On March 12, 2026, China enacted its landmark Ecological and Environmental Code (“the Code”), which is set to take effect on August 15, 2026. Comprising over 1,240 Articles organized into a hierarchical structure of Parts, Subparts, Chapters, and Sections, the Code marks a shift from fragmented regulation to a unified legal framework that integrates pollution control, ecological protection, green transition, and climate response. Importantly for climate change mitigation, the Code clarifies the legal obligations of enterprises and public institutions to control greenhouse gas (GHG) emissions (Arts. 9 and 949) and empowers national ministries/agencies to promulgate standards on pollution control and green and low-carbon development (Art. 70). Notably, the Code consolidates and updates existing laws, while leaving room for future institutional strengthening and sector-specific legislation. This is especially relevant to climate-related content in the Code. In particular, Part IV of the Code establishes the legal foundation for green and low-carbon development, which can later be supplemented with dedicated laws and regulations on GHG emissions control (Art. 1,239).

Overview of provisions related to mitigating super climate pollutants

The Code does not create a specific regulatory framework for super climate pollutants, such as methane, hydrofluorocarbons (HFCs), black carbon soot, tropospheric ozone, and nitrous oxide (N₂O). However, Part II on Pollution Control, Part IV on Green and Low-Carbon Development, and Part V on Legal Liabilities are all relevant for understanding China’s legislative approach to mitigating super climate pollutants. Specifically, Part II includes provisions addressing coalbed methane and HFCs. Part IV contains a chapter on climate change requirements. And Part V specifies legal liabilities for violations of GHG emissions-related requirements. Further details on these provisions are provided below.

Pollution Control

Part II contains provisions that directly support methane and HFC mitigation. In its Subpart 2 on air-pollution-control, the Code incorporates sector-specific requirements relevant to methane mitigation, including compliance with coalbed methane emission standards (Art. 203) and the recovery and treatment of flammable gases from landfills (Art. 218). Additionally, the Code provides for the control of ozone-depleting substances through measures including total-quantity control and quota management (Art. 254). The water pollution and solid waste Subparts (Subparts 3 and 6) contain Articles relevant to methane mitigation. The Code requires the treatment of urban sewage and wastewater (Arts. 303-304), supports rural wastewater and garbage treatment (Art. 305), strengthens control of fertilizer use (Arts. 306-308) and promotes the comprehensive utilization and safe disposal of livestock manure (Art. 309). Regarding solid-waste control, the Code requires comprehensive management of solid waste to reduce waste at sources, increase resource reutilization, and minimize landfill volumes (Arts. 466-467). Furthermore, it establishes integrated systems for the classification, collection, resource utilization, and harmless treatment of household waste (Arts. 499-515), including emissions monitoring and data disclosure requirements for household waste treatment facilities (Art. 513).

It is also important to note that Part II of the Code requires that air-pollution-control measures promote coordinated control of air pollutants, including particulate matter, sulfur dioxide, nitrogen oxides, volatile organic compounds, ammonia, and GHGs (Art. 189). This coordinated control requirement is especially relevant for reducing black carbon soot, tropospheric ozone, and methane emissions, including in the transportation, waste, agriculture, and fossil-energy sectors.

Development of the Circular Economy

Chapter 2 under Part IV on the Development of Circular Economy addresses GHG emissions during production, waste management, and consumption. For production, the Code encourages adopting green design and advanced technologies and equipment to conserve resources and reduce GHG emissions (Arts. 960-974). Notably, in the waste-management context, the Code supports the comprehensive utilization of crop straw and livestock and poultry manure, thereby helping reduce methane emissions (Art. 981). It also includes strengthened provisions on the classification, treatment, and resource recovery of household solid waste (Arts. 983-984). For consumption, the Code encourages green consumption incentives and trade-in programs for consumer goods (Arts. 992-993). It further strengthens the government’s green procurement program (Art. 994) and requires enterprises to adopt green procurement practices and develop green supply chains by prioritizing energy-efficient, water-saving, and resource-conserving materials, products, and services (Art. 1,000).

Energy Conservation and Green Low-Carbon Transition

Chapter III under Part IV on Energy Conservation and Green Low-Carbon Transition includes provisions that are especially relevant to improving cooling efficiency and reducing methane emissions. Specifically, the Code emphasizes the importance of the energy-conservation standard system and the energy-efficiency labeling system for achieving energy-conservation goals, especially for high-energy-consuming products like household appliances (Arts. 1,008 and 1,011). It also supports coalbed methane extraction and utilization (Art. 1,015), encourages the green and efficient extraction of oil and natural gas (Art. 1,016), and promotes the high-quality development of hydrogen energy (Art. 1,024).

Climate Change

Chapter IV under Part IV on Addressing Climate Change forms the primary statutory foundation for climate governance in China, as China has not yet enacted a dedicated climate change law. The Code clarifies key points about agency authorities and climate-governance mechanisms. It designates the Ministry of Ecology and Environment as the responsible agency for national climate-change work, while assigning the National Development and Reform Commission a coordinating role in achieving the country’s carbon peaking and neutrality goals (Art. 1,026). It also provides that product carbon footprints are measured in carbon dioxide equivalent, thereby including GHGs beyond CO₂ in such measurements (Art. 1,036). Additionally, the Code states that China supports international cooperation on climate-related technologies, such as hydrogen energy and carbon capture, utilization, and sequestration (Art. 1,051).

Legal Liabilities and Compliance Assurance

Part V of the Code provides that any entity or individual that pollutes the environment or violates green and low-carbon provisions shall be held legally liable (Art. 1,052). Part V is essential to ensuring compliance with and enforcement of the provisions discussed above, as well as key compliance-assurance mechanisms such as data monitoring, reporting, and verification (Arts. 1,085-1,093), and environmental impact assessment (Arts. 1,094-1,100).

Conclusion

Overall, China’s Ecological and Environmental Code strengthens the legal foundation for addressing super climate pollutants. It embeds relevant provisions across the Parts and Chapters on pollution control, circular economy, energy conservation, climate governance, and legal liability. While it does not create a standalone legal regime for these pollutants, it provides a stronger basis for the next steps including implementation measures, and strengthened compliance and enforcement.

We will continue to monitor future developments, particularly in policy design, standard development, monitoring and enforcement action, and pilot projects in key sectors. As China’s regulatory framework evolves, it may also help shape the global supply chains and impact the broader international climate cooperation. Therefore, the significance of the Code lies not only in its current provisions, but also in the broader regulatory and institutional developments it may support in the next phase of implementation.

Additional IGSD China resources:

• IGSD (18 March 2026) China’s 15th Five-Year Framework Plan: Overview of Key Targets and Priorities for Mitigating Super Climate Pollutants.

• IGSD (9 February 2026) China Strengthens Lifecycle Management of Ozone‑Depleting Substances and HFCs.

• IGSD (8 January 2026) China Releases New Policies to Advance Efficient and Climate-Friendly Cooling.

• IGSD (26 November 2025) China Launches Stakeholder Alliance to Control Industrial Nitrous Oxide Emissions.