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China’s 15th Five-Year Framework Plan for National Economic and Social Development (hereinafter referred to as “the Plan”), released on March 13, 2026, identifies the country’s key targets and priorities for economic and social development during 2026–2030, including on climate change mitigation. This policy brief provides an overview of key targets and priorities that are relevant to the mitigation of non-CO2 super climate pollutants, including methane, hydrofluorocarbons (HFCs), black carbon, tropospheric ozone, and nitrous oxide (N2O), as well as for improving cooling efficiency.

The Plan includes a project-based target for specific non-CO2 super climate pollutants. It states that China will develop projects to reduce methane, N2O, and HFCs in the coal mining, crop cultivation and livestock production, waste treatment, and chemical production sectors, with the goal of building 30 million tons of CO₂-equivalent mitigation capacity by 2030.

The Plan also includes other targets relevant to the mitigation of super climate pollutants. These targets include:

  • Reducing CO₂ emissions per unit of GDP by 17% cumulatively for 2026-2030 (a slightly lower target in comparison to the reduction target of 18% and achieved reduction of 17.7% for 2021-2025);
  • Raising the share of non-fossil energy in total energy consumption to 25% in 2030 (from 21.7% in 2025);
  • Reducing energy consumption per unit of GDP by around 10% by 2030;
  • Lowering PM2.5 concentration to below 27 micrograms per cubic meter in cities at or above the prefectural level by 2030 (from 28 micrograms per cubic meter in cities at or above the prefectural level in 2025);
  • Reducing the emissions of nitrogen oxides (NOx) and volatile organic compounds (VOCs) by over 8% respectively by 2030;
  • Increasing the share of surface water bodies rated at good quality to 85% in 2030 (from 80% in 2025); and
  • Increasing forest coverage rate to 25.8% in 2030 (from 25.1% in 2024).

The Plan includes strategies and priorities that are relevant to the mitigation of super climate pollutants. These are described below.

  • Developing governance and policy frameworks to achieve China’s carbon peaking goal by 2030 that can support the mitigation of super climate pollutants. The Plan provides for the implementation of policies and standards on local carbon assessment, sectoral carbon control, enterprise carbon management, project carbon evaluation, and product carbon footprint. Specifically, China will establish rules and standards for product carbon-footprint accounting, issue standards for key product carbon emissions-limits, create a product carbon-labeling and certification system, regularly update the national greenhouse gas (GHG) inventory, expand the coverage of the national carbon emissions trading market, and accelerate the development of the voluntary GHG reduction trading market.
  • Promoting key sectoral priorities for energy conservation and carbon reduction that can implement measures on super climate pollutants mitigation. The Plan highlights actions and projects to peak coal and oil consumption, strengthen management of high-energy-consuming and high-emission projects, deploy green and low-carbon technologies, construct zero-carbon factories and parks, and improve cooling efficiency. Furthermore, the Plan calls for strengthening energy efficiency governance in key sectors through the energy efficiency labeling system and Top Runner program.[1]
  • Advancing development priorities in the energy sector that can guide relevant methane mitigation strategies and policies in China. The Plan identifies hydrogen energy as one of the prioritized new growth industries, including its application in transportation, electricity, and industry. Additionally, as part of the energy infrastructure development plan, China will promote green hydrogen and strengthen the operation and dispatch system for the national oil-and-gas network. It is also noteworthy that the China-Russia gas pipelines are listed as one of the key energy-infrastructure projects by 2030. Lastly, China is enhancing energy security through measures such as increasing natural gas production and boosting gas storage capacity.
  • Supporting domestic market-building initiatives that can align with cooling efficiency improvement. As part of China’s efforts to build a strong domestic market, the Plan calls for promoting green consumption, including the sale of green and low-carbon products. These efforts could advance the market penetration of high-efficiency and climate-friendly cooling equipment in China. This is particularly significant given that China produces over 80% of global room air conditioners, with roughly 60% of that production destined for the domestic market.
  • Providing near-term opportunities for international cooperation on super climate pollutant reduction through China’s opening-up agenda and Belt and Road Initiative. As China promotes its high-level opening-up agenda, the Plan highlights efforts to promote compatibility between domestic and international rules and standards, making China’s rules compatible with leading international economic and trade rules. The Plan provides that such measures can help foster a transparent, stable, and predictable trade environment and support the integration of domestic and international trade. Key areas for mutual recognition of international and Chinese rules and standards include energy efficiency, water efficiency, and carbon footprint standards for key products. Additionally, the Plan calls for strengthening policy communication and strategic alignment with partner countries and international organizations involved in the Belt and Road Initiative, especially in areas such as energy and green development.
  • Advancing environmental-quality priorities, including controlling air pollution and emerging environmental pollutants, can support the synergistic control of super climate pollutants. For example, the Plan states that China will further strengthen efforts to control particulate matter and VOCs in key regions. These measures reinforce the broader air-quality and industrial-upgrade context in which the policies on mitigating the super climate pollutants can be strengthened and implemented. Additionally, the Plan provides that China will establish a coordinated governance and risk-control system for persistent organic pollutants, endocrine disruptors, antibiotics, microplastics, and related substances. This suggests a tightening of the chemical and environmental risk governance system that could further refine the pathways for refrigerant transition in China.

In conclusion, the 15th Five-Year Plan offers key strategic and policy guidance for mitigating super climate pollutants within China’s national development planning framework for 2026–2030. Going forward, we will continue to monitor how these targets and priorities are integrated into China’s regulatory and standardization systems, as well as into the sectoral and subnational 15th five-year plans to be released in 2026 and beyond.

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[1] China’s Energy Efficiency Top Runner Program provides for the regular publication of catalogues of the most energy-efficient products, enterprises and public institutions together with their energy-efficiency levels. The program is intended to guide products and industries toward continuous technological upgrade and improved efficiency levels. It also establishes a mechanism for the timely incorporation of Top Runner energy-efficiency levels into the mandatory energy-efficiency performance standards and energy-consumption limit standards.

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.

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On 24 February 2026, the Government of Himachal Pradesh launched the state’s first comprehensive emissions assessment and policy roadmap to tackle short-lived climate pollutants (SLCPs) and other non-CO₂ emissions, in a ceremony held in Shimla. The report, Tackling Non-CO₂ Emissions: Pathways for Himachal Pradesh, establishes a 2019 emissions baseline and models sector-specific pathways through 2047. The report was developed by the Department of Environment, Science, Technology & Climate Change, Government of Himachal Pradesh, in partnership with the Institute for Governance & Sustainable Development (IGSD) and The Energy and Resources Institute (TERI).  

Hon’ble Chief Minister Sukhvinder Singh Sukhu, present at the launch of the report, said:

“Protecting our glaciers, rivers, and mountain ecosystems is a responsibility we owe to future generations. This report gives us a science-based roadmap to reduce harmful pollutants while strengthening livelihoods, hydropower reliability, and public health. Himachal Pradesh will continue to lead with evidence-based climate action. I congratulate all partners who have helped in the development of the report. Building knowledge pools like this can only support our plans to ensure a sustainable future for our state.”

Sushil Kumar Singla, Secretary (Environment, Science & Technology and Climate Change), Himachal Pradesh, said:

“Our state’s unique terrain, high-elevation, and rapidly-expanding urban spaces make us more vulnerable to the impacts of Short-Lived Climate Pollutants such as black carbon and methane. These degrade air quality and contribute to glacier melt, which, in turn, threatens water security, agriculture, hydropower, and disaster resilience.   This report, with its rigorous scientific assessment of non-CO₂ emissions, is a critical reference framework in that respect. It also spotlights actionable solutions across key sectors.”

DC Rana, Director, Department of Environment, Science, Technology & Climate Change, said:

Increasingly, and at a steady pace, Himachal Pradesh has witnessed shifts in its climate. From excess rainfall, including extremely heavy rainfall days, to heat stress, which has started impacting hilly regions as well, the adverse effects of a warmer climate are coming to pass now. These have a ripple effect: for instance, warmer and drier conditions increase forest fire incidences, which lead to black carbon emissions that deteriorate air quality. Considering these overlapping climate and air-quality challenges, mitigating SLCPs becomes essential. This report will help to frame policies that address such SLCP challenges in the state.”

Durwood Zaelke, President of IGSD, emphasized the urgency of targeting super pollutants. He said:

“For a Himalayan state like Himachal Pradesh, cutting methane and black carbon is the fastest strategy available for turning down the heat. These pollutants are driving near-term warming and amplifying the pace of glacier melt. This makes the report valuable for the state’s policymaking and for the people of Himachal Pradesh to ensure a secure future in the face of changing climatic conditions.”

Vibha Dhawan, Director General, The Energy & Resources Institute (TERI), said:

“Climate change is not an abstraction in the world today. Especially for vulnerable Global South countries, the ramifications of negative environmental changes are high. In India, Himachal Pradesh – with its sensitive ecology and landscape – is a critical state from the lens of a rapidly changing climate. But if we need to formulate targeted policies to save fragile ecosystems, we need precise data to work with. To this end, the report offers a range of data-led insights and policy actions that can support the important work the state government is already doing. With collective effort, we can realize the goal of a climate-resilient Himachal Pradesh.”  

Carolina Urmeneta, Waste and Circular Economy Program Director at the Global Methane Hub, said:

“The launch of a comprehensive SLCP emissions policy roadmap by the government of Himachal Pradesh will help build resilience of the most pristine and eco-sensitive zones of the country, while contributing to temperature reductions by addressing methane, especially in the waste and agriculture sector (accounting for a large share of the methane emissions). The report shows that practical and cost-effective solutions exist, and the policy actions that ensue have the potential to deliver improved livelihoods and better public health outcomes to the citizens and rural communities of Himachal Pradesh. We commend the leadership shown in publishing this policy, while emphasizing that real impact depends on its effective implementation, which is of regional and global importance in the global climate crisis, and supports India’s net zero targets under the Paris Agreement.”

Zerin Osho, Director, IGSD India, said:

“We cannot change what we cannot measure. This report addresses that challenge by providing the right data sets and policy tools to act now and to track progress over time. This is more than an emissions inventory. It is a decision-support framework for departments, districts, and investors. By integrating air quality and climate action, Himachal Pradesh can secure rapid climate benefits while improving public health and rural incomes.”

Read the full report, Tackling Non-CO₂ Emissions: Pathways for Himachal Pradesh, here or on the Himachal Pradesh Department of Environment website.

See the Government of Himachal Pradesh press release here.

On 9 February 2026, the China Ministry of Ecology and Environment (MEE) issued the Circular on Further Strengthening the Management of Ozone-Depleting Substances (ODSs) and Hydrofluorocarbons (HFCs), which takes effect on 1 March 2026. The Circular covers the full lifecycle management of ODSs and HFCs, including production (including by‑production), sales, consumption, servicing, end‑of‑life recovery, reclamation, and disposal. Overall, it serves as an important government document supporting the implementation of the Regulation on the Administration of ODSs, related to China’s obligations as a Party to the Montreal Protocol on Substances that Deplete the Ozone Layer and its Kigali Amendment. (IGSD’s English reference translation of the Regulation on the Administration of ODSs is available here.) 

Key provisions in the Circular include:

  • Production quota licensing: Entities producing controlled substances for controlled consumption and feedstock shall submit an application by 31 Oct. each year for the quota for the following year.
  • Sales record‑filing: Sellers of controlled substances (including polyol blends and blended refrigerants) shall file a record with the municipal-level ecology and environment authority in the city where they are located. For renewals, the sales record shall be filed between Dec. 1 and Jan. 31 of the following year.
  •  Consumption quota-licensing or record‑filing: large-scale HCFC consumers (≥100 t/yr with baseline records) and certain CTC consumers shall apply for consumption quota licensing (submit applications by 31 October each year for the following year’s quota). Other consuming entities, including feedstock users, air conditioner manufacturers/installers, PU foam users of polyol blends, fire suppression product manufacturers, lab reagent and electronic gas purification entities, and quarantine and treatment entities using controlled substances such as methyl bromide, shall complete record‑filing (for renewals, consumption records shall be filed between Dec.1 and Jan. 31 of the following year).
  •  Record‑filing for servicing and end‑of‑life recovery, regeneration, and destruction: Entities engaged in servicing and dismantling/scrap handling of systems containing controlled substances, and entities conducting recovery, reclamation, or destruction activities shall complete record‑filing at the city level for servicing/dismantling and at the provincial level for recovery, reclamation, or destruction.
  • Control of by-produced carbon tetrachloride (CTC): Methylene chloride producers with CTC by-production and entities with CTC feedstock design use exceeding 1,500 t/yr are required to install automatic monitoring equipment, connect it to the ecology and environmental authorities’ monitoring network, and ensure data accuracy.
  • Control of by-produced HFC-23: Facilities with HFC-23 by-production are prohibited from emitting HFC-23 directly. If the by-produced HFC-23 is not used as feedstock or for other permitted purposes, it must be destroyed using required technologies. The facilities are required to develop an HFC-23 monitoring plan, and carry out standardized measurements and periodic reporting in accordance with the Technical Specification for Accounting Methods and Reporting of By-product Trifluoromethane Emission from Chlorodifluoromethane Production Facility (HJ 1420—2025) (effective as of 1 March 2026). Furthermore, the facilities shall take measures for leakage detection and repair to reduce fugitive HFC-23 emissions.
  • Record keeping and reporting via the national system: Producers, sellers, users, servicers, end-of-life handlers, and recovery, reclamation, and destruction entities shall use the ODS Information Management System for quota applications or record-filing, retain complete original records for at least three years, and report data quarterly (production, sales, and consumption: within fifteen working days after the quarter’s end) or annually (servicing or end-of-life recovery, reclamation, and destruction: within thirty working days after the year’s end).
  • Strengthened enforcement: Ecology and environment authorities will prioritize inspections and supervision in relevant sectors, using automated monitoring, cross-agency data screening, big-data analytics, and on-site checks to identify violations, especially unlicensed or over-quota production or sales, improper buying or selling, illegal consumption of phased-out substances or unlicensed/over-quota consumption, and failure to meet record-keeping or filing requirements.

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8 January 2026 – China recently released two national policy instruments to advance the transition to energy-efficient, climate-friendly residential air conditioners (ACs) in its domestic market. These instruments also aim to strengthen the domestic collection and recycling systems needed to improve lifecycle refrigerant management. IGSD provides further details on these instruments, referred to as “Circulars,” below, with links to the original Chinese versions.

  1. Circular on Implementing the Large-Scale Equipment Upgrade and Consumer Goods Trade-in Policies in 2026 (National Development and Reform Commission and Ministry of Finance, 8 January 2026):

This Circular incentivizes the purchase of energy-efficient ACs and supports end-of-life AC and refrigerant management through:

  • Providing a subsidy to individual consumers who purchase ACs with level-1 energy efficiency performance, the highest level under China’s AC energy efficiency standards, at 15% of the product sale price, with a cap of RMB 1,500 per unit and limiting to one unit per consumer; and 
  • Supporting improvements to end-of-life AC and refrigerant management by strengthening the recycling system, including the collection points, transfer stations, and sorting centers, and by strengthening supervision of disassembly/recycling enterprises.

2. Circular on Green Consumption Promotion Action (Ministry of Commerce, together with the National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Ecology and Environment, Ministry of Housing and urban-Rural Development, Ministry of Agriculture and Rural Affairs, the People’s Bank of China, the State Administration for Market Regulation, and the National Financial Regulatory Administration, 4 January 2026):

This Circular contains several AC-related provisions:

  • Encouraging consumers to buy green smart appliances, including fluorine-free ACs;
  • Promoting the development of a green supply chain, including prioritizing the procurement of high-efficiency equipment and conducting the carbon-footprint evaluation; and  
  • Supporting the establishment and improvement of collection and recycling systems, which include the collection points, transfer stations, and sorting centers. 

Together, these two policy instruments are expected to incentivize the transition to energy-efficient and climate-friendly ACs in China’s domestic market and to support lifecycle refrigerant management by strengthening the collection and recycling system for end-of-life ACs. We will continue to monitor these developments, as they serve as useful examples of policies for transitioning cooling systems in a major Global South producer of cooling equipment.

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