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China Opens Public Comment on New Energy and Carbon Measurement Rules

China's State Administration for Market Regulation is seeking public feedback on draft regulations for energy and carbon measurement supervision. Foreign founders should note the compliance implications for companies operating in China.

China Seeks Public Input on Energy and Carbon Measurement Supervision

The State Administration for Market Regulation (SAMR) has released a draft of the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (hereinafter the “Draft Measures”) for public comment. The draft is part of China’s broader effort to strengthen energy and carbon measurement oversight, promote energy conservation and carbon reduction, and support sustainable development. Measurement is described as playing a fundamental role in achieving China’s carbon peak and carbon neutrality goals.

For foreign founders establishing or operating a company in China, this development is relevant because the final rules may impose new measurement-related obligations on businesses in energy-intensive sectors or those subject to carbon reporting requirements. While the draft text itself is not yet law, now is the time to monitor the process and consider how future compliance might affect your operations.

What the Draft Covers

According to the notice, SAMR has organized the drafting of the Measures to enhance supervision over energy and carbon measurement. The draft is intended to provide a regulatory framework for measurement activities that underpin energy efficiency and carbon accounting. The full text of the draft and an accompanying drafting explanation are available as attachments to the notice.

The notice does not specify which industries or entities would be directly affected, nor does it detail the exact obligations. However, the focus on energy and carbon measurement suggests that companies involved in energy production, manufacturing, or other emission-intensive activities may need to pay particular attention to how they measure and report energy use and carbon emissions.

How to Submit Comments

SAMR is inviting feedback from the public, including foreign-invested enterprises and their advisors. The comment period is open until November 23, 2026. Stakeholders can submit their views through the following channels:

• Online: Visit the SAMR website (www.samr.gov.cn) and navigate to the “Collection and Survey” section under the “Interaction” column on the homepage.
• Email: Send comments to [email protected]. Please use the subject line “Feedback on the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment)”.
• Post: Mail comments to the Measurement Department, SAMR, No. 9 Madian East Road, Haidian District, Beijing, Postal Code: 100088. Mark the envelope with “Feedback on the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment)”.

The notice was published on October 23, 2026, by SAMR.

Practical Implications for Foreign Founders

If you are registering a company in China or already operating one, here are a few practical points to keep in mind:

• Stay informed: Even if your business is not directly targeted by the draft, the final rules could have ripple effects across supply chains. Monitoring the consultation process helps you anticipate changes.
• Assess your measurement practices: If your operations involve significant energy use or carbon emissions, review how you currently measure and report this data. The draft may lead to more standardized requirements.
• Participate in the consultation: Foreign-invested enterprises can submit comments through the channels above. This is an opportunity to voice concerns or seek clarifications that could affect your compliance burden.
• Seek local advice: China’s regulatory environment is complex and evolving. Engaging with local professionals can help you interpret the draft and prepare for potential changes.

The draft measures are not yet in force, and the final text may change after the comment period. However, the direction is clear: China is tightening its framework for energy and carbon measurement, and businesses should be ready to adapt.

Next Steps

Foreign founders who wish to comment on the draft should do so before the November 23, 2026 deadline. Even if you choose not to comment, reviewing the draft and its explanatory note can provide valuable insight into China’s regulatory priorities. For companies in relevant sectors, it may be prudent to conduct a preliminary gap analysis of your measurement and reporting systems.

ChinaMNC will continue to monitor the development of these rules and provide updates as more information becomes available.

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

Call to action: Foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535 for help registering and operating a company in China.