中国实现环境完整的二氧化碳地质封存的政策建议

POLICY RECOMMENDATIONS FORACHIEVING CO2 GEOLOGICALSTORAGE WITH ENVIRONMENTALINTEGRITY IN CHINA JANUARY 2026 CONTENTS Executive summary41.0.Introduction61.1 Overview of China’s progress on CCUS61.2 Environmental integrity is central to CO2 geological storage regulations61.3 Purpose of this report72.0.Global Review82.1 The US and EU’s approaches to regulate CO2 geological storage92.2 Technical recommendations103.0.China review163.1 China’s existing environmental legal and regulatory frameworkfor CO₂ geological storage163.2 Case studies of CO₂ geological storage projects in China174.0.A proposed pathway for effectively regulating China’s CO2geological storage activities194.1 Lessons from international approaches194.2 Recommendations for the overall framework214.3 Recommendations for specific areas225.0 Conclusion236.0.References247.0.Appendix 125 Weare grateful for the numerouscontributionsto this report,includingthe peer review provided by multipleexternal experts. Wealso appreciate the internal peerreviewsprovided by Poh Boon Ung,IanHavercroft,and Anhar Karimjee.Furthermore,we are thankful to oureditor,Wendy Wells,for her valuablesuggestions that significantly enhancedthe manuscript. XIAOLIANG YANG,Global CCS InstituteSHUANGXING LIU,CNPC Research Institute of Safety and Environmental TechnologyMING XUE,CNPC Research Institute of Safety and Environmental Technology EXECUTIVE SUMMARY CarbonCapture,Utilisation,and Storage(CCUS)ispoised to become a major pillar of China’s strategyto achieve carbon neutrality before 2060. Since thenation’s climate pledge in 2020, CCUS has garneredsignificantattention from policymakers and industryleaders.National initiatives such as the“2023ImplementationPlan for Green and Low-CarbonTechnology Demonstration” and the “2024 Action PlantoReduce Coal Emissions”have formally integratedCCUS,leading to increased governmental support.Noteworthydevelopments include the operation ofChina’s first integrated megatonne-scale CCUS projectin2022,the commissioning of the world’s largestcement-sectoroxyfuel CCUS facility in 2024,and agrowing portfolio of large-scale capture and storageprojects across both power and industrial sectors. Thereport distills key technical and environmentalrequirements from international models across the fullproject lifecycle, including CO₂ stream characterisation,siteselectionandmodelling,wellconstruction,monitoring, closure, emergency response, and financialassurance. While China currently lacks a unified legal frameworkforgeological storage,its existing environmentallawsand decades of experience in environmentalprotection provide a solid foundation. These includetheEnvironmental Protection Law(1989,amended2014), the Water Pollution Prevention and Control Law(1984,amended 2008 and 2017),the EnvironmentalImpact Assessment Law (2002, amended 2018), and theMineral Resources Law (1986, amended 2020). Theselaws mandate Environmental Impact Assessments (EIAs),public consultation, and risk management. Despite this momentum, China’s geological CO₂ storageefforts remain in the early stages, with a comprehensiveregulatoryframework still under development.Keycomponents such as site selection, risk assessment,long-term liability, and environmental monitoring requiremoredetailed guidelines.Ensuring environmentalintegrity is paramount; a robust regulatory frameworkmust guarantee the safe and permanent containmentof CO₂ while safeguarding groundwater, ecosystems,and public health. Well-designed regulations not onlymitigaterisks like leakage or pressure interferencebut also bolster public confidence in CCUS as a viableclimate solution. Concurrently,China is drafting national standardsgroundedin ISO models,such as the GeologicalStorage Standard (based on ISO 27914:2017) and theEORStorage Standard(based on ISO 27916:2019).Once finalised, these standards aim to guide projectdeveloperson critical aspects like site selection,injection operations, risk management, and monitoring,aligningdomestic practices with international bestpractices. More specifically, the report calls for: •Developing enforceable standards for CO₂ stream composition that align with international norms.•Accelerating the adoption of ISO standards to the national context, creating specific guidelines for site selection.This should encompass fault mapping, area of review (AoR) modelling, and the identification of potential leakagepathways to ensure comprehensive site characterisation.•Developing robust monitoring strategies that cover the entire lifecycle of CO₂ storage projects.•Establishing clear protocols for risk assessment and incident response. This framework should include measuresfor managing seismic risks, conducting routine training exercises, and setting requirements for post-injectionmonitoring to maintain environmental safety and track containment. To facilitate the commercial deployment of geologicalCO₂storage,this report recommends that Chinaestablishdedicated regulations or integrate stor