Research & Publications

SansCarbon publishes open analyses of Taiwan’s carbon removal policy framework and of the international corporate climate rules that shape demand for it. 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.

Both reports are written in Traditional Chinese and carry English abstracts. This page summarises their findings in English.

Last updated: 2026-09-22

Publications

Version 1.1 · 2026 · six chapters and appendices · CC BY 4.0

Certifying Carbon Removal in Taiwan

Benchmarking the EU CRCF and the Case for an Independent Certification Framework

DOI: https://doi.org/10.5281/zenodo.21618472

Key findings

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

DOI: https://doi.org/10.5281/zenodo.22869799

Key findings

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

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 at present. Eligible verified mitigation outcomes come from three parallel sources, of which removal is one; and of the six categories of climate action a contribution budget may fund, five have nothing to do with removal. Mandatory removals appear only in the post-2035 requirement — which the standard labels illustrative and will review in its next major revision — and in neutralisation at the net-zero year.

How large is the 2035 long-lived removal obligation in practice?

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.

Can removals be purchased now and banked for post-2035 use?

No. Three criteria in the standard close that 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.

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 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. Both 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.

About the author

Ming-Cheng Chiu

Co-founder, SansCarbon Co., Ltd.. ORCID: 0009-0006-8418-0679

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

SansCarbon 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.

Versions

If either report is substantively revised, a new version will be issued, the previous version retained, and this page updated accordingly.

Contact

Ming-Cheng Chiu mingcheng@sanscarbon.earth