On October 30, 2026, China’s State Administration for Market Regulation (SAMR) announced the joint issuance of the Action Plan for Developing a Standards System for the Carbon Footprints of Key Products (2026–2028), together with the National Development and Reform Commission, the Ministry of Ecology and Environment, the Ministry of Industry and Information Technology, and the National Energy Administration. Guided by urgency, coordinated implementation and industry collaboration, the Action Plan focuses on five priority areas: energy, raw materials, consumer goods, machinery and equipment, and transport equipment. It aims to introduce more than 100 national standards for product carbon footprints and develop selected national standards in parallel with international standards, supporting China’s product carbon footprint management system and the low-carbon transition of key industries. Official announcement

For foundational standards, the Action Plan calls for accelerated development of rules covering carbon footprint data monitoring, measurement, management and traceability, alongside emission factor calculation, data quality management and information disclosure. It also addresses database development, data security, exchange and evaluation. Further work will explore product carbon footprint classification and assessment standards, as well as rules for incorporating renewable energy green electricity certificates into product carbon footprint accounting.

The energy sector provisions cover coal, electricity, gaseous fuels, petroleum and liquid fuels. Electricity-related standards will address major generation technologies, including coal, natural gas, hydropower, nuclear, wind, solar photovoltaic, concentrated solar power and biomass, as well as electricity transmission, distribution and energy storage. For raw materials, priorities include steel, chemicals, non-ferrous metals and building materials, particularly products with high emissions, widespread applications or explicit downstream demand for carbon footprint data. Certain steel industry by-products are also included.

Consumer goods priorities encompass light industry, textiles, and electrical and electronic products. Examples include household appliances, furniture, paper products, textile materials and finished goods, consumer electronics, office electronics, and communications products and facilities. Machinery and equipment standards will focus on complete machines and components with substantial lifecycle emissions and applications across multiple downstream industries. Transport equipment priorities include electric vehicles, petrol-, diesel- and gas-powered vehicles, key automotive components, seagoing vessels, electric inland waterway vessels and associated marine equipment.

To improve consistency across product categories, the Action Plan requires closer coordination with the National Technical Committee on Carbon Emission Management Standardization (SAC/TC 548). Standards development must follow GB/T 24067, aligning accounting boundaries, methodologies, data and emission factor values across raw materials, intermediate products and finished goods. Industry research and trial carbon footprint calculations must accompany standards development to verify feasibility, with subsequent revisions informed by implementation results.

Implementation measures include training, national carbon emission management standardization pilots, and the dissemination of successful practices. The Action Plan also encourages participation in international standards development, submission of international standard proposals, and greater alignment and mutual recognition. It establishes priorities for the next three years; detailed accounting and application requirements will depend on the standards and supporting measures subsequently issued.

The initiative intersects with EU green regulation, although the instruments serve different purposes. The EU’s Ecodesign for Sustainable Products Regulation (ESPR) establishes a framework for product sustainability requirements. Subsequent delegated acts may introduce requirements concerning carbon footprints, durability, repairability and Digital Product Passports. Specific obligations depend on the product category and applicable implementing rules; there is no uniform carbon footprint disclosure obligation already applying to all products. China’s Action Plan, meanwhile, focuses on developing accounting standards and the underlying data infrastructure. ESPR legal text

The EU Emissions Trading System (EU ETS) places a carbon price on emissions from regulated installations and operators through emissions caps, monitoring and verification, and allowance surrender obligations. The Carbon Border Adjustment Mechanism (CBAM), which entered its definitive phase on January 1, 2026, links the carbon costs of embedded emissions in specified imported goods to the EU ETS. Businesses therefore need to distinguish the accounting subjects and boundaries used for product carbon footprints, installation emissions and CBAM embedded emissions. EU ETS, CBAM

For businesses, the new Chinese standards system could improve the completeness and traceability of domestic supply chain carbon data, providing a stronger foundation for export compliance. However, whether reports prepared under Chinese standards can support EU declarations will depend on compatibility with the relevant accounting boundaries, emission factors and verification requirements. Using green electricity certificates does not automatically qualify for a CBAM carbon price deduction, which concerns an eligible carbon price effectively paid and supported by appropriate evidence. European Commission explanation

BESTAO considers that businesses should begin establishing traceable carbon data systems that allow calculations to be adapted to different regulatory methodologies. They should also monitor Chinese standards development, ESPR product-specific rules and CBAM requirements separately. The Action Plan provides a programme for standards development; specific product obligations must be assessed against the standards and applicable rules subsequently adopted.