CCER Fieldnotes

China CCER Procurement Evidence: What to Ask For Before You Buy Units

Sources checked

If your team is buying China CCER units against a carbon cost exposure, the first question is not price. It is whether the seller can show you the underlying records. China's national voluntary emissions reduction market is administered through public registries, and several of the documents that a seller needs to point you to — design documents, calculation reports, validation reports and verification reports — are required to be disclosed through the registry system. This is editorial guidance on what to request and how to read it, not legal or certification advice.

Start with the registry entry, not the marketing deck

The administrative measures for the national greenhouse gas voluntary emissions reduction market state that a single national registry system records project and credit information, and that information held in that system is the definitive basis for judging ownership and status of certified voluntary reductions.

That single sentence should shape your whole request. Ask for the registry identifiers for the specific project and the specific issuance you are being offered, not for a summary document. If the identifiers are missing or do not resolve, that is a gap in the evidence you can resolve before pricing is discussed.

Ask for the validation report and the verification report — separately

The same measures distinguish two different documents and two different mandates:

  • The project validation report is issued by a validation and verification body and covers matters including legal and policy compliance, whether the project falls within a supported methodology, whether that methodology was applied properly, and whether the project has authenticity, uniqueness and additionality.
  • The reduction verification report (减排量核查报告) is issued by a validation and verification body in respect of a project's reduction calculation report and covers compliance with technical specifications, whether the project was implemented as described in the design document, and whether the reduction calculation follows the principle of conservatism.

These are not interchangeable. A project can be validly registered while a specific issuance remains unverified, so treat them as two separate pieces of evidence with two separate dates. The measures also state that the body validating a project may not be engaged to verify that project's reductions, so ask which two entities were involved.

Check the public disclosure trail

Under the measures, the project owner publishes its design document through the registry system for a public comment period of twenty working days, naming the validation and verification body at the same time. The reduction calculation report goes through the same kind of public disclosure before an issuance application.

That gives you two dated, nameable events to check. Ask when the documents were published and how long the comment period ran. Under Articles 13 and 20, the validation report and the verification report must each include the project owner's explanation of how public comments received during the disclosure period were handled. That explanation is the record to read for how the project responded to objections.

Confirm the eligibility conditions you are actually relying on

Several conditions in the measures are the kind of detail that quietly fails a diligence request:

  • The project must have started construction after 8 November 2012.
  • Reductions applied for registration must be generated after 22 September 2020.
  • Each application covers reductions generated within the five years before the application date.
  • Projects with a statutory greenhouse gas reduction obligation, or projects covered by national or local emissions trading allowance management, cannot apply for voluntary reduction registration.

Ask the seller to show you how the specific project satisfies each of these, and ask for the dates rather than assurances.

Ask what the units will be used for, because it affects what you should hold

The measures specify that where certified reductions are used to offset allowance surrender obligations in the national or local emissions trading markets, for carbon neutrality of large events, or to offset enterprise emissions, they should be cancelled in the registry — meaning the cancellation is recorded in the registry system for those listed uses. Whether that is the use your purchase falls under is a question to establish on the facts.

If your team is not in a surrender or offset context, treat that as a commercial question about what you are buying, not a compliance claim. Also note what the measures do not say: cross-border trading and use of certified reductions are to be addressed by separate rules to be formulated by the ecology and environment authority together with relevant departments. Those separate rules are a matter for your own counsel, and no supplier should be able to characterise the position for you.

A short request list to send

Put these in writing and require an answer per line:

  1. Registry project identifier and registry identifiers for the specific issuance.
  2. Project validation report, with date and the name of the validating body.
  3. Reduction verification report (减排量核查报告) for the issuance, tied to the reduction calculation report, with date and the name of the verifying body.
  4. Evidence that the two bodies are different entities.
  5. Public disclosure dates for the design document and the reduction calculation report.
  6. Project start-construction date, and the generation period of the credits.
  7. Confirmation that the project is not covered by national or local allowance management.
  8. Written confirmation of intended use, and whether retirement in the registry is expected.
  9. Any reliance on methodology or guidance not yet in force, named and dated.

What a good answer looks like

This article's due-diligence recommendation, not a legal standard: a credible counterparty answers with dates, identifiers and named public documents, and is comfortable with you resolving each one yourself in the registry. Counterparties who prefer to describe the credit in their own words, or who offer, in our editorial view as due-diligence practice, a valuation-style summary in place of the reduction verification report itself, are telling you something useful.

Ask the questions in this order, take the answers in writing, and let the public records decide.

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