Beijing's 100-Standard Carbon Footprint Push: What the Five-Ministry Plan Actually Means for Steel

On 19 October 2026 the State Administration for Market Regulation (SAMR), the National Development and Reform Commission, the Ministry of Ecology and Environment, the Ministry of Industry and Information Technology and the National Energy Administration jointly issued a three-year action plan for building a carbon footprint standards system for key products (国市监标技发〔2026〕124号). The notice itself — as posted on SAMR and MIIT — is only a cover letter naming the addressees (relevant units and national standardisation technical committees) and carrying the five signatures. The substantive plan and its annex, the list of standards to be developed, sit in an attachment that has not been published in accessible form.

That gap matters less than it might appear, because the plan's architecture is already visible from SAMR's explanatory release and from the draft national standards that have been moving through the system this year. This article sets out what is actually known, separates it from what is still unverified, and explains why the steel provisions will be shaped more by work already underway than by the new document itself.

What the plan commits to

The headline numbers, per SAMR's release of 30 October:

Two framing choices are worth noting. First, the principle of 急用先行 — "urgent uses first" — signals sequencing by downstream demand rather than by product importance. Second, the stated aim of helping Chinese exporters respond to changes in international trade rules is explicit: this is a standards programme with a trade-policy function, not merely an environmental one.

The steel article: modest in itself, important in what it sits on

The raw-materials chapter contains a dedicated steel provision covering four groups:

• raw and auxiliary materials with high emissions, or where downstream customers impose explicit carbon-footprint data requirements;
• steel products (钢铁产品);
• steel articles (钢铁制品, i.e. fabricated and downstream steel goods);
• by-products — blast furnace slag, steel slag and blast furnace gas.

Four agencies — MIIT, MEE, NDRC and SAMR — are assigned "according to division of responsibilities". The NEA is not named for steel, which is consistent with its role being confined to the energy chapter.

That energy chapter is not irrelevant to steel, however. It explicitly covers coal for use in the steel industry alongside coal for chemicals and power generation, and the power article spans generation, transmission, distribution and storage. For a blast-furnace route mill in Hebei, the two largest determinants of a finished-steel footprint figure are coking coal and grid electricity. Putting those upstream factors into national standards is arguably more consequential for the credibility of a Chinese steel footprint number than the steel article itself.

The plan also references existing provincial work: Inner Mongolia's DB15/T 4058-2025 and Handan's DB1304/T 498-2025 show that local authorities have not waited for the national framework.

The infrastructure already exists

The plan is not the sector's entry point into carbon-footprint accounting. A general national standard is already in force:

Two route-specific standards are in the pipeline under the same committee structure: 20256513-T-605 for electric-arc-furnace short-process steel products and 20256510-T-605 for BF-BOF long-process products. These map directly onto the two categories already used in the national carbon-footprint labelling pilot scheme, which — per MEE's 2026 progress report — covers long-process steel, EAF steel and ferroalloys.

This reframes the plan's significance. The 2026–2028 window is not about establishing a steel methodology; it is about extending coverage from a generic steel standard to route-specific products, to fabricated steel articles, and to slag and gas by-products that currently sit outside most product boundaries. The by-product provision is the most technically interesting item on the steel list, because assigning credits or burdens to blast furnace slag and gas is exactly where footprint declarations from different producers diverge and where CBAM verification disputes are most likely to arise.

Where the leverage actually sits

The practical constraint on all of this is not ambition but drafting capacity. More than 100 national standards in three years means roughly one every ten working days, across five product domains, with each requiring technical committee work, public comment and approval. The Chinese system's established ladder — association standard first, then conversion to industry or national standard, under the naming convention 《温室气体 产品碳足迹量化方法与要求 XX产品》 — is designed to manage that load. Industry associations such as CISA have already produced the route-level association standards (T/CISA 469-2024 and T/CISA 470-2024) that the national route standards will presumably build upon.

For steel producers, the near-term obligations are therefore already identifiable from documents that have been published, independently of the action plan:

1. GB/T 47064-2026 has applied since 1 August 2026 — any producer making footprint claims to customers or regulators should already be working to it.
2. Route-specific standards will follow and will not necessarily produce the same figure as the generic method for a given heat.
3. CBAM compliance requires separate calculation under EU rules and default values, which will not be identical to the Chinese national-standard result.

What remains unverified

The most important missing item is the annex — the list of national standards to be developed — which would reveal how many steel standards are planned, their titles and their target dates. Until it is accessible, the number of steel-specific standards, the treatment of ferroalloys, and whether stainless or coated products get separate standards should be treated as unknown. The plan's own text, as republished by industry media, gives the chapter structure and the steel scope but not the per-product schedule.

Analytical takeaway

The plan is best read as a consolidation and coverage-extension exercise with a trade-defence purpose, not as a new regulatory direction. Its steel content is a modest four-item list sitting on top of a standard that has been in force since August and two route-specific standards already in the pipeline. The genuinely consequential elements are the explicit inclusion of steelmaking coal and grid electricity in the energy chapter — which determines whether Chinese steel footprint figures become defensible internationally — and the by-product provisions, which will decide how slag and off-gas are accounted for in declarations.

For exporters, the operational message is uncomfortable but simple: the binding deadline is not the 2028 horizon of this plan, but the standards already applicable, and the parallel EU framework that does not wait for Beijing's sequencing.

References

• MIIT notice page (cover letter), 国市监标技发〔2026〕124号, published 2 November 2026.
• SAMR notice page, same document, published 2 November 2026.
• SAMR explanatory release on the plan, 30 October 2026.
• Mysteel republication of the plan's full text.
• GB/T 47064-2026 standard record, SAMR open standards platform.
• National standard plan record 20240017-T-605, National Standards Information Public Service Platform.
• MIIT interpretation of the Guidelines for Compiling Carbon Footprint Accounting Rules and Standards for Key Industrial Products, 2024.
• MEE, Progress Report on the Construction of the Product Carbon Footprint Management System (2026).
• European Commission, CBAM legislation and guidance.