(1) Imperfect laws and regulations support system, immature trading system design
China's emissions trading market lacks a fundamental guiding law and a unified trading system. The “Guiding Opinions on Further Promoting the Paid Use of Emission Rights and Trading Pilot Work” issued by the General Office of the State Council on August 6, 2014 is a departmental regulation. Although it is generally binding, it has no legal effect. The country also has no uniform regulations on specific trading system design, market management methods, and quota allocation methods.
Due to the lack of guidance and unified supervision at the national level, there are large differences in the formulation of management methods among local pilots, and there are large differences in the definition of pollutant indicators, guide prices, and transaction scope. The problem of "one place, one system" has caused the fairness of emissions trading to be questioned.
(2) The pricing method is not uniform, and the secondary market is not active
At present, various regions have set their own methods for allocating paid allocation of quotas and pricing methods. Many places have published guidance prices for major pollutants. However, these guidance prices vary greatly from region to region, and they often do not reflect the scarcity of environmental capacity. For example, the guide price of sulfur dioxide emission rights in Shanxi is 18,000 yuan / ton, and the emission index is valid for a long time, while the Chongqing emission index is valid for 1 year, and the annual clearance and verification, the price is about 1,000 yuan / ton.
Existing emission rights trading is usually divided into primary and secondary markets. The former is carried out between the government and enterprises, such as the initial allocation of emission rights, government repurchases, etc. The latter is the quota trading between enterprises. The pilot situation shows that about two-thirds of the pilot regions in Inner Mongolia and Zhejiang have experienced “faults” in the secondary market transaction records of varying degrees. Some regions have not even had a transaction volume for several months. The secondary market transactions are not active, reflecting Most outgoing enterprises are involved in trading in order to meet their own emissions needs. Generally, they only participate in the primary market and purchase emission indicators from the government. They lack awareness and enthusiasm for inter-enterprise quota trading.
(3) Insufficient implementation of the connection with the sewage permit system
In recent years, China has vigorously promoted the permit system for pollutants discharge and implemented "one certificate management" for various pollutants. Theoretically, the emission permit system is a prerequisite for emission rights trading. The government allocates emission rights to relevant polluting companies by issuing emission permits, and the enterprises conduct emission rights trading based on the expected emissions. However, in actual operation, the emission rights trading started earlier, and the provinces formulated trading systems and management methods according to their own circumstances; while the emission permit system was clarified in the revised Environmental Protection Law in 2014, and the system was vigorously developed after 2016 Construction and specific implementation. At present, there are many areas in the implementation level where the two have not yet achieved a good connection, mainly reflected in the three aspects of pollution indicators, work scope and duration.
(4) There is overlap with the environmental protection tax
On January 1, 2018, China formally implemented an environmental protection tax. According to the Environmental Protection Tax Law of the People's Republic of China, the environmental protection tax is levied on air pollutants, water pollutants, solid waste and noise. The types of pollutants involved in the trading of emission rights are mainly chemical oxygen demand, ammonia nitrogen, sulfur dioxide, and nitrogen oxides, which coincide with the taxable pollutants stipulated in the environmental protection tax, and the scope stipulated in the environmental protection tax is wider. For the same pollutant, emission rights trading and environmental protection taxes are marketable tools that can be replaced by each other. Emissions trading is a quantity-based tool, cut in by quantity control, and environmental tax is a price-based tool, based on emissions. Cutting in from the perspective of cost can achieve the purpose of controlling and controlling the discharge of pollutants. Therefore, the collection of environmental taxes will compress the emissions trading market. For the controlled enterprise, on the one hand, it is necessary to consider the total amount control, on the other hand, it must also consider the possible taxes and fees, which will increase the burden on the enterprise.
