二 〇 二 五 年 度 2025 年 9 月 19 日 全国碳市场：四季度能否如期反弹？ 唐惠珽 投资咨询从业资格号：Z0021216 tanghuiting@gtht.com 报告导读： ◼ 核心观点 近期，全国碳市场价格持续走弱，根本原因在于实际流通配额的增加已显著改变了买卖双方的交易心 态。展望四季度，市场能否出现预期中的反弹，关键取决于盈余企业自有余量的净卖出比例是维持在 40% 附近还是大幅高于这一水平。盈余企业自有余量的净卖出比例主要受到两方面因素影响：第一，企业经营 状况及决策者是否倾向通过出售配额弥补经营性亏损；第二，决策者对 2026 年及以后市场价格走势的预 期。为评估企业"通过出售配额弥补经营亏损"的倾向，本文对 A 股火电板块 31 家上市公司公开披露的 经营状况与碳交易状况进行了案头调研，核心结论如下： （1）超过 90%的样本企业 2024 年显性碳成本收入比低于 1%，约 40%的样本企业履约压力呈逐年增加 趋势。 （2）预计 24 家样本公司在前两个履约周期整体存在配额结余，其中 15 家公司的"扣非归母净利 率"与"碳净收益率"（逆序）两项指标走势在统计期内基本同步，表明部分 ...

Core Viewpoint - The recent policy shift in China's carbon market signifies a transition from intensity-based constraints to total volume control, impacting high-emission industries such as steel, cement, and electrolytic aluminum, which will face stricter regulations by 2027 [1][3][6] Group 1: Policy Changes and Market Development - The new guidelines aim to establish a national carbon trading market based on total volume control by 2030, moving away from the previous intensity-based approach [1][4] - As of July 2025, the national carbon market has recorded a cumulative trading volume of 680 million tons and a transaction value exceeding 46.7 billion yuan, with carbon prices stabilizing around 72 yuan per ton [1][3] - The policy emphasizes a gradual transition from free allocation of quotas to a mixed system of free and paid allocations, enhancing the scarcity and price signals of carbon quotas [4][5] Group 2: Industry-Specific Challenges - The steel, cement, and electrolytic aluminum industries collectively emit approximately 3 billion tons of CO2 equivalent annually, accounting for over 20% of national emissions, making them critical to the implementation of carbon constraints [6][9] - The steel industry is expected to increase the proportion of electric furnace steel to 15% by 2025 and promote low-carbon smelting technologies, aligning with the new carbon market price signals [7][11] - The cement industry faces unique challenges due to high process emissions, necessitating a combination of strategies such as reducing clinker ratios and utilizing alternative fuels to achieve deep emissions reductions [9][10] Group 3: Market Mechanisms and Financial Integration - The policy encourages the introduction of diverse trading products and financial instruments to enhance market liquidity and attract more capital into the carbon market [5][12] - The establishment of a monthly certification system for key parameters and the use of advanced technologies like big data and blockchain are aimed at improving the quality of carbon emissions data [13][14] - Companies are advised to integrate carbon asset management into their daily operations, utilizing quota trading and financial tools to optimize carbon asset transactions and cash flow [14]

Group 1: National Carbon Market Development - The central government has issued a significant policy document to advance the construction of the national carbon market, marking the first central document in this field, which outlines a timeline, roadmap, and tasks for long-term development [1][2] - The national carbon market has been operational for four years, achieving breakthroughs by expanding coverage to the steel, cement, and aluminum industries, and officially issuing the first batch of certified voluntary emission reductions (CCER) [1][7] - As of June 30, 2025, the cumulative trading volume of carbon allowances reached 669 million tons, with a total transaction value of 45.93 billion yuan, and the trading volume for 2024 alone reached a historical high of 18.044 billion yuan [2][7] Group 2: Carbon Footprint Management - The Ministry of Ecology and Environment is actively working on establishing a product carbon footprint management system, which includes developing accounting standards and guidelines for carbon footprint calculations [3][4] - The ministry has released national standards for greenhouse gas product carbon footprint quantification, aiming to facilitate the calculation of carbon footprints across various sectors [3][4] - Future efforts will focus on enhancing data infrastructure, conducting pilot projects, and promoting international cooperation in carbon footprint management [5][6] Group 3: Carbon Financial Market - The carbon financial market has seen increased activity, with at least 18 financial institutions obtaining carbon trading qualifications, and various carbon financial products being developed [12][13] - The national carbon market currently restricts participation to key emission units, while the voluntary carbon market allows a broader range of participants, including financial institutions and project owners [12] - Plans are in place to expand trading participants and develop new financial products while ensuring market stability and regulatory oversight [12][13] Group 4: Climate Investment and Financing - The climate investment and financing pilot regions have made significant progress, with over 5,400 projects in the pipeline and total investments exceeding 3 trillion yuan [15] - The pilot regions have developed a collaborative mechanism involving government, departments, and market participants to support climate investment and financing [14][15] - Financial tools have been innovated to address funding bottlenecks, with carbon reduction support tools facilitating over 1.1 trillion yuan in loans [16] Group 5: International Cooperation and Global Carbon Market - China is actively participating in the development of international carbon market rules and has established a national carbon trading market that plays a crucial role in global climate governance [17][18] - The country is exploring cross-border carbon trading and aims to enhance international collaboration in carbon market mechanisms [18] - China emphasizes the importance of multilateralism in addressing climate change and is committed to contributing to global green and low-carbon transitions [19][20]

Core Viewpoint - The article discusses the release of the "Opinions on Promoting Green and Low-Carbon Transition and Strengthening the Construction of the National Carbon Market," which aims to establish a more effective and internationally influential national carbon market in China [1][2]. Summary by Sections National Carbon Market Structure - The national carbon market consists of two interconnected markets: the mandatory carbon emission trading market for key emission units and the voluntary greenhouse gas reduction trading market [2]. - By 2027, the mandatory carbon trading market is expected to cover major industrial sectors, while the voluntary market aims for full coverage in key areas [2]. Strategic Importance and Current Status - The "Opinions" document is seen as a significant policy initiative under China's dual carbon goals, providing strategic guidance for the future [3]. - As of July 2025, the cumulative trading volume in the national carbon market reached approximately 681 million tons, with a transaction value of about 46.784 billion yuan [3]. Future Development Focus - Key areas for future development include expanding industry coverage, optimizing quota distribution and management, enhancing market liquidity, and integrating regional pilot markets into a unified national market [4]. Enhancing Market Vitality - The "Opinions" emphasize enhancing market vitality through the introduction of diverse trading products, expanding trading participants, and strengthening market regulation [5]. - The current market primarily consists of spot quota trading, lacking financial instruments, which the new policies aim to address by attracting more capital and improving liquidity [5]. Participant Diversity - Currently, market participants are mainly compliance enterprises, which limits market activity. Introducing diverse participants is expected to improve trading structure and market effectiveness [6].

Core Viewpoint - The document outlines the Chinese government's plan to accelerate the construction of a unified national carbon market, aiming for optimal resource allocation and maximum efficiency in carbon emissions management by 2030 [1]. Group 1: Goals and Objectives - By 2027, the national carbon trading market will cover major industrial sectors, and the voluntary greenhouse gas reduction trading market will achieve full coverage in key areas [1]. - By 2030, a comprehensive carbon trading market will be established, featuring a combination of free and paid allocation methods, with a transparent and unified approach that aligns with international standards [1]. Group 2: Market Development and Participation - The carbon market will expand to include more industries beyond the current four (electricity, steel, building materials, and non-ferrous metals), based on industry development status and carbon emission characteristics [2]. - The introduction of qualified individuals into the voluntary greenhouse gas reduction trading market and the establishment of carbon pledge and repurchase policies are effective measures to broaden the trading participant base [2]. Group 3: Regulatory Framework and Oversight - The government will implement a combination of free and paid carbon allocation methods, gradually increasing the proportion of paid allocations while preventing non-compliant carbon assets from entering the market [3]. - Strengthening regulatory oversight of trading activities is essential, including the establishment of risk assessment and management systems for compliance among major emitters [3]. Group 4: Legal and Institutional Framework - Ongoing legislative research is focused on improving the management of voluntary greenhouse gas reduction trading, enhancing the efficiency of fund clearing mechanisms, and reducing transaction costs in the carbon market [4]. - The construction of the national carbon market is a complex system engineering project that requires a balanced approach between government regulation and market dynamics [4].

Core Insights - The carbon market is a crucial policy tool for addressing climate change and promoting a green transition in the economy and society [1] - The recent document from the Central Committee and State Council emphasizes China's commitment to achieving carbon peak and carbon neutrality [1] Group 1: Carbon Market Development - China has established a national carbon emissions trading market and a voluntary greenhouse gas reduction trading market, which together form a comprehensive carbon market system [2] - As of July 2025, the national carbon emissions trading market has seen a cumulative transaction volume of 681 million tons and a transaction value of 46.784 billion yuan, indicating a growing market influence [2] - The voluntary greenhouse gas reduction trading market has registered 9.48 million tons of certified voluntary reduction, with a transaction value of 208 million yuan as of July 2025 [2] Group 2: Market Functionality and Goals - The document outlines a roadmap for the medium- and long-term development of the national carbon market, with specific targets set for 2027 and 2030 [4] - The focus will be on expanding the coverage of industries and greenhouse gases, establishing a transparent quota management system, and transitioning from intensity control to total control of carbon emissions [4][5] - The aim is to create a low-carbon development awareness across society, emphasizing that carbon emissions have costs while carbon reductions yield benefits [3] Group 3: Systematic Approach and Governance - The construction of the national carbon market is a complex system that requires a balance between market and government roles, long-term and short-term goals, and domestic and international considerations [6][7] - The government is tasked with creating a regulatory framework and risk prevention system, while the market focuses on resource allocation efficiency [7] - Local pilot carbon markets will continue to play a role in testing policies and mechanisms that can be scaled to the national level [7] Group 4: International Cooperation and Standards - The carbon market should also serve as a platform for international cooperation in green and low-carbon development, adhering to international standards and facilitating cross-border collaboration [8]

Core Viewpoint - The article emphasizes the importance of establishing a more effective, dynamic, and internationally influential national carbon market in China as a key policy tool for addressing climate change and promoting green transformation in the economy and society [1]. Group 1: Current Status of National Carbon Market - China has established a national carbon emissions trading market and a voluntary greenhouse gas reduction trading market, which together form a comprehensive national carbon market system [2]. - As of July 2025, the cumulative trading volume of carbon emission allowances reached 681 million tons, with a total transaction value of 46.784 billion yuan, indicating the market's growing effectiveness [2]. - The completion rate for allowance compliance among the 2,096 key emission units included in the trading market for 2024 is nearly 100% [2]. Group 2: Development Goals and Strategies - The document outlines a roadmap for the medium- and long-term development of the national carbon market, with specific targets set for 2027 and 2030 [4]. - It emphasizes the need to enhance market functions, expand the coverage of industries and greenhouse gases, and establish a transparent carbon allowance management system [4]. - The strategy includes a gradual shift from intensity control to total control of carbon emissions and the implementation of both free and paid allocation methods for carbon allowances [4]. Group 3: Market Dynamics and Governance - The construction of the national carbon market aims to create a low-carbon development awareness among society, emphasizing that carbon emissions have costs while reductions yield benefits [3]. - There is a focus on balancing market vitality with effective government regulation to ensure a healthy and orderly development of the carbon market [7]. - The role of local pilot carbon markets will continue as "policy testing grounds" to innovate regulatory methods and contribute to the national market's development [7]. Group 4: International Cooperation and Standards - The national carbon market is positioned as a mechanism for international cooperation in green and low-carbon development, adhering to international standards and facilitating cross-border collaboration [8]. - The design of the carbon market aims to enhance its international influence while promoting domestic green technologies and industries to expand globally [8].

Core Viewpoint - The new policy aims to enhance the national carbon market construction and promote green and low-carbon transformation, with specific targets set for 2027 and 2030 [1][2]. Group 1: National Carbon Market Development - By 2027, the national carbon emission trading market will cover major emission industries in the industrial sector, and the voluntary greenhouse gas reduction trading market will achieve full coverage in key areas [1]. - By 2030, a national carbon emission trading market based on total quota control, combining free and paid allocation, will be basically established [1]. - The policy emphasizes expanding the coverage of the national carbon emission trading market and improving the carbon emission quota management system [1]. Group 2: Voluntary Emission Reduction Market - The policy calls for accelerating the construction of the voluntary emission reduction trading market and promoting the application of certified voluntary emission reductions [2]. - It encourages government agencies, enterprises, and social organizations to actively use certified voluntary emission reductions to offset carbon emissions [2]. Group 3: Market Vitality Enhancement - The policy proposes to enhance market vitality by enriching trading products, expanding trading entities, and strengthening market transaction supervision [2]. - Financial institutions that meet requirements will be allowed to participate in the national carbon market trading under lawful and risk-controlled conditions [2]. - A risk assessment and management system for compliance of key emission units will be established to prevent compliance risks [2]. Group 4: Capacity Building - The policy outlines the need to improve management systems and support frameworks, strengthen carbon emission accounting and reporting management, and ensure strict regulation of carbon emission verification [2]. - It includes the implementation of qualification management for verification institutions in the national carbon emission trading market [2]. Group 5: Implementation Assurance - The policy emphasizes increasing joint efforts to combat illegal activities in the carbon market and enhancing policy coordination with green electricity and green certificate markets [3].

Core Viewpoint - The document outlines the Chinese government's strategic plan to enhance the national carbon market, aiming for a more effective, vibrant, and internationally influential system to support green and low-carbon transformation by 2030 [1][2]. Group 1: Overall Requirements - The plan emphasizes the integration of economic development with green and low-carbon transformation, aiming for a unified national carbon market that optimizes resource allocation and maximizes efficiency [2]. - Key targets include achieving basic coverage of major industrial sectors in the carbon trading market by 2027 and establishing a comprehensive carbon pricing mechanism by 2030 [2]. Group 2: National Carbon Emission Trading Market - The coverage of the national carbon emission trading market will be expanded based on industry development, emission reduction contributions, and data quality [3]. - A transparent carbon emission quota management system will be established, transitioning from intensity control to total volume control by 2027 for stable emission sectors [3]. Group 3: Voluntary Greenhouse Gas Reduction Trading Market - The development of a voluntary reduction trading market will be accelerated, focusing on sustainable projects with significant social and ecological benefits [5]. - The government encourages the use of certified voluntary reduction credits in various sectors, including government and enterprises, to offset carbon emissions [6]. Group 4: Enhancing Market Vitality - Financial institutions will be encouraged to develop green financial products related to carbon emissions, enhancing support for greenhouse gas reduction [7]. - The introduction of new trading participants, including individuals and financial institutions, will be facilitated to broaden market engagement [7]. Group 5: Strengthening Market Capacity - A robust management system will be established to support the national carbon market, including digital and intelligent management systems [8]. - The document emphasizes the importance of accurate carbon emission accounting and reporting, with a focus on improving data quality and regulatory oversight [9]. Group 6: Organizational Implementation and Support - Local governments are tasked with implementing the carbon market strategy, ensuring effective supervision of emission units and quota management [11]. - Legal frameworks will be developed to support carbon market operations, including regulations for voluntary reduction trading [12]. Group 7: International Cooperation - The plan highlights the importance of participating in international climate agreements and promoting the recognition of China's carbon market practices globally [12].

Core Insights - The national carbon emissions trading market in China is set to expand its coverage to include the steel, cement, and aluminum smelting industries, which are significant carbon emitters, with an estimated total emissions coverage of approximately 80 billion tons [1][3][4] - The market has seen a cumulative trading volume of about 673 million tons and a total transaction value exceeding 46.2 billion yuan as of July 15, 2025, indicating a growing trading scale and stable price trends [1][6][12] - The introduction of the voluntary carbon emissions reduction trading market (CCER) has begun, with the first certified voluntary reduction units officially issued, further enhancing market activity [1][12] Market Expansion - The national carbon market is recognized as a major institutional arrangement to address climate change and promote green low-carbon transformation in the economy [2][4] - The expansion plan was outlined in the government work report for 2025, emphasizing the need to broaden the industry coverage of the carbon emissions trading market [2][4] - The newly included industries are expected to add around 1,500 key emission units, increasing the total to approximately 3,700 units, which will cover over 60% of the national carbon emissions [3][4] Trading Mechanism and Performance - The carbon trading system has adopted a single-sided bidding method to enhance trading efficiency [3] - The carbon price has fluctuated within a reasonable range, with the market price recently stabilizing between 70-80 yuan per ton after reaching a peak of over 105 yuan per ton in November 2024 [7][9] - The completion rate for the 2023 carbon quota was approximately 99.98%, indicating a strong compliance culture among key emission units [6][11] CCER Market Development - The CCER market has seen a cumulative trading volume of about 237,800 tons and a total transaction value of 200 million yuan as of July 15, 2025, reflecting its growing importance [13][12] - Various stakeholders, including national and local key emission units, project developers, and financial institutions, are participating in the CCER market, which is expected to further stimulate market activity [13][14] - The CCER price has remained higher than the carbon emissions allowance (CEA) price, indicating strong market demand and the potential for future price adjustments as supply increases [10][14]