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China Opens Public Comment on Draft Energy and Carbon Measurement Supervision Rules

China's market regulator is seeking public feedback on draft rules for energy and carbon measurement, with comments due by November 23, 2026. Foreign founders should note the potential compliance implications for energy use and emissions reporting.

China Seeks Public Input on Draft Energy and Carbon Measurement Rules

China's State Administration for Market Regulation (SAMR) has released a draft of the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment) and is inviting public feedback. The deadline for comments is November 23, 2026. For foreign founders operating or planning to establish a company in China, this is a timely opportunity to understand and potentially influence the regulatory framework that will govern energy and carbon measurement.

Why This Matters for Foreign Businesses

Energy and carbon measurement are foundational to China's broader goals of energy conservation, emissions reduction, and sustainable development. The draft measures aim to strengthen supervision in these areas and to give measurement a basic safeguarding role in achieving peak carbon and carbon neutrality targets. While the full text of the draft is not reproduced here, the fact that SAMR is drafting such measures signals that companies with significant energy use or emissions may face new requirements for measurement, reporting, and compliance. Foreign founders in manufacturing, energy-intensive industries, or any sector subject to carbon reporting should monitor this development closely.

How to Submit Comments

SAMR has provided three official channels for submitting feedback on the draft. All comments must be received by November 23, 2026.

• Online: Visit the SAMR website at www.samr.gov.cn and navigate to the "Interactive" section, then "Solicitation Surveys" to submit your comments electronically.
• Email: Send your feedback to [email protected]. The subject line of your email must clearly state "Feedback on the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment)".
• Postal Mail: Send a letter to the Measurement Department of SAMR, No. 9 Madian East Road, Haidian District, Beijing, Postal Code: 100088. The envelope should be marked "Feedback on the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment)".

These channels are open to the public, including foreign-invested enterprises. If you wish to provide input, ensure your submission follows the specified format and arrives before the deadline.

Context of the Draft Measures

The draft measures are part of China's efforts to enhance the supervision of energy and carbon measurement. According to the notice, the goal is to promote energy saving, carbon reduction, and sustainable development, and to leverage measurement as a fundamental tool for achieving the country's carbon peak and carbon neutrality objectives. The notice does not provide details on the specific obligations that would be imposed on companies, as the full draft and an explanatory document are attached separately. Foreign founders should review the attached draft and explanatory notes on the SAMR website for a complete understanding.

Practical Steps for Foreign Founders

Given the potential impact on operations, foreign founders should consider the following actions:

• Review the draft: Access the full draft and its explanatory notes from the SAMR website to assess whether your business activities fall within the scope of the proposed measures.
• Assess compliance readiness: If your company uses significant energy or generates emissions, evaluate your current measurement and reporting systems to identify gaps that may need to be addressed if the measures are finalized.
• Engage in the comment process: If you have concerns or suggestions, submit them through the official channels before the deadline. This is a chance to contribute to the rulemaking process and to flag any practical challenges for foreign-invested enterprises.
• Monitor developments: The draft is not yet final. Keep track of any revisions or announcements from SAMR regarding the final version and its implementation timeline.

What Happens Next

After the comment period closes on November 23, 2026, SAMR will review the feedback and may revise the draft before finalizing the measures. The timeline for finalization and implementation has not been announced in the notice. Foreign founders should stay informed through official channels and consider seeking local legal or compliance advice to prepare for potential changes.

Conclusion

The public comment period on China's draft energy and carbon measurement rules is a key opportunity for foreign businesses to understand and engage with upcoming regulatory requirements. By participating or preparing early, founders can better position their companies for compliance and sustainable growth in China. For assistance with company registration, regulatory compliance, or understanding the implications of this draft, foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535.

This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.