Sans Carbon publishes open analyses of Taiwan’s carbon removal policy framework, of its carbon fee and emissions trading system, and of the international corporate climate rules that shape demand for carbon removal. Everything on this page is released under a Creative Commons Attribution 4.0 International licence (CC BY 4.0). You are welcome to quote, translate, adapt and redistribute it — including in government documents and commercially — provided you credit the author, name the document and link to the source.
All three reports are written in Traditional Chinese and carry English abstracts. This page summarises their findings in English.
The gaps sit at three levels and cannot substitute for one another. Taiwan's NDC 3.0 sets a 2035 reduction target but does not disaggregate removals into a separate quantified commitment. Every approved or pending removal methodology addresses natural sinks; engineered and material-based removals are entirely absent. The verification regime recognises organisational, project and product-footprint categories, with no removal category capable of handling permanence monitoring, reversal risk or the termination of monitoring obligations.
The EU framework is closed to Taiwan by legal design, not by timing. Quality criteria apply only to activities carried out within the Union; all units count toward the EU's own NDC and may not be counted toward a third country's; and at methodology level, biochar production facilities and storage locations must both be located within the Union. Waiting does not eventually yield a transplantable framework — it yields a framework that stays closed.
The legal threshold for action is substantially lower than commonly assumed. Of six recommendations, five require no legislative amendment: a removal verification category can be created by administrative notice under an existing catch-all provision, and engineered removal methodologies fall squarely within the competent authority's existing approval powers. Only one — excluding removal units from carbon fee offsetting — requires amending subordinate legislation. None requires amending the parent act. The obstacle is priority, not authority.
Durability thresholds are policy choices, not scientific constants. Across six major biochar standards, H/Corg thresholds differ by a factor of 1.75 and assessment horizons by an order of magnitude, while the underlying literature is largely shared. Taiwan should therefore choose rather than wait, prioritising international compatibility, and should invest in the two gaps common to every existing standard: decay parameters calibrated for high-temperature soils, and models for non-soil applications.
Back-casting from a 2030 target for first issuance of removal units, methodology work had to begin in the second half of 2026.
Cite as
Chiu, M.-C. (2026). Certifying carbon removal in Taiwan: Benchmarking the EU CRCF and the case for an independent certification framework (v1.1). Zenodo. https://doi.org/10.5281/zenodo.21618472
Version 1.0 · 2026 · twenty-four chapters and eight appendices · CC BY 4.0
Fulfilling Ongoing Emissions Responsibility
An Analysis of the OER Framework under the SBTi Corporate Net-Zero Standard V2.0 and Its Implications for Taiwan
The OER recognition programme does not require carbon removals. Eligible verified mitigation outcomes include value-chain-external reductions and the restoration of natural sinks, and contribution budgets may fund research, adaptation or loss and damage. Mandatory removals appear only in the post-2035 requirement, which the standard itself labels illustrative, and in net-zero neutralisation.
The 2035 long-lived removal quota is far smaller than commonly reported. The denominator in C45.4 is covered emissions attributable to long-lived GHGs — not total ongoing emissions. Combined with the 1% coverage level set for 2035, the minimum obligation is on the order of one thousandth of ongoing scope 1–3 emissions. The burden is in the slope, not the starting point: two linear ramps multiply into quadratic growth, so a company at ninety tonnes in 2035 reaches ninety thousand by 2050.
Buying now to hold for 2035 does not work. Read together, three criteria foreclose it: outcomes already used for OER cannot be reused for post-2035 or net-zero requirements; eligible outcomes must have occurred within five years of the reporting year; and qualifying removals must be delivered within the same reporting period as the emissions they cover. The constraint is shelf life, not price.
For Taiwan, three institutional facts converge. Taiwan is classified as a high-income economy and is therefore subject to the standalone 10,000 tCO₂e scope 1–2 trigger for Category A — below the 25,000 tCO₂e threshold of the domestic carbon fee, so the standard reaches further than the fee does. Unit prices are comparable while aggregate obligations are not: the Advanced contribution budget of US$20/t converts to roughly NT$637, below the rate committee's NT$1,200–1,800 benchmark for the post-2030 general rate, but OER is calculated on five-year cumulative scope 1–3 emissions with no exemption threshold. And Taiwan's voluntary reduction methodologies contain no durable removal category, so no qualifying domestic supply exists — an absence of classification rather than of capacity.
Responsibility travels down the supply chain. A company may share scope 3 coverage responsibility with a value-chain partner that reports the same emissions, provided at least one party explicitly assumes it and a written agreement is filed. The only condition the text places on the assuming party is that it reports the same emissions — it need not participate in the recognition programme, hold a validated target, or maintain a full annual scope 3 inventory. A Taiwanese supplier that has never engaged with the SBTi can therefore receive a sharing request from 2027 onwards.
Cite as
Chiu, M.-C. (2026). Fulfilling ongoing emissions responsibility: An analysis of the OER framework under the SBTi Corporate Net-Zero Standard V2.0 and its implications for Taiwan (v1.0). Zenodo. https://doi.org/10.5281/zenodo.22869799
Version 1.0 · 2026 · eight chapters and six appendices · CC BY 4.0
Discipline in Effective Carbon Pricing
Commitments, Adjustments and Prices Actually Paid under Taiwan's Carbon Fee and ETS (2026 Baseline)
Taiwan began levying its carbon fee in 2025 and collected its first payments in 2026. The rules, rate-review records and approved self-reduction plans are public, but no record yet compares, over time, what the government committed to with what it subsequently did. This report provides that record for the carbon fee and for the forthcoming emissions trading system (ETS).
Key findings
Three forms of discipline can be tracked. Timing discipline asks whether dated commitments occur as stated; threshold discipline asks whether the conditions attached to discounts are enforced; direction discipline asks whether the net effect of simultaneous parameter changes matches the stated direction. An adjustment is legible when it states four things: its trigger, the prior rule it modifies, its expected effect, and its net effect on the effective carbon price.
A ledger of 31 commitments and adjustments, each tagged with source tier and specificity, shows three gaps. Long-term commitments in high-tier documents rarely carry dates. Public data stop at plan approval and do not yet cover compliance audits. And none of the six rule adjustments since the fee's launch quantifies its effect on the price actually paid.
Following the method of Canada's independent assessment of carbon pricing, the average effective rate in the first payment year is about NT$32.0–34.8 per tonne, roughly one-tenth of the NT$300 headline rate, and the emissions-weighted marginal rate is roughly NT$20–39. The discounts lower marginal and average prices alike, so abatement incentives rest mainly on whether self-reduction plan targets are enforced.
For covered firms, internal carbon prices and export-cost estimates should rest on the price actually paid. Under the European Commission's draft rules on carbon prices paid in third countries, a steel plant with high-leakage status would be able to claim about 0.76% of the second-quarter 2026 CBAM certificate price; the headline rate would suggest 11.3%.
Comparisons with Switzerland, the EU, Germany, Canada, Korea, Singapore, Japan and Sweden show how adjustments can be written into rules or documented so that they can be verified. The report closes with six checkpoints for Taiwan's ETS pilot plan and a list of data whose disclosure would make the record precise. The ledger is published with the report as a CSV file and will be updated annually.
Cite as
Chiu, M.-C. (2026). Discipline in effective carbon pricing: Commitments, adjustments and prices actually paid under Taiwan's carbon fee and ETS (2026 baseline) (v1.0). Zenodo. https://doi.org/10.5281/zenodo.23308221
Op-eds
Commentary published in outside media. Links go to the original publication.
Taiwan Environmental Information Center · · In Chinese
How the label "reduction credit" could leave Taiwan's million tonnes of 2030 carbon removal without buyers
Two agencies of Taiwan's environment ministry describe the same biochar programme in different terms: one as a carbon removal mechanism, the other as a reduction methodology issuing reduction credits. Issued as reduction credits, removals could be used to dilute emission-cutting obligations, and international buyers looking for genuine removals would stay away. Renaming the units and creating a separate removal category require no new legislation, and are easiest to do while the rules are still being written.
Frequently asked questions
What is Taiwan's current institutional position on carbon dioxide removal?
There isn't one. Removals have no quantified target at national level, no engineered or material-based methodologies, and no category in the verification regime. The methodologies that do exist — afforestation, forest and bamboo management, agricultural soil management — are all natural sinks.
Why can't Taiwan simply adopt the EU CRCF?
Because it is closed to non-EU activity by legal design. The quality criteria apply only to activities carried out within the Union, all resulting units are counted toward the EU's own NDC, and the biochar methodology requires production facilities and storage locations to be inside the Union. A Taiwanese project cannot be certified under it, and waiting will not change that.
Does the SBTi's Ongoing Emissions Responsibility require companies to buy carbon removals?
Not yet — but preparation starts now. The obligation begins in 2035: the post-2035 requirement (which the standard labels illustrative, to be reviewed at its next major revision) and neutralisation at the net-zero year both call for eligible carbon removals. Removals must be delivered within the same reporting period as the emissions they cover, much of the high-quality durable supply is already contracted to anchor buyers through 2028–2030, and forward purchases often take one to four years or more from contract to delivery. Procurement planning therefore has to work backward from the delivery date rather than start in 2035. Until then, removal is one of three parallel sources of eligible verified mitigation outcomes, and five of the six categories of climate action a contribution budget may fund have nothing to do with removal.
How large is the 2035 long-lived removal obligation in practice?
Small at the start, steep afterwards. The 2035 starting point is smaller than most commentary suggests, because the denominator is narrower than it is usually read to be: it is covered emissions attributable to long-lived GHGs, not total ongoing emissions, and in 2035 covered emissions are 1% of ongoing scope 1–3. For a typical manufacturer the 2035 minimum works out at roughly one thousandth of ongoing emissions. The trajectory afterwards is what matters: because two linear ramps multiply, the requirement grows quadratically to 2050 — and with durable supply contracted years ahead of delivery, that curve has to be planned for now, not in 2035.
Can removals be purchased now and banked for post-2035 use?
No — what can be built now is supplier relationships, not a position. Three criteria in the standard close the banking route: no double use of outcomes already applied to OER, a five-year look-back window on eligible outcomes, and same-period delivery for qualifying removals. Credits acquired today cannot be applied after 2035. Relationships do not expire: knowing suppliers' capacity and delivery record, and building up information on contract terms, remain useful whatever the rules become.
Who in Taiwan is affected — only companies with SBTi targets?
No, and this is the most common misreading. Two routes lead to exposure. A company may be in scope itself: Taiwan falls under the high-income pathway, where 10,000 tCO₂e of scope 1 and 2 emissions makes a company Category A regardless of revenue — a lower bar than the domestic carbon fee. Or its customers may be in scope, in which case the supplier's scope 1 is the brand's scope 3, and coverage responsibility can be shared by written agreement with no requirement that the supplier itself participate in the programme.
Is there any qualifying durable removal supply in Taiwan?
No. Taiwan's voluntary reduction methodologies contain no durable removal category, so there are no registrable long-lived removal projects and no qualifying units. Sourcing abroad runs into a different constraint: as of April 2026 a single buyer accounted for 78.5% of disclosed durable removal offtake, and most suppliers are contracted to anchor buyers through 2028–2030.
How much carbon fee do covered emitters in Taiwan actually pay per tonne?
About NT$32–35 on average in the first payment year — roughly one-tenth of the NT$300 headline rate. Three discounts account for the gap: the first 25,000 tonnes per facility are exempt; facilities meeting their self-reduction plan targets pay a preferential rate of NT$100 or NT$50; and facilities recognised as at high risk of carbon leakage are charged on only 20% of their emissions in the first period. Depending on category, each additional tonne costs between NT$10 and NT$300. High-leakage facilities, which account for about three-quarters of covered emissions, mostly pay NT$10–20 at the margin.
How much of Taiwan's carbon fee can be deducted under the EU CBAM?
Only the price actually paid. The European Commission's draft implementing rules treat any parameter that lowers the obligation to pay as compensation to be deducted, which covers the carbon fee's exemption threshold, preferential rates and leakage adjustment factor. For a high-leakage steel plant on preferential rate B, the price actually paid is NT$20 per tonne, about 0.76% of the second-quarter 2026 CBAM certificate price; the headline rate would suggest 11.3%. Claiming the deduction also requires facility-level proof of payment, attribution of embedded emissions from facility to product, and verification at reasonable assurance.
How does Taiwan's carbon fee compare with OER costs?
Unit prices are comparable; totals are not. The difference is the calculation base: the carbon fee is annual, has an exemption threshold, and covers direct emissions plus purchased electricity, while OER is calculated on five-year cumulative scope 1–3 emissions with no exemption. In a worked example of a mid-sized manufacturer, the Advanced-tier contribution budget runs roughly 8.5 times the annual carbon fee. Estimating OER costs from carbon fee figures understates them by at least an order of magnitude.
May I quote, translate or reuse this work?
Yes. All three reports and everything on this page are released under CC BY 4.0. Government bodies, researchers, journalists and companies may quote, translate, adapt and redistribute the material, including commercially, without seeking permission — please credit the author, name the document and link to the source. Suggested citations are given above.
Also available in Chinese
Two-page policy briefs summarising each report, a serialised commentary blog, an OER cost estimation tool, and a sixteen-slide presentation deck on the 2035 demand timeline and Taiwan’s supply gap. All are in Traditional Chinese and are listed on the Chinese version of this page.
The presentation deck is released under CC BY 4.0 and may be reused or adapted in internal briefings, training and public talks.
He holds an M.S. in Environmental Engineering from National Taiwan University, completed doctoral candidacy at the Hong Kong Polytechnic University, and is a certified Project Management Professional. He has worked in carbon markets since 2019, across corporate GHG inventory and ESG disclosure in manufacturing, carbon market project development, and carbon removal methodology and MRV.
Competing interests
Sans Carbon works in carbon removal supply and is not a neutral party on these questions — the company benefits commercially if institutional demand for removals grows. All sources cited are public, and recommendations do not favour any particular technology or operator.
Discipline in Effective Carbon Pricing adds two further constraints: it takes no position on what rates, adjustment factors or allocation shares should be, and it does not assess the substance of any individual rule adjustment. A stronger overall carbon price signal generally strengthens incentives for abatement and removal, from which the company benefits indirectly.
Versions
All three reports carry versioned DOIs. If any report is substantively revised, a new version will be issued, the previous version retained, and this page updated accordingly.
Discipline in Effective Carbon Pricing is a baseline-year edition. It will be updated annually using the same ledger and the same method, and a v1.1 will compare Taiwan's ETS pilot plan against the report's six checkpoints once the draft is published.