Expert Interpretation of the "Technical Guidelines for Enterprise Greenhouse Gas Emission Verification in the Steel Industry"

The "Enterprise Greenhouse Gas Emission Accounting and Reporting Guidelines for the Steel Industry" (hereinafter referred to as the "Accounting Guidelines") guide key emission units in the steel industry to account for and report related emission data and information. The "Verification Guidelines" provide detailed verification requirements for the basic situation of key emission units in the steel industry, accounting boundaries and emission sources, accounting methods, accounting data, data quality control plans, and implementation. For key parameters at the enterprise and process levels, the guidelines specify verification methods such as "check, ask, observe, and verify," along with precautions. Some key parameters also have reasonable value ranges or empirical values. Key verification points and methods are marked with "*", while other unmarked verification items are determined by the verification team based on document review results, the actual situation of key emission units, or experience judgment to decide the specific content and detail level of checking, asking, observing, and verifying. This approach improves verification efficiency and avoids inconsistent understanding and standards among different verification agencies regarding the "Accounting Guidelines."

The "Accounting Guidelines" distinguish between enterprise-level emissions and process-level emissions. Correspondingly, the "Verification Guidelines" propose different verification requirements for key parameters at the enterprise and process levels. The "Accounting Guidelines" clearly stipulate that the consumption of solid fuels by key emission units should be based on the received basis. Therefore, the "Verification Guidelines" specify verification requirements to confirm whether coal consumption data is based on the received basis to improve data authenticity and accuracy and reduce data quality risks. For cases where it is impossible to provide coal consumption data at the enterprise level on a received basis or coal input at the process level, abnormal data must be handled conservatively. If non-received basis data is found during verification, it must be reported to the provincial ecological environment authority through the verification report or other means.

Crude steel output is one of the key parameters for calculating greenhouse gas emission intensity and quota allocation in the steel industry. The "Accounting Guidelines" specify detailed requirements for measuring crude steel output. Correspondingly, the "Verification Guidelines" provide detailed verification requirements for crude steel output, including verification methods for continuous casting billet and mold cast ingot output data obtained by theoretical calculation. The verification team is required to cross-check data such as enterprise crude steel sales volume, crude steel inventory, and steel product output from rolling processes converted by yield rate to ensure the authenticity and accuracy of crude steel output data.

Additionally, the "Verification Guidelines" require verification agencies to make technical judgments on the rationality of key parameter values. For obviously abnormal data, non-conformities should be issued and reported to the provincial ecological environment authority, along with relevant explanatory materials, serving as a focus for the authority's data quality risk control.

Unlike the power generation, cement, and aluminum smelting industries, the steel industry produces, consumes, and externally supplies secondary energy such as coke and blast furnace gas/coke oven gas/convertor gas. Steel enterprises may also purchase coke and blast furnace gas/coke oven gas/convertor gas externally. These secondary energies at the enterprise level are easily confused with primary energy in accounting. Internal consumption of secondary energy is not accounted for; only externally sold secondary energy is accounted. The "Verification Guidelines" separately provide verification methods for the purchase (sale) volume of blast furnace gas/coke oven gas/convertor gas at the enterprise boundary and input/output volumes at the process level, clearly distinguishing them from the verification methods for primary energy such as coal.

Many steel enterprises use adjusted energy consumption data from energy balance sheets for each process instead of metered data to report energy consumption. This issue is easily overlooked by verification agencies. The "Verification Guidelines" specifically point out that if key emission units have directly metered data available but choose other data acquisition methods, the verification team should issue non-conformities (for sintering and ironmaking processes, key emission units are also required to revise their data quality control plans). If key emission units lack metering instruments or the instruments do not meet requirements, the verification team should issue non-conformities (for processes other than sintering and ironmaking, key emission units are also required to adopt conservative data missing methods) and equip compliant metering instruments. These non-conformities do not need to be closed during the current verification but require verification of corrective actions in the next verification.

The data quality control plan is an important basis for key emission units to carry out data and information evidence preservation, inspection and testing, emission accounting and reporting, emission report verification, and data quality supervision and inspection. It is the "guiding line" for the entire carbon emission data quality management. Article 11 of the "Interim Regulations on Carbon Emission Rights Trading Management" clearly stipulates that "key emission units shall take effective measures to control greenhouse gas emissions, formulate and strictly implement greenhouse gas emission data quality control plans in accordance with relevant national regulations and technical specifications formulated by the ecological environment authority of the State Council."

The "Verification Guidelines" emphasize in the verification requirements for each parameter that the data quality control plan should first be reviewed to understand the specific data acquisition methods related to the parameters, confirming that the data acquisition methods in the emission report are consistent with it; then, corresponding verification steps and methods are proposed for different data acquisition methods. This verification guideline strengthens the role of the data quality control plan, which on one hand can effectively improve verification efficiency, and on the other hand can effectively promote key emission units to genuinely implement their established data quality control systems and continuously optimize and improve them.

Overall, the "Verification Guidelines" provide a highly normative and operable guiding document for greenhouse gas emission verification in the steel industry. By following this guideline, the accuracy of carbon emission data in the steel industry can be ensured, laying a solid foundation for the smooth expansion and healthy operation of the national carbon emission rights trading market.