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China SAMR Seeks Public Comment on Draft Measures for Energy and Carbon Measurement Supervision

China's State Administration for Market Regulation (SAMR) has released a draft regulation on energy and carbon measurement supervision for public comment until November 23, 2026. Foreign founders operating in China should note the potential compliance implications for energy use and carbon reporting.

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

The State Administration for Market Regulation (SAMR) has drafted the Supervision and Administration Measures for Energy Measurement and Carbon Measurement (Draft for Comment) and is inviting public feedback. The draft aims to strengthen supervision over energy and carbon measurement, support energy conservation, carbon reduction, and sustainable development, and give measurement a foundational role in achieving China's carbon peak and carbon neutrality goals. The notice was published on October 23, 2026, with a comment deadline of November 23, 2026.

For foreign founders establishing or operating a company in China, this draft signals potential new compliance obligations related to energy measurement and carbon measurement. While the draft is not yet in force, understanding its scope can help you prepare for future requirements. This article summarizes the key points from the official notice and explains how to submit comments.

Key Points from the Draft Notice

Purpose and Scope

The draft measures are intended to enhance the supervision and administration of energy measurement and carbon measurement. They form part of China's broader efforts to promote energy saving, carbon reduction, and sustainable development. Measurement is described as a basic safeguard for achieving the country's carbon peak and carbon neutrality targets. The draft, if finalized, would likely apply to entities involved in energy use and carbon emissions, though the specific obligations are detailed in the draft text itself (available as an attachment to the notice).

How to Submit Comments

SAMR has provided three channels for public feedback:

The deadline for submitting comments is November 23, 2026. All feedback must be received by this date.

Attachments and Further Details

The notice includes two attachments: (1) the draft measures themselves, and (2) an explanatory note on the drafting of the measures. These documents provide the full text and background rationale. Foreign founders are encouraged to review them to understand the specific requirements that may apply to their operations.

What This Means for Foreign Founders in China

Although the draft is still open for comment, it indicates that China is moving toward more rigorous oversight of energy and carbon measurement. Companies that consume significant energy or emit carbon may face new obligations related to measurement equipment, data reporting, or verification. Foreign-invested enterprises should monitor the final version of these measures and assess whether their current practices align with upcoming requirements.

To stay compliant, consider the following practical steps:

It is important to note that the draft measures are not yet law. The comment period allows stakeholders to influence the final text. Foreign founders should treat this as an early warning of potential compliance changes and plan accordingly.

Conclusion

The SAMR's public consultation on the draft energy and carbon measurement measures reflects China's ongoing commitment to environmental goals and regulatory transparency. Foreign founders operating in China should stay informed about this development, as it may lead to new compliance obligations. By understanding the draft and participating in the comment process, businesses can better prepare for the future regulatory landscape.

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

For assistance with company registration and ongoing compliance in China, foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535.

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General information only, not legal or tax advice.