欧盟碳边境调节机制（CBAM）的豁免政策，是缓解企业合规压力的重要保障，尤其惠及中小出口企业。厘清豁免范围、明确免申报产品类型及适用条 件，能帮助企业精准规避合规风险、降低申报成本，本文结合最新政策细则，深度剖析可免除CBAM申报的产品及核心要求。 欧盟碳边境调节机制（CBAM）豁免政策并非无差别适用，核心遵循"微量豁免、特定情形豁免、等效机制豁免"三大原则，仅针对符合条件的产品和企业 开放，且需提前完成相关备案或证明材料提交，未满足条件将无法享受豁免权益。 豁免政策的核心初衷，是在保障碳管控目标的前提下，减轻中小企业和特殊贸易场景的合规负担，同时兼顾人道主义、产业供给等特殊需求。需明确的 是，豁免仅免除申报义务，若产品后续超出豁免范围或条件，仍需补充履行CBAM申报流程，避免违规风险。 结合2025年以来CBAM修订方案及简化政策，可免除申报的产品主要分为四大类，每类产品均有明确的适用边界，企业需精准匹配自身情况，避免误判豁 免资格。 第一类是微量进口产品，即年度进口CBAM管控品类总量不超过50吨的相关产品，可免于履行申报义务。需注意，氢能和电力不享受该微量豁免，无论进 口数量多少，均需按要求完成申报，这 ...

Group 1: Climate Risks - Climate-related risks are categorized into transition risks and physical risks, impacting financial, compliance, and reputational aspects for companies[3] - Transition risks arise from changes in policies, laws, technologies, and consumer preferences aimed at addressing climate change[3] - Physical risks include acute events like extreme weather and long-term changes in climate patterns, affecting operational stability[3] Group 2: Climate Opportunities - Efforts to mitigate and adapt to climate change can create opportunities for businesses, including resource efficiency and market resilience[3] - Enhanced disclosure of climate-related risks and opportunities will provide necessary metrics for investors and stakeholders to analyze potential financial impacts[3] Group 3: Regulatory Framework - The Ministry of Finance and the Ministry of Ecology and Environment released a draft for the "Corporate Sustainable Disclosure Standards No. 1 - Climate" on April 30, 2025, establishing systematic disclosure requirements[3] - The TCFD framework emphasizes the financial impacts of climate-related issues through revenue, expenditure, assets, liabilities, and capital[3] Group 4: Global Emission Trends - From 1850 to 2019, the cumulative CO2 emissions reached approximately 2400±240 GtCO2, with over 58% occurring before 1990[12] - The remaining carbon budget to limit global warming to 1.5°C is estimated at 500 GtCO2, with a 50% probability of success[23] Group 5: International Agreements - The Paris Agreement aims to limit global temperature rise to well below 2°C, with 194 parties committed to its goals[28] - The TCFD was established by the Financial Stability Board in 2015 to provide guidance on climate-related financial disclosures, enhancing market stability[33]

Group 1 - The Ministry of Finance and the Ministry of Ecology and Environment have jointly released the "Corporate Sustainable Disclosure Guidelines No. 1 - Climate (Trial) (Draft for Comments)," marking significant progress in the establishment of sustainable information disclosure standards in China [1][2] - The draft aims to standardize the disclosure of climate-related risks, opportunities, and impacts by companies, providing essential information to investors, creditors, and other stakeholders for economic decision-making [1][2] - The climate guidelines are the first specific guidelines following the release of the basic guidelines, indicating a rapid advancement in the overall work of sustainable disclosure standards [2][3] Group 2 - The climate guidelines consist of six chapters and 47 specific provisions, aligning with the four core elements of sustainable information outlined in the basic guidelines [3][4] - Companies are required to disclose both qualitative and quantitative information regarding the financial impacts of climate-related risks and opportunities, including current and expected future effects [3][4] - The draft allows for certain exemptions in information disclosure, such as national secrets or commercially sensitive information, and provides flexibility in the level of detail required [4] Group 3 - The draft aligns with international standards, particularly the ISSB's climate-related disclosure standards (S2), while also considering China's unique circumstances [5][6] - The overall approach of the Ministry of Finance is to create a unified national sustainable disclosure standard that reflects international best practices while being tailored to China's context [5][6] - Companies, especially those listed in Hong Kong, are encouraged to prepare for climate-related disclosures in line with the new guidelines, as they will be required to comply with similar standards starting in the 2025 fiscal year [6][7] Group 4 - Specific industries, including finance, electricity, steel, coal, oil, fertilizer, aluminum, hydrogen, cement, and automotive, are urged to pay particular attention to the climate guidelines [7] - The Ministry of Finance is working on developing application guidelines for these industries, which will be released after the climate guidelines are finalized [7]

Group 1 - The Ministry of Finance and the Ministry of Ecology and Environment jointly released the "Corporate Sustainable Disclosure Guidelines No. 1 - Climate (Trial) (Draft for Comments)" on April 30, with a feedback deadline of May 31, 2025 [1][2] - The guidelines will include application guidelines for nine specific industries, including electricity, steel, coal, oil, fertilizer, aluminum, hydrogen, cement, and automobiles, to provide direction for the application of basic and climate guidelines [1][2] - The overall goal is to establish a unified sustainable disclosure guideline system in China by 2030, with basic and climate guidelines expected to be released by 2027 [2][3] Group 2 - The "Climate Guidelines Draft for Comments" consists of six chapters and 47 articles, maintaining high consistency with the "Basic Guidelines" in terms of objectives, disclosure targets, and technical requirements [3] - The draft aligns with international standards, particularly in disclosing climate-related risks and opportunities, and encourages companies to pursue low-carbon development [3] - Companies will have the option to voluntarily implement the guidelines before formal requirements are established [3]

Core Points - Climate information disclosure is becoming a key focus for corporate sustainability reporting, with the Ministry of Finance recently releasing the "Corporate Sustainability Disclosure Standards No. 1 - Climate (Trial) (Draft for Comments)" [1] - The draft emphasizes the need for companies to disclose greenhouse gas emissions categorized into Scope 1, 2, and 3, and to build a disclosure framework around four pillars: governance, strategy, risk and opportunity management, and metrics and targets [1][3] Group 1: Regulatory Framework - The draft is the first specific standard focusing on climate issues, following the basic sustainability disclosure standards released in November 2024 [1] - The Ministry of Finance plans to establish a unified sustainability disclosure standard system by 2030, with the climate standards expected to be finalized by 2027 [2] - The draft aligns closely with international standards, facilitating the integration of domestic practices with global frameworks [2] Group 2: Disclosure Requirements - Companies are required to disclose governance structures overseeing climate-related risks and opportunities, including how performance metrics are integrated into compensation policies [3] - The strategic dimension requires companies to disclose how climate-related risks and opportunities impact their strategies, financials, and resilience to climate change [3] - In terms of risk and opportunity management, companies must outline their processes for identifying, assessing, and monitoring climate-related risks and how these processes fit into their overall risk management systems [4] Group 3: Emission Accounting - The draft specifies that companies must disclose their total greenhouse gas emissions, with a focus on Scope 3 emissions, which are often the most challenging to quantify [4] - Financial institutions are particularly required to disclose information related to their financed emissions, which typically represent a significant portion of their total emissions [4] - Unlike the international GHG Protocol recommended by IFRS S2, the draft localizes the accounting standards, requiring companies to follow national carbon emission accounting standards [4] Group 4: Implementation Challenges - The climate information disclosure poses challenges for companies in measuring, analyzing, and planning their greenhouse gas emissions [6] - Companies are encouraged to adopt a gradual approach to implementing the standards, starting with qualitative disclosures if quantitative data is not available [7] - The draft suggests that companies with the capacity should actively explore pilot projects and develop feasible disclosure plans [7]

Group 1 - The Ministry of Finance and the Ministry of Ecology and Environment of China released the "Corporate Sustainability Disclosure Standards No. 1 - Climate (Trial) (Draft for Comments)" on April 30, 2023, which consists of six chapters and 47 articles covering governance, strategy, risk and opportunity management, indicators and targets, and appendices [1][2] - The governance chapter outlines disclosure objectives related to governance structures, management information, and third-party verification requirements [1] - The indicators and targets chapter specifies general and industry-specific climate-related indicators, climate-related goals, and the basis for greenhouse gas emissions accounting [1] Group 2 - The implementation of the climate standards will initially be voluntary for companies, considering their actual disclosure capabilities, before formal requirements are established [2] - Guidelines for nine specific industries, including electricity, steel, coal, oil, fertilizer, aluminum, hydrogen, cement, and automotive, are being developed to provide guidance for the application of the basic and climate standards [2] - The overall goal is to establish a unified sustainability disclosure standard system in China by 2030, with basic and climate standards expected to be released by 2027 [1][2]

Group 1 - The core viewpoint of the article is the introduction of the draft "Corporate Sustainability Disclosure Standards No. 1 - Climate (Trial) (Consultation Draft)" by the Ministry of Finance and the Ministry of Ecology and Environment, which aims to establish a unified climate disclosure standard in China [2][3] - The draft consists of six chapters and 47 articles, covering general principles, governance, strategy, risk and opportunity management, indicators and targets, and appendices [2] - Companies are required to identify climate-related risks and opportunities that may reasonably be expected to affect their development prospects and disclose the financial impacts of these risks and opportunities [2][3] Group 2 - Specific climate indicators that companies must disclose include greenhouse gas emissions, climate-related physical risks, transition risks, opportunities, capital allocation, internal carbon pricing, and compensation metrics [3] - For Scope 3 greenhouse gas emissions, companies must determine and disclose the categories included in their measurement based on their value chain [3] - The Ministry of Finance indicates that the draft aligns with the International Financial Reporting Sustainability Disclosure Standards No. 2 - Climate-related Disclosures (S2), promoting low-carbon and green development while considering the actual disclosure capabilities of Chinese companies [3][4] Group 3 - The Ministry of Finance is developing application guidelines for nine specific industries, including electricity, steel, coal, oil, fertilizers, aluminum, hydrogen, cement, and automobiles, to provide guidance for the implementation of the basic and climate standards [4]