31 of 2025 issued by the National Development and Reform Commission, hereinafter referred to as the “Measures”). This revision is an important step to adapt to new situations and requirements and further improve the energy conservation and carbon reduction institutional framework, providing vital institutional support for promoting green, low-carbon, and high-quality development.

　　 First, strengthen source control and firmly curb the disorderly expansion of “high-energy consumption and high-emission” projects.

　　Energy-related activities are the primary source of carbon emissions in China. To achieve the goals of peaking carbon emissions and achieving carbon neutrality on schedule, energy conservation is a crucial lever and key support. The energy conservation review system is a proactive measure aimed at enhancing energy efficiency and curbing the reckless launch of “high-energy consumption and high-emission” projects. However, in practical implementation, some localities have experienced issues such as the gradual decentralization of review authority, leading to difficulties in effectively taking over and managing these responsibilities. Particularly since the 14th Five-Year Plan period, some regions have shown a strong impulse to launch “high-energy consumption and high-emission” projects blindly, driving the nation’s total energy consumption to surge far beyond expectations and significantly worsening the carbon emission situation. This has also triggered problems such as disorderly capacity expansion and “involutionary competition” in certain industries, urgently calling for strong and effective measures to address these challenges.

　　The revised Measures adhere to a problem-oriented approach and focus on further strengthening the role of institutional gatekeeping at the source. Specifically, the National Development and Reform Commission is explicitly instructed to establish a dynamic adjustment mechanism for the authority to review energy conservation in fixed-asset investment projects. Under this mechanism, projects in key sectors with annual comprehensive energy consumption of 500,000 tons of standard coal or more (or annual coal consumption of 500,000 tons or more) will be brought under the purview of higher-level energy conservation review authorities. Moreover, the Measures require that project energy consumption and carbon emission data—as well as details such as industry capacity scale and market performance—be thoroughly analyzed in the project’s energy conservation reports and other relevant materials. It is also explicitly prohibited to delegate the authority for energy conservation review of high-energy-consumption and high-emission projects to county-level energy conservation review agencies. Through these comprehensive provisions, the management authority and requirements for energy conservation reviews will be further optimized, enabling energy conservation to play an even stronger supporting role in reducing carbon emissions. Additionally, these measures will provide robust institutional safeguards for effectively and efficiently controlling “two-high” projects.

　　 II. Optimize resource allocation to better leverage the regulatory and guiding role of energy conservation and carbon reduction.

　　The energy conservation review system is an important regulatory tool for adjusting and optimizing the allocation of energy resources and enhancing the level of green, low-carbon, and high-quality development. The Measures uphold the guiding and regulatory role of the energy conservation review system. On the one hand, they require energy conservation review authorities to conduct thorough analysis and demonstration of the impacts of project implementation on the region’s carbon peak trajectory and on the achievement of energy-saving and carbon-reduction targets, and to firmly halt projects that fail to meet the relevant requirements in accordance with energy-saving and carbon-reduction management standards. On the other hand, the Measures strictly align with mandatory energy consumption limit standards, energy efficiency standards, and benchmark energy efficiency levels in key sectors, and urge and guide project developers to optimize their technical approaches and equipment selection plans before construction begins, ensuring that project energy efficiency and carbon performance indicators reach advanced levels.

　　By further clarifying relevant regulations, we can better leverage the regulatory role of the energy conservation review system. This will effectively guide the concentration and allocation of energy resources toward industries with high energy efficiency and high output benefits from energy resources, encouraging fixed-asset investment projects to actively adopt measures aimed at improving energy-use efficiency, increasing consumption of non-fossil energy sources, and reducing greenhouse gas and pollutant emissions. As a result, we will strongly promote the upgrading of industrial structures, the optimization of energy structures, and the continuous improvement of ecological environment quality, thereby providing solid support for achieving our energy conservation and carbon reduction goals.

　　 III. Strengthen institutional innovation and fully implement the transition from dual control of energy consumption to dual control of carbon emissions.

　　The Measures integrate carbon emission assessment requirements into the energy conservation review system and promote them in a coordinated manner, marking a significant reform of the energy conservation review system. Going forward, while continuing to rigorously scrutinize the energy consumption of projects, the energy conservation review process will further strengthen the management of carbon emission access for projects, placing particular emphasis on controlling and reducing the consumption of fossil fuels such as coal. This will effectively lay a solid foundation for the dual-control efforts on carbon emissions during the 15th Five-Year Plan period.

　　The Measures integrate carbon emission assessment requirements into all stages of project development, including the preparation of energy conservation reports, energy conservation reviews and examinations, acceptance of energy conservation reviews, and ongoing supervision and management. Specifically, all projects subject to energy conservation review by the National Development and Reform Commission must undergo carbon emission assessments. Moreover, local authorities are required to conduct parallel carbon emission assessments for projects with substantial carbon emissions that could adversely affect their region’s carbon peak trajectory and the achievement of targets for reducing carbon intensity. In addition, to effectively curb additional carbon emissions arising from fossil fuel consumption—especially coal consumption—the Measures include fixed-asset investment projects with annual coal consumption exceeding 1,000 tons within the scope of energy conservation review, thereby strengthening controls and reduction targets for coal consumption and providing robust support for achieving carbon emission control goals.

　　 4. Strictly enforce legal responsibilities and strengthen closed-loop management across the entire project review process.

　　Clear legal responsibilities and effective regulatory measures are crucial to ensuring the proper implementation of the energy-saving review system. Since the introduction of the energy-saving review system, some localities still see instances of projects commencing construction without prior approval, putting into operation before passing the energy-saving review and acceptance inspection, or engaging in construction that does not comply with approved plans. Therefore, it is necessary to continuously deepen the regulatory provisions for energy-saving reviews, strengthen the institutional framework, enforce legal responsibilities, and refine the closed-loop management mechanism for projects.

　　The Measures further refine the supervision and management mechanisms as well as the requirements for legal responsibilities. For instance, if a project is commenced or put into operation without undergoing the required energy-saving review or after failing such a review, the authorities will order the project to halt construction or production and usage, and set a deadline for rectification. For the first time, it is clearly stipulated that once a project has been certified as having completed rectification, only a relevant certificate may be issued—not another energy-saving review opinion—thus eliminating the issue of “retroactively obtaining energy-saving review procedures.” Moreover, the Measures specify clear provisions regarding changes to energy-saving reviews, deadlines for rectification, and penalties applicable to projects experiencing significant alterations before commencement of construction, during construction, or after being put into production and use. In addition, the Measures detail the supervisory and management responsibilities of relevant departments in areas such as project approval and management, acceptance management, routine supervision, and credit supervision, thereby promoting the establishment of a closed-loop management mechanism covering the entire chain and ensuring that the energy-saving review system is better implemented and yields tangible results.

　　The Measures fully implement the decisions and deployments of the Party Central Committee and the State Council, and in light of the new situation and new tasks in energy conservation and carbon reduction, systematically improve and comprehensively innovate the energy conservation review system. All relevant parties should earnestly study and understand the requirements of the Measures, rigorously ensure their thorough implementation, and effectively leverage the important roles of the energy conservation review and carbon emission assessment systems. This will provide strong support for advancing the achievement of energy conservation and carbon reduction targets and for carrying out energy conservation and carbon reduction efforts at a higher level and with greater quality. (Authors: Liu Qiong, Director of the National Energy Conservation Center; Yan Jingguang, Director of the Review Division of the National Energy Conservation Center)