Comparing Carbon Emission Trading Schemes of China, Japan & Korea

Assessing their readiness for linkage

The 2015 Paris Agreement on Climate Change[1] has prompted countries to consider stronger policies to achieve de-carbonization. One of the most efficient ways to reduce GHG emissions is the carbon pricing policy instruments.

In this regard Asia is rapidly establishing itself as new Emission Trading Scheme (“ETS”) hub.  To help speed industries’ transition away from emissions-intensive production, Asian countries are increasingly exploring carbon pricing policies[2]. Some of the recent encouraging developments include China official - even though soft - launch of its nationwide ETS in December 2017[3], South Korea reforms in the ETS and its Government’s approval of ETS’s Phase 2 on July 2018[4], With both South Korea and China having a nationwide ETS, there is tremendous political pressure on Japan to enact a policy to impose a carbon market and price across its whole economy in light of positive results its sub-national ETSs have achieved. While the countries’ experiences with ETS, national or sub-national, will no doubt be helpful for potential linkages between themselves or other countries in the future, their differences in ETS’s architectures present significant challenges[5]. This paper first walks through the design of China’s new nationwide ETS and contrasts it with the ones of Japan and South Korea. In the next section, and even though China, Japan, and Korea have no near term plans to link their ETSs, we catalog and compare some of the most important three countries’ ETS technical features to highlight potentialities for linkage. Some barriers are particularly relevant in the Northeast Asian context, while others apply more generally[6].

Section 1 – China, Japan and South Korea ETSs

There are two types of ETSs, national and sub-national.

Source: International Carbon Action Partnerships[7]

1 - National ETSs

  • South Korea ETS

On January 1st, 2015, Korea launched its national ETS (“KETS”)[8], the first nation-wide Cap-and-Trade program in operation in East Asia. The KETS covers approximately 525 of the country’s largest emitters, which account for around 68% of national GHG emissions[9].  Expectedly, the performance of the KETS in the first year of its operation was quite disappointing with the total traded permits were only 0.8% of the total quantity of pre-allocated allowances, for a total of 543 million tons. The lack of trading liquidity occurred because it was the first year for compliance. A company tends to observe how the ETS works and waits to determine whether to trade their permits. Similarly, EU companies did not actively participate in ETS during the first year of implementation[10]. During the first phase (2015–2017) of the KETS, there was a shortage of emission permits in the power generation and energy sector, whereas the steel industry had a relatively sufficient number of emission permits.

In 2016, efforts were made to increase the supply of allowances in to ease the pressure on market participants.

Since the start of trading, carbon prices in the ETS have been following an upward trend[11].


January 2015

December 2015

June 2016

Average price


KRW 8.185 (approx. EUR 6.50)

KRW 10,000 (approx. EUR 7.94)

KRW 17,000 (approx. EUR 13.50)

KRW 16,309 (EUR 12.95)

KCU 2015

KRW 9,933 (EUR 7.89)

KRW 12,000 (EUR 9.53)

KRW 18,500 (EUR 14.69)

KRW 15,599 (EUR 12.39)


Overall, the total value of units traded between January 2015 and June 2016 was KRW 1,781 billion (EUR 1.4 billion). Trading activity was highest during the first half of 2016, when a significant share of the total transactions took place (80% of KAU trades and 60% of KCU trades). Therefore, the average price of units over this period is close to the final price on 30 June 2016, and the difference between them was relatively small. On 11 July 2018, the Korean government released the Allocation Plan for the second phase of its ETS[12].

  • China ETS

Over past decades, China heavily relied on subsidy programs as the primary policy tools for low carbon development. The Ministry of Finance stopped the energy efficiency subsidy program in 2013 and the Chinese government has been attaching increasing importance to market-based policies to achieve its environmental goals[13]. This involved a long debate on whether China should introduce an ETS or a carbon tax. In its 12th Five-year plan (FYP12 – from 2011 to 2015) the State Council announced for the first time, a national carbon intensity reduction target[14].  Chapter 21 of the FYP12 calls for the implementation of market-based mechanisms such as ETSs to implement goals of the Plan. In October 2011 the National Development and Reform Commission (“NDRC”) [15] published a Notice that assigned the task of establishing ETS pilot programs to five cities (Beijing, Chongqing, Shanghai, Shenzhen and Tianjin) and two provinces (Guangdong and Hubei). The main objective of the establishment of pilot ETS programs was to learn lessons through experiences and to facilitate the development of a national ETS.  The seven pilots each started their operations between June 2013 and June 2014.

The 7 provinces and cities were carefully selected based on two main factors (i) willingness of provincial leaders to have an ETS pilot (ii) need to represent a variety of Chinese economic, social, and geographic criteria. Together, the 7 locations represent about 25% of the country’s annual GDP[16].  Leaders have emerged among the pilots, helping to establish best practices for the national market. Guangdong and Hubei have experimented with auctioning allowances, the allocation approach the national market intends to eventually transition to after an initial period of free allocation. The Beijing market has maintained the highest and most stable carbon price.  The NDRC guidelines help structure the overall design of the pilot programs by requiring that the two provinces and five cities. On December 19, 2017 China officially and softly launched its national ETS[17].  However, it will take until around 2020 before seeing actual monetary transactions in the ETS[18]. China has bought time for laying a solid groundwork needed for market operation. A number of uncertainties remain around the scheme, including concerns over data quality, and measuring, verification and reporting systems in many of the Chinese provinces. When fully implemented, the ETS could more than double the volume of worldwide carbon dioxide emissions covered by either tax or tradable permit policy.  China now has over a decade of policy experience with, the implementation of seven ETS pilots. Hubei and Shanghai have been selected to lead preparatory work in two vital aspects of the nationwide ETS. Hubei will take charge of setting up and maintaining the national carbon registry while Shanghai is responsible for getting the trading platform ready. According to the policy document released, China’s national ETS construction will involve three phases. The first phase (“infrastructure construction”) (“system test”) (“development and improvement”)[19]. Many elements are not detailed in the document, particularly the allowance allocation protocol. In the remainder of this section we describe the expected design based partly on the recent document and partly on experience with an allowance allocation trial.

The ETS, for now, will only be run in the power sector, due to better data quality and reliability when comparing to other sectors, covering coal-fired and gas-fired power plants, including those that produce both power and heat. Even so, this makes up a third of China’s total carbon emissions.

 2 - Sub-national ETSs

  • Mandatory ETSs

While the Japanese Global Warming Tax (“JGWT”), J-Credit Scheme, and the international Joint Crediting Mechanism (“JCM”) are currently operational, cap-and-trade has not yet found its way into national level climate policy. However, Japan’s capital runs the local Tokyo Metropolitan Government Emissions Trading Scheme (“TMGETS”), which is directly linked to a prefectural-level ETS in neighboring Saitama (“SETS”).



The TMGETS, launched in April 2010[20], is Japan’s first mandatory sub-national ETS. In FY2014, emissions by covered entities reduced by 25% compared to base year emissions. It amounts to approximately 14 million tons reduction in the first compliance period[21].Views differ in Japan on the role of carbon pricing in Japan. ETS is viewed with caution in Japan, because of concerns about price volatility and the risk of speculation[22]. Some analysts have concluded that Japan already has one of the world’s highest carbon prices and therefore cannot raise its carbon price without harming its economy while others point to the need for industrial restructuring to increase value added per ton of carbon emissions in the Japanese economy.

In terms of linkage with other ETSs, Japan can make an important contribution to international mitigation efforts, by providing public and private support for emissions-reduction activities in other countries especially in South East Asia where many Japanese companies’ factories are established.. TMGETS and SETS are connected with each other as Japan sometimes considers a national scheme. The coverage of STES is basically the same as TMGETS. It covers large-scale facilities (buildings and factories) with total consumption of fuels, heat and electricity of 1,500 kiloliters or more per year in crude oil-equivalent. Approximately 600 facilities are covered.

Saitama Prefecture revised its global warming strategy action plan—Stop Global Warming Saitama Navigation 2050—in 2015 and set a target greenhouse gas reduction of 21 %  below 2005 levels by 2020. Excess Credits from Tokyo Metropolitan Government's emissions trading system and Small and Midsize Facility Credits issued by Tokyo Metropolitan Government are officially eligible as offset credits. Credits from excess emission reductions and Small- and Mid-size Facility Credits are eligible for trade between the two ETSs. During the first compliance period, 14 credit transfers took place between the Saitama Prefecture and Tokyo (8 cases from Tokyo to Saitama, 6 cases from Saitama to Tokyo).

Overall, the stance of Japan’s government has been to carefully consider ETS, evaluating its burden on Japanese industry, associated impacts on employment, developments and effects of emissions trading schemes in other countries, and global warming countermeasures that are already implemented in Japan (e.g., voluntary actions by industry).

Tokyo aims to become the city with the lowest environmental impact in the world. The end of September 2016 was the deadline for meeting the obligations of the first compliance period. Over the first five years of operation (FY2010–FY2014), TMGETS led to a remarkable drop in emissions from covered facilities in Tokyo. Total emissions for FY2014, the last year of the first compliance period, were 25% lower than base-year emissions[23].

3. Voluntary ETS

The Kyoto Prefecture has a "Kyoto Verified Emission Reduction" scheme managed by the "Kyoto COReduction Bank,”. it does not impose any reduction obligation on facilities in Kyoto.[24]

Section 2 – Assessing potentialities for inking China, Japan and Korea ETSs

China, Japan, and Korea together account for approximately 30 % of global GHG[25]. Emissions have been increasing significantly in the region, especially in China, which is the world’s largest emitter. In order to address global climate change effectively, China, Japan and Korea may take full advantage of the international cooperation scheme under Article 6.2 of the Paris Agreement. These extraterritorial emissions reductions may be less costly to achieve than domestic mitigation opportunities. Barriers that may slow down or even stop the process of carbon market integration through linking come in various forms. The table below compares some of the key features of the three countries’ ETSs systems.






Pro-linkage / anti linkage/Uncertain impacts

Targets &

ex post adjustment

BY 2020: 40–45% reductions in carbon intensity compared to 2005 levels.


2016–2020: Reduction in carbon emissions per unit GDP by 18% compared to 2015 level


By 2030: Peak CO2 emissions around 2030, with best efforts to peak earlier.


Ex post adjustments available


Source: NDC China[26]

By 2020: 25% absolute reduction target from 2000 GHG levels. By 2030: 30% reduction from 2000 GHG levels.


No ex-post adjustment












Source: NDC Japan[27]

GHG reduction targets BY 2020: 30% below BAU. By 2030: 37% below BAU (536 MtCO2e). This represents a 22% reduction below 2012 GHG levels.


No ex-post adjustments











Source: NDC Korea[28]



China will implement intensity target while Japan and Korea has opted for an absolute target.

The NDRC will need to strongly enforce the intensity targets in order for the ETS to function effectively, as an intensity target does not discourage companies from decreasing overall production. Allocations under intensity targets are adjusted ex-post, and this could lead to over-allocation or liquidity problems down the road for the national ETS.

Because ETSs  of Japan and Korea function on the basis of permits for absolute amounts of emissions, China has to convert its emissions intensity target to an absolute emissions target. Because of the strong correlation between the economy and the energy, environment and climate systems, ETSs and other policy targets are not independent, and different policies may have influence on each other.


Scope of ETS

Sub-national (7 pilots) transiting to Nationwide ETS

3 Sub-national ETSs




Since Japan has no national-level ETS, linking its domestic emissions-allowance market to a foreign one would have to involve the market of a local jurisdiction that has already introduced an ETS. The TMGETS and SETSs, however, have already reduced emissions more than expected, leaving these markets with excess allowances. Given Japan’s current and quite modest national reduction target under the Paris Agreement, there is little necessity to trade emission allowances with other countries at this stage.


Nature of ETS

Mandatory (Sub-national ETS)

Mandatory (Nationwide ETS)

Mandatory (Tokyo + Saitama)


Mandatory with voluntary opt-in



All there ETS are mandatory. However, please refer below to sectors and thresholds.


Covered sectors  

The National ETS will first cover power generation. It will extend to other sectors later on.



Compliance factor 1st Period (FY2010–2014): 8% - 6% reduction below base-year emissions. 2nd Period (FY2015–FY2019): 17% or 15% reduction below base-year emissions. The higher compliance factors (8% and 17%) apply to office buildings, and district and cooling plant facilities).



The industry, power generation & energy, building, transportation and waste sectors are covered, which are further divided into 23 sub-sectors


 Phase 1 (2015–2017): 23 sub-sectors from steel, cement, petro-chemistry, refinery, power, buildings, waste and aviation sectors.




The existing markets differ substantially in the sectors they regulate with Korea’s market covering most economic sectors, while those in Japan exclude the emissions of power and transport sectors. China will focus on power generation for phase 1.


GHG coverage

The nationwide ETS does not provide full details. If we consider Sub-national ETS, there are major differences in covered gases between Beijing ETS and other country’s sub-national ETS.


 (CO2), (CH4), (N2O), (HFC), (PFC),(SF6)


Carbon Dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O), Hydrofluorocar­bons (HFC), Perfluorocarbons (PFC), and Sulfur hexafluoride (SF6)



Covered gases don’t seem to vary significantly. We would need to see what gases are covered by China nationwide ETS.

Inclusion thresholds

Sub-national ETS : 1200 MtCO2e


Nationwide ETS Phase 1 (2017–2019): 3000–5000 MtCO2e/year, (projection only)



Tokyo : 13 MtCO2e

Saitama : 11 MtCO2e



Phase one (2015–2017): 1,687 MtCO2e, including a reserve of 89 M tCO2e for market stabilization measures, early action and new entrants.


Inclusion Thresholds: Company >125,000 tCO2/year, facility >25,000 tCO2/year


Phase two (2018-20): 2018: 538.5MtCO2e. Caps for 2019 and 2020 will be announced in 2018.




Emission permits allowance

Most emission allowances will be distributed freely by the government in the first phase of China’s national ETS.

Grandfathering based on historical emissions.



allocation Phase one (2015–2017): 100% free allocation, no auctioning.


Phase two (2018–2020): 97% free allowances, 3% auctioned.


Phase three (2021–2025): Less than 90% free allowances, more than 10% auctioned.





in Phase 1 of China nationwide ETS,  permits will be allocated for free which cause hardship for international linkage


In Japan, instead of distributing emission allowances, the TMGETS defines reduction obligations and only issues excess reduction credits (“ERC”) if these obligations are exceeded. TMGETS follows the cap-and-trade approach but limits trading to excess allowances and offsets.


Current Allowance Price (per t/CO2e)

Prices between China’s sub-national ETS vary. Looking at Beijing ETS (most stable China’s ETS pilot market) the average t/CO2e price was USD  7.59 (2017) up to 9.44 (2018) making it higher than Tokyo price.


According to the deputy head of NDRC’s climate change department, Jiang Zhaoli, companies will not feel real pressure to cut emissions until the carbon price hits 200-300 CNY (USD 29-43) tonne which he does not expect to happen until after 2020.


Source for prices[29]


The average t/CO2e price was USD 31.5 in 2015. In 2017, the average price was USD 13.60 and in 2018 it was USD 5.69.





Source for prices[30]





Average t/CO2e price was 26,500 KRW or USD 24 and declined to USD 18 in 2017. The average t/CO2e price in 2018 was USD 21.






Source for prices[31]




The price differences between the three countries seem to reduce. Korea>Shanghai> Japan. Japan and Korea have a relative paucity of low-cost emissions options domestically compared to China, which in turn could benefit from the revenue generation opportunities of selling permits abroad. Policymakers in China may deliberately decide to impose a price floor or ceiling, like in California, in the Chinese ETS to keep the prices stable and lower than carbon prices in other jurisdictions.


Price management

NDRC in cooperation with other ministries are to develop adjustment mechanism to prevent abnormal price fluctuations.

In general, TMG does not control carbon prices. However, the supply of credits available for trading may be increased in case of excessive price evolution (increase of decrease).

The Allocation Committee may decide to implement market stabilization measures in case of excessive price evolution (increase of decrease).





Price management follow a similar arrangement.

Banking and borrowing, offsets and credits


Banking is allowed.

 Use of carbon of set credit is limited on CCER (domestically-produced offsets) (5%~10%)

Sub-national ETS (limited to CCER which issued by projects in Hubei area).The use of CCER credits is expected to be allowed at certain time during 3rd Phase of nationwide ETS.


Banking is allowed between two compliance periods.


Eligible credits include: 1) Small and Medium-sized Facility Credits Within the Tokyo Area, 2) Outside Tokyo Credits, 3) Renewable Energy Certificates, and 4) Saitama Credits.

Banking and borrowing are allowed. Covered entities can use offsets to meet up to 10% of their allowance submission obligations. In Phase I & II, only domestic offsets are accepted. In Phase III, the use of international offset credits will be allowed, but only up to half of the offsets submitted may be international offset credits.



Although borrowing policies differs between the three countries they are unlikely to impact market liquidity and transactions.













Point of regulation



Mixed: Both direct emissions from the power sector and indirect emissions from electricity (and heat) consumption are included in the scheme in the long term.

Downstream bias (large energy consumers)

The KETS covers direct emissions as well as indirect emissions from electricity consumption



Number of liable entities

The ETS regulates around 1,700 companies from the power sector (including combined heat and power as well as captive power plants of other sectors), which emit more than 26,000 tons GHG per year, or consume more than 10,000tce per year.

Approximately 1,400 commercial and public facilities that have a total consumption of fuels, heating and electricity of at least 1,500 kilolitres per year.


599 business entities including 5 domestic airlines as of November 2017. Companies whose total annual emissions are 125,000 tCO2e or more or companies with places of business whose annual emissions are 25,000 tCO2e or more are subject to caps under the KETS. Companies whose emissions are below the threshold described above may voluntarily participate in the KETS.


Measurement, Reporting & Verification

The NDRC is currently drafting regulation for third-party verification for the national ETS. Before this is finalized, local DRCs are asked to select suitable institutions and personnel to carry out the verification tasks according to suggested requirements by the NDRC.


Participants are required to annually submit (fiscal year) their emission reduction plans and emissions reports. Seven GHG gases have to be monitored and reported: CO2 (non-energy related), CH4, N2O, PFCs, HFCs, SF6 and NF3. Verification: These reports also require third-party verification. Framework: These are based on “TMG Monitoring/Reporting Guidelines” and “TMG Verification Guidelines”.


Mandatory annual report to the Governor under the “Guidelines for Calculating Greenhouse Gases” are verified by a third-party verification agency registered with the Governor of Tokyo

Covered facilities are required to develop an annual emission inventory, which must be verified by a third party before being reported to the government.


Once reports are certified, facilities are listed in the Emission Trading Registry System (ETRS), established by the government. Facilities are required to submit the allowances which account for emissions from the previous year.


Emission Certification Committee under the Ministry of Strategy and Finance confirms the report based on the evaluation. Korea now has 19 independent verification agencies and 207 certified verifiers..




While China has set up a robust MRV programme under the seven ETS pilots, the sheer size of China’s national ETS and the number of potential companies and installations that will be included will prove to be a challenge in scaling-up MRV across the country. It could take several years for the MRV process in China to be reliable enough for the government to move away from free allocation to auctioning and this could also delay any subsequent policy discussions on linkage with other ETSs.


In addition China’s national ETS starts at the firm level. The main consideration is that the smallest unit in China’s current energy statistical system is the firm, and CO2 emissions are largely determined from energy data. Thus, data collection at the firm level is the most convenient method of starting an ETS for China. Under this method, the accuracy of emissions measurements relies heavily on the accuracy of energy data.



Under the ETS pilots, compliance has been enforced at the local level. This has allowed for the operators to negotiate their free allocation relatively easily . Under a national ETS, there will be less flexibility for local DRCs to negotiate free allocation for operators and enforce compliance.


The administrative burden of enforcing compliance will fall on the NDRC and this could pose challenges in the future where the total number of operators is much greater than currently in the ETS pilots. Such challenges largely involve expanding the institutional and staffing arrangements for the NDRC’s Climate Change Department.

Two-step penalties are enforced in case of non-compliance:


1) Requirement to reduce 1.3 times the shortfall

2) Fine (up to JP¥ 500,000), publication of the breach, and surcharge proportional to the shortage.




The penalty for non-compliance with the KETS is an administrative fine not exceeding three times the average market price per unit of tCO2e for that year. The maximum penalty is KRW 100,000 per tCO2e, or approximately US $91 per tCO2e.




There is a big question mark regarding the penalties to be imposed in the future under the China nationwide ETS system. It is too early to decide whether penalties are considered as pro or anti-linkage. We would need to see NRDC’s proposed measures before making any conclusion.


Following the adoption of the Paris Agreement expectations have been growing regarding international cooperation in the field of climate change, including ETSs. Putting aside political readiness[32] of China, Japan and Korea, and looking at technical readiness of those countries’ ETSs only it can be concluded from this study that they share in common some of the vital ETSs’ elements and approaches making the potential linkage between their ETS less hypothetical than it first appears. In the next few months, the development of China nationwide ETS will either enhance the chances of linkage with Korea and Japan or not.



[1] Paris Agreement On Climate Change 2015 – Available At Https://Unfccc.Int/Process-And-Meetings/The-Paris-Agreement/The-Paris-Agreement

[2] BARAN DODA Barriers To Linking Carbon Markets In Northeast Asia, ASIA SOCIETY POLICY INSTITUTE CARBON MARKET COOPERATION IN NORTHEAST ASIA, June 2018. Joojin Kim Key Issues for the Korean Emissions Trading Scheme and their Implications for International Linkage Discussions in Northeast Asia, International Cooperation In East Asia To Address Climate Change, Harvard Project on Climate Agreements February 2018.

[3] Shaozhou Qi & Si Cheng (2018): China’s National Emissions Trading Scheme:

Integrating Cap, Coverage And Allocation, Climate Policy, Available At Https://Doi.Org/10.1080/14693062.2017.1415198

[4] South Korea’s Cabinet Approves ETS Allocation Plan, 2030 GHG Roadmap, https://Carbon-Pulse.Com/55985/

[5] Yu LIU, Shenghao FENG, Songfeng CAI, Yaxiong ZHANG, Xiang ZHOU, Yanbin CHEN, Zhanming CHEN Carbon Emission Trading System Of China: A Linked Market Vs. Separated Markets, Earth Sci. 2013, 7(4): 465–479.

 William. A. Pizer and Xiliang Zhang, China’s New National Carbon Market Nicholas Institute for Environmental Policy Solutions, January 2018.

[6] Toshi H. Arimura, The Potential of Carbon Market Linkage between Japan and China

Asia Society Policy Institute Carbon Market Cooperation in Northeast Asia, , June 2018.

[7] Map can be downloaded from

[8] Act on the Allocation and Trading of Greenhouse Gas Emission Permits 11419 of May 11, 2012. The Act is available at

[9] Jeff Swartz & Stefano De Clara Republic of Korea  “The World’s Carbon Markets: A Case Study Guide for Practitioners”,  IETA, Climate Challenges Market Solutions. International Carbon Action Partnership ETS Detailed Information, Korea Emissions Trading Scheme, International Carbon Action Partnership, March 2018. Korea ETS,  International Carbon Action Partnership, ETS detailed Information, March 2018,  available at

[10] Jaeseok Lee and Jongmin Yu Market Analysis during the First Year of Korea Emission Trading Scheme, Energies 2017, 10, 1974.

[11] Data collected from online platform Carbon Pricing Dashboard, World Bank

[12] The document is available at

And for a brief analysis

[13] Yifei Zhang, Jonathan Harris, and Jin Li China’s Carbon Market:  Accelerating a Green Economy in China and Reducing Global Emissions

April 2018, GDAE Working Paper No. 18-01: China’s Carbon Market.

[14] A full version of the plan is available at  or at 2011China12thFiveYearPlanonNationalEconomicandSocialDevelopment-Chinese.pdf?attredirects=0&d=1. 2 “Key targets of China's 12th five-year plan,” Xinhua, March 5, 2011.

[15] The NDRC released the official document Guidelines of its ETS construction, which was approved by the State Council. The document available at  tells the guiding principles and steps of China’s national ETS construction.

[16] Jeff Swartz CHINA: An Emission Trading Case Study, September 2016, Climate Challenges Market Solution.

[17] International Carbon Action Partnership press release in English

 Kimfeng Wong, China Earns Plaudits Despite ‘Soft’ ETS Launch, EI New Energy, Volume 6, No. 51, December 21, 2017

[18] Emily Feng, China Moves Towards Launch of Carbon Trading Scheme, Financial Times, December 19, 2017.

[19] China, International Carbon Action Partnership, ETS detailed information, March 9, 2018. Available at[]=55

[20] Japan - Tokyo Cap-and-Trade Program International Carbon Action Partnership ETS Detailed Information, March 9, 2018, available at[]=51  

[21] Masayo Wakabayashi. Osamu Kimura The impact of the Tokyo Metropolitan Emissions Trading Scheme on reducing greenhouse gas emissions: findings from a facility-based study, Climate Policy, Volume 18, 2018, Issue 8.

[22] Office of Market Mechanisms Ministry of the Environment of Japan, Consideration of Emissions Trading Scheme in Japan, April 2012,

[23] Emissions Trading Worldwide International Carbon Action Partnership (ICAP) Status Report 2017, available at

[24] Japan: An Emissions Trading Case Study, The World’s Carbon Markets: A Case Study Guide to Emissions Trading Last Updated: May, 2015








[32] Jess Swartz, Building the Foundation for Regional Carbon Market Linkage in Northeast Asia, Asia Society Policy Institute Carbon Market Cooperation in Northeast Asia, , June 2018.