Strengthening the energy-saving review and carbon-emission assessment for fixed-asset investment projects is an important measure to effectively and powerfully curb the reckless launch of “high-energy consumption and high-carbon emission” projects and promote green, low-carbon, and high-quality development. Recently, the National Development and Reform Commission issued the "Measures for Energy-Saving Review and Carbon-Emission Assessment of Fixed-Asset Investment Projects" (Order No. 31 of 2025 of the National Development and Reform Commission, hereinafter referred to as the "Measures"). These measures represent a crucial institutional arrangement for adapting to new situations, new tasks, and new requirements and for solidifying efforts in energy conservation and carbon reduction. They are of great significance for establishing a new mechanism that fully transitions from dual control of energy consumption to dual control of carbon emissions and for actively and steadily advancing the goals of peaking carbon emissions and achieving carbon neutrality.

　　 I. Energy-saving review work enters a new stage.

　　Newly launched fixed-asset investment projects, as one of the primary drivers behind the growth in energy consumption across society, represent an important “battlefield” for promoting energy conservation and carbon reduction efforts. Since the implementation of the energy-saving review system in 2010, this system has played a significant role in enhancing the energy efficiency of new projects, reducing unreasonable energy consumption and carbon emissions at the source, fostering the optimization and upgrading of industrial structures, and promoting advanced energy-saving and carbon-reduction technologies and equipment.

　　As the world’s largest developing country, China’s energy consumption and carbon emissions are expected to continue growing in the coming period. Achieving the carbon peak target within a tight time frame and under heavy tasks will require strenuous efforts. This year marks a critical juncture—the concluding year of the 14th Five-Year Plan and the initial stage for planning the 15th Five-Year Plan. Faced with new situations, new tasks, and new requirements, the Measures integrate project carbon emission assessments into the energy conservation review system, elevate the authority for energy conservation reviews of major projects in key sectors, refine the regulatory requirements for energy conservation reviews during and after the review process, further improve relevant regulations, address institutional shortcomings, and promptly clarify how energy conservation reviews should be conducted under the new circumstances. This is of great significance for strengthening the source-level control of energy conservation reviews and carbon emission assessments, and for propelling energy conservation and carbon reduction efforts to a new level.

　　 II. Refine and clarify the requirements for carbon emission assessment work.

　　The “Measures for Energy Conservation Review of Fixed-Asset Investment Projects,” revised and released in March 2023 (Order No. 2 of 2023 issued by the National Development and Reform Commission), requires that projects equipped with conditions for carbon emission statistics and accounting shall include in their energy conservation reports information on carbon emissions as well as the impact of such emissions on the region’s ability to achieve its carbon reduction targets. Building on this, the Measures further strengthen the guidance for managing project energy consumption and carbon emissions, in line with the requirements set forth in the “Work Plan for Accelerating the Establishment of a Dual-Control System for Carbon Emissions” (Guobanfa [2024] No. 39), which stipulates that “requirements related to carbon emission assessment shall be incorporated into the energy conservation review of fixed-asset investment projects, and comprehensive assessments of project energy use and carbon emissions shall be conducted.” This ensures effective alignment between the energy conservation review system and the dual-control system for carbon emissions.

　　The Measures require that energy conservation reports include indicators such as total carbon emissions, the structure of carbon emissions, carbon emissions per unit of product, and carbon emissions per unit of value added (output value), as well as comparisons of these indicators with relevant standards and industry-leading levels. At the same time, the Measures further clarify the specific requirements for carbon emission assessments. On the one hand, they emphasize as key review and assessment areas the impact of project commencement on the overall carbon emission situation and on achieving carbon emission intensity reduction targets, as well as whether the carbon emissions per unit of product and output value comply with national and industry standards, and whether the carbon emission data compilation and analysis are accurate and well-founded. On the other hand, the Measures specify that projects subject to energy conservation reviews conducted by the National Development and Reform Commission must simultaneously carry out carbon emission assessments. Moreover, local energy conservation review authorities are required to conduct carbon emission assessments—taking into account local conditions—for projects with high carbon emissions that could adversely affect the achievement of peak carbon goals and the reduction of carbon emission intensity. These provisions provide concrete guidance for conducting carbon emission assessments for projects, thereby helping to establish effective carbon emission control mechanisms at the source and at the entry point.

　　 III. Optimize the management authority for energy-saving reviews

　　In recent years, based on local practices, the energy conservation review system has encountered several challenges in its actual implementation, including the layered delegation of review authority and inadequate review quality. The Measures adopt a problem-oriented approach, strengthen institutional innovation, further optimize the management authority for energy conservation reviews, and refine the requirements for tiered and categorized management. At the national level, a dynamic adjustment mechanism for energy conservation review authority has been established. The National Development and Reform Commission will comprehensively consider factors such as the situation of energy conservation and carbon reduction and the development status of various industries, and implement energy conservation reviews for 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). At the local level, provincial energy conservation review authorities are responsible for conducting energy conservation reviews on projects with annual comprehensive energy consumption of 10,000 tons of standard coal or more (or annual coal consumption of 10,000 tons or more). It is required that the energy conservation review authority at or below the provincial level be promptly adjusted or suspended if progress on relevant energy conservation and carbon reduction indicators lags behind, professional capacity is insufficient, or review quality is low. Furthermore, the delegation of energy conservation review authority for high-energy-consumption and high-emission projects to county-level energy conservation review authorities is strictly prohibited. These provisions will help establish a coordinated energy conservation review framework characterized by top-down linkage, clear division of responsibilities, and efficient collaboration, thereby providing crucial support for effectively enhancing the efficiency of energy conservation review work.

　　 IV. Strengthen mid- and post-event supervision of energy-saving reviews for projects.

　　The energy-saving review opinions serve as an important basis for the commencement of construction, completion acceptance, and operational management of a project. To urge and guide project developers to strictly implement the energy-saving review opinions and strengthen ex-ante, in-process, and post-event supervision of energy-saving reviews, the Measures require that projects undergoing significant changes before or during construction must undergo amendments to their energy-saving review. The Measures also specify in detail the time nodes for energy-saving review and acceptance, the content of acceptance inspections, and the authorities responsible for acceptance management. Moreover, they explicitly stipulate that the implementation of local energy-saving reviews will be taken into account as a key component in energy-saving inspections and performance evaluations related to energy conservation and carbon reduction. Building on this foundation, the Measures clearly define specific penalties for illegal and non-compliant behaviors such as commencing construction without prior approval or failing to implement the energy-saving review opinions. These measures further enhance the closed-loop management of the entire energy-saving review process, helping to bridge the "last mile" in the effective implementation of the system and ensuring that energy-saving review opinions are truly put into practice.

　　Overall, the institutional design of the Measures has been continuously optimized, improved, and innovatively developed. It represents a continuation and deepening of previous efforts and is better equipped to meet the new situations and requirements facing energy conservation and carbon reduction work. We are confident that these Measures will effectively guide all relevant parties in earnestly carrying out energy conservation reviews and carbon emission assessments under the new circumstances, providing strong support for establishing a new mechanism that fully transitions from dual control of energy consumption to dual control of carbon emissions, and for advancing energy conservation and carbon reduction efforts at a higher level and with greater quality. (Authors: Zhang Yingjian, Director of the Resources and Environment Division, China International Engineering Consulting Corporation; Lun Liyong, Director of the Energy Conservation Division, Resources and Environment Division, China International Engineering Consulting Corporation)