The interviews informing this paper provide a series of interlocking case studies of the ways in which specialist expertise in renewable energy institutions is integrated through the consultative drafting processes for Chinese emission trading schemes (ETS). This has been implemented through drafting groups, research collaboration, various types of meetings and conferences, industry feedback and online solicitation of opinions. Interviews in state-related research institutions, universities, regional ETS carbon exchanges and private sector consultancies indicated that this process can be a useful means of integrating regulatory measures that have proven effective. Not all interviewee recommendations are reflected in the February 2021 Trial Measures for the Chinese national ETS and related implement- ing rules. Examples of adoption of interviewees’ recommendations included detailed requirements for emissions monitoring plans, models for trading systems and registries, and specific methodologies such as default emissions values. The most important examples of non-adoption were stringent penalties for emissions and monitoring, reporting and verification (MRV) offences and supervisory powers of regulators relating to third-party inspection organisations. The March 2021 opinion solicitation draft (OSD) for a higher level, more permanent State Council regulation contains stronger penalties and supervisory powers. The 2019 and 2020 OSDs for the current national ETS rules also contained stronger penalties and supervisory powers than the current rules. Hence, all of the OSDs more closely resemble interviewee recommendations than the current rules. Interview evidence, and related scholarly writing, suggests that this pattern may relate to resistance of powerful economic interests. Nonetheless, it suggests that such resistance can be countered through capacity building and the example of early adopters in effective emissions trading. While the consultative drafting process has proved a useful means for identifying effective regulatory design on the basis of pilot ETS experience, it has yet to be put to best effect in the current national ETS rules.
carbon price, Chinese, consultative drafting, emissions trading, regulation, renewable energy
 Stoerk, T., Dudek, D.J. & Yang, J., China’s national carbon emissions trading scheme: lessons from the pilot emission trading schemes, academic literature, and known policy details. Climate Policy, 19(4), pp. 472–486, 2019. https://doi.org/10.1080/14693062.2 019.1568959
 Constitution of the People’s Republic of China, National People’s Congress (adopted and effective on 4 December 1982; amended on 12 April 1988, 29 March 1993, 15 March 1999, 14 March 2004 and 11 March 2018).
 Guidelines for Accounting and Reporting GHG Emissions for Key Enterprises; NDRC 2013, 2014 and 2015; Interim Measures for the Administration of Carbon Emissions Trading, NDRC 2014; Notice on Implementation of Activities to set up Carbon Emissions Trading Market, NDRC 2016.
 Tang, R., Guo, W., Oudenes, M., Li, P. & Tang, J., Key challenges for the establish- ment of the monitoring, reporting and verification (MRV) system in China’s national carbon emissions trading market. Climate Policy, 18, Supplement 1, pp. 106–121, 2018. https://doi.org/10.1080/14693062.2018.1454882
 Peng, F. & Yan, L., The institutional comparison research of 7 pilot ETS-based on the review on the legal documents of the 7 pilots. China Environment Law, 2, pp. 25–45 2014.
 Interview with Wang Dai, Li Zhou and Zhang Lin, offices of the Tianjin bureau of the MEE, 16 December 2019. Wang Dai is a member of the Tianjin Academy of Envi- ronmental sciences. Li Zhou and Zhang Lin are members of the Tianjin Low-Carbon Research Centre.
 Legislation Law of the People’s Republic of China, National People’s Congress (adopted on 15 March 2000, effective on 1 July 2000 and amended on 15 March 2015), Articles 7, 8, 11, 56, 71 and 73.
 Interview with Zeng Xuelan and Li Weichi, Sun Yatsen University, 4 January 2020. The Low-Carbon Research Centre of Sun Yat-sen University was the forerunner of the Guangdong Research Centre for Climate Change.
 Guangdong Development and Reform Commission (DRC) Notice on Implementation Measures on Monitoring, Reporting and Verification of Carbon Emissions for Enter- prises in Guangdong (Trial), Guangdong DRC Order No. (2014) 145, 18 March 2014.
 Notice on Enterprise GHG Emissions Reporting Verification Guide (trial), MEE 26 March 20201, [184.108.40.206.1 a)], 2.3 and [4.1.1], with detail at 220.127.116.11 - 18.104.22.168. http://www.mee.gov.cn/ xxgk2018/xxgk/xxgk06/202103/t20210329_826480.html
 MEE, ‘Carbon Emissions Trading Management Interim Regulations (Opinion Solicita- tion Draft)] 3 April 2019, available at: https://www.mee.gov.cn/hdjl/yjzj/wqzj_1/201904/t20190403_698483.shtml
 Interim Regulations on the Administration of Carbon Emissions Trading (Revised Draft) http://www.mee.gov. cn/xxgk2018/xxgk/xxgk06/202103/W020210330371577301435.pdf English transla- tion http://www.cet.net.cn/uploads/soft/202104/1_15100052.pdf
 International Carbon Action Partnership, China publishes two major policy draft for national ETS, November 2020. https://icapcarbonaction.com/en/news-archive/728- china-publishes-two-major-policy-drafts-for-national-ets
 Interview with Duan Maosheng, Tsinghua University Beijing, 20 December 2019. Duan Maosheng is the Director of the Institute of Energy, Environment and Economy, Tsinghua University; and Director, China Carbon Market Centre, Tsinghua University.
 International Carbon Action Partnership, China Releases Draft Interim Regulations on the Management of Carbon Emissions Trading. https://icapcarbonaction.com/en/news- archive/628-china-releases-draft-interim-regulations-on-the-management-of-carbon- emissions-trading
 Zhang, Z., Carbon Emissions Trading in China: The Evolution from Pilots to a Nation- wide Scheme, Working Paper 1503, Crawford School of Public Policy Centre for Climate Economics& Policy, Australian National University, 14, 2015. Available at: https://ccep.crawford.anu.edu.au/publication/ccep-working-paper/5535/carbon-emis- sions-trading-china-evolution-pilots-nationwide
 Ministry of Ecology and Environment (MEE), Carbon Emissions Trading Management Measures (Trial), MEE Order No. (2021) 16, 31 December 2020 (effective 1 February 2021).
 Interview with Yu Zexia and Tian Yiran at Hubei Carbon Exchange, Wuhan, 6 January 2020. Yu Zexia is Manager and Tian Yiran is Vice Manger of the trading department, Hubei Carbon Exchange.
 International Carbon Action Partnership (ICAP) ETS Detailed Information: China, Hubei’, https://icapcarbonaction.com/en/?option=com_etsmap&task=export&format= pdf&layout=list&systems%5B%5D=58
 Interview with Yan Lei and Professor Liu Yonggong, China Agricultural University, Beijing, 19 December 2019. Yan Lei is a Senior Manager in the Carbon Trading Center of the China Beijing Environmental Exchange.
 Hua, Y. & Dong, F., China’s carbon market development and carbon market connection: A literature review. Energies, 12(9), p. 1663, 2019. https://doi.org/10.3390/en12091663
 Interview with Guo Wei, Chen Zhibin and Jia Hui, offices of Sino Carbon, Beijing, 18 December 2019.
 Deng, Z., Li, D., Pang, T. & Duan, M., Effectiveness of pilot carbon emissions trading systems in China. Climate Policy, 18(8), pp. 992–1011, 2018. https://doi.org/10.1080/ 14693062.2018.1438245
 Zeng X., Duan, M., Yu, Z., Li, W., Li, M. & Liang, X., Data-related challenges and solu- tions in building China’s national carbon emissions trading scheme. Climate Policy, 18, sup1, pp. 90–105, 2018. https://doi.org/10.1080/14693062.2018.1473239