New Regulations by the Ministry of Environment:Expansion of Mandatory GHG Inventory Coverage — Enterprises Required to Conduct and Register Greenhouse Gas Emissions

Chapter 1 .Policy Background and Rationale for Expanding the Scope of Covered Entities by the Ministry of Environment

1.1 Global Climate Change Trends and Taiwan’s Carbon Reduction Commitments

In response to the escalating risks posed by climate change, the global community is progressively advancing toward the sustainable development goal of Net-Zero Emissions. Under the Paris Agreement, countries have committed to jointly limiting the increase in global average temperature to within 1.5°C above pre-industrial levels, and to achieving net-zero greenhouse gas emissions within this century. The European Union, the United States, Japan, and South Korea have all pledged to reach net-zero emissions by 2050, while China has set a target of achieving carbon neutrality by 2060.

As an integral part of the global economic and trade system, Taiwan has also committed to achieving net-zero emissions by 2050. In support of this objective, the Executive Yuan approved the “Taiwan’s Pathway to Net-Zero Emissions by 2050 and Strategic Framework” in 2022, identifying energy transition, industrial transformation, and the establishment of carbon governance mechanisms as the three core pillars. Furthermore, the passage of the Climate Change Response Act in 2023 has provided a strengthened legal foundation for the government to advance greenhouse gas management policies.

Under the accelerating net-zero transition, enterprises face not only heightened operational risks but also significant transformation opportunities. Establishing a comprehensive greenhouse gas inventory system represents the first critical step for enterprises to enter the core of carbon governance.

1.2 Legislative Basis and Policy Objectives for the Ministry of Environment’s Expansion of Mandatory GHG Inventory Requirements

Pursuant to Article 21 of the Climate Change Response Act, the Ministry of Environment is authorized to designate businesses above a specified scale to conduct greenhouse gas (GHG) emissions inventories and registration of their emission sources. To support the enhancement of Taiwan’s 2030 phased greenhouse gas reduction targets, the Ministry of Environment announced in March 2025 the expansion of emission sources subject to mandatory GHG inventory and registration requirements.

This policy expands the existing scope of regulated entities to cover a wider range of sectors, including service industries, healthcare, transportation, universities and colleges, as well as small and medium-sized manufacturing enterprises, thereby extending GHG management beyond traditional high-emitting industries.

Clearly Defined Objectives of the Expanded GHG Inventory Policy

The objectives of this expansion are as follows:

1. To strengthen the government’s understanding of greenhouse gas emissions across multiple sectors;

2. To enhance the data foundation for formulating sectoral energy efficiency and carbon reduction policies;

3. To establish baseline data for future carbon pricing mechanisms and emissions trading systems;

4. To promote departmentalized accountability for emissions management and reinforce cross-sector governance coordination.

By incorporating high electricity-consuming and energy-intensive non-industrial sectors into the inventory framework, the Ministry of Environment aims to advance a governance logic of “inventory-driven emissions reduction.” This approach ensures that emissions data are no longer exclusive to a limited number of energy-intensive industries, but instead serve as the starting point for society-wide shared responsibility for decarbonization.

1.3 Policy Implications of the “Three No’s and One No-Carbon-Fee” Principle

To mitigate resistance and administrative burden for newly regulated enterprises, the Ministry of Environment has explicitly emphasized the adoption of the “Three No’s and One No-Carbon-Fee” principle in this policy announcement, which includes the following elements:

1. No Additional Administrative Burden

The GHG inventory and registration process will be designed as a fully online, self-service system, with integration of Taiwan Power Company (Taipower) electricity consumption data. Enterprises will not be required to repeatedly submit duplicate or redundant data.

2. No Mandatory Outsourcing

Enterprises may complete the inventory and registration procedures independently by following official guidelines. There is no requirement to engage external consultants, thereby avoiding unnecessary additional costs.

3. No Mandatory Third-Party Verification

Unlike large-scale manufacturing industries that require professional third-party verification of inventory results, entities newly included under this announcement are not required to undergo third-party verification, significantly simplifying compliance procedures.

4. No Immediate Carbon Fee Obligation

At this stage, the policy focuses solely on establishing baseline emissions data and disclosure mechanisms. It does not involve the collection of carbon fees, nor does it immediately classify regulated entities as subjects of carbon pricing or carbon fee schemes.

The design of this principle demonstrates the flexibility and inclusiveness of the policy transition, helping enterprises develop awareness and capacity for carbon emissions data management, while gradually preparing them for future, more stringent carbon pricing and emissions trading policies.

Chapter 2  Detailed Explanation of Newly Regulated Entities

2.1 Overview of Newly Included Industries and Sectors

To expand the scope of greenhouse gas (GHG) emissions oversight in Taiwan, the Ministry of Environment announced in March 2025 the “Emission Sources Subject to GHG Inventory Registration by Business Entities.” This announcement extends the carbon inventory framework—previously focused primarily on high energy-intensive manufacturing industries—to a broader range of economic activities.

The newly regulated entities covered by this expansion fall into six major categories, namely:
(1) information services and commercial retail sectors

(2) universities and colleges 

(3) hospitality industry

(4) medical institutions

(5) automotive transportation services 

(6) small and medium-sized manufacturing enterprises.

Although these sectors are not traditionally classified as energy-intensive industries, they are characterized by high aggregate electricity consumption, numerous operational sites, and diverse mobile emission sources, which collectively exert a significant impact on Taiwan’s overall greenhouse gas emissions.

According to estimates by the Ministry of Environment, this expansion is expected to bring approximately 500 additional business entities into the inventory and registration system. For example, information service providers, department stores, shopping malls, and mass retail outlets typically operate large centralized building spaces with year-round air-conditioning and lighting demands, resulting in high electricity consumption and carbon emissions. Universities and colleges are long-hour operational entities, often equipped with laboratories and multiple teaching facilities, making their overall energy loads substantial. Meanwhile, hotels and hospitals operate continuously throughout the year, with stable yet highly concentrated energy demand; the electricity consumption of a single facility can often exceed one million kilowatt-hours annually.

The automotive transportation sector is classified as a typical category of mobile emission sources due to its large number of operating vehicles and intensive fuel consumption. Under the announcement, highway passenger transport, urban public transport, tour bus operators, and freight transport companies are required to be included in the GHG inventory system, particularly those operating more than 200 vehicles. Although emissions from these enterprises are geographically dispersed across vehicle fleets, their aggregate emissions are substantial and relatively traceable, making them well-suited for regulatory oversight.

For small and medium-sized manufacturing enterprises, entities whose energy consumption reaches specified thresholds—such as annual coal consumption of 4,000 metric tons or fuel oil consumption of 3,200 kiloliters—are likewise required to complete inventory registration in accordance with the provisions of this announcement.

Notably, the government’s regulatory focus extends beyond individual business entities to encompass corporate groups and parent companies, emphasizing their overall management responsibility for subordinate units. Where a parent company or university system operates multiple stores, branch campuses, or operational sites, it is required to conduct unified inventory registration across all locations. This arrangement reflects the policy’s emphasis on systematic carbon management, encouraging enterprises to establish consistent, cross-site greenhouse gas governance frameworks.

Overall, the selection logic underpinning this expansion of regulated entities does not rely solely on traditional industrial classifications. Instead, it is based on risk prioritization derived from actual energy use patterns and operational characteristics. This energy-intensity-based, sectoral stratification approach enables a more accurate understanding of Taiwan’s economy-wide emissions structure and provides a robust data foundation for the future implementation of carbon pricing mechanisms and emissions trading systems.

For enterprises, this expansion represents both a regulatory challenge and an opportunity—serving as a gateway to structured carbon management practices and a pathway toward enhanced long-term sustainability and competitive advantage.

2.2 Sector-Specific Inclusion Thresholds and Determination Criteria

In this expanded regulatory announcement, the Ministry of Environment has established clear and specific inclusion thresholds for different types of business entities, serving as the basis for determining whether an entity is required to conduct and register a greenhouse gas (GHG) emissions inventory. These thresholds are primarily defined using quantifiable indicators, such as scale of energy consumption and operational scale, with the objective of precisely targeting enterprises and institutions with higher potential emissions, thereby enhancing both the policy effectiveness and fairness of the inventory system.

First, for electricity-intensive service sectors and facility-based entities—including information services, department stores, shopping malls, mass retailers, railways and MRT systems, and universities and colleges—the inclusion thresholds are defined under two alternative conditions:

1. Total annual purchased electricity consumption of the enterprise exceeds 20 million kWh; or

2. Annual purchased electricity consumption at a single operating site exceeds 10 million kWh.

These criteria reflect the government’s focus on carbon risk associated with electricity-intensive, long-operating facilities. Examples include large-scale data centers, MRT electromechanical facilities, and central air-conditioning and laboratory equipment in universities, where electricity consumption constitutes the dominant share of operational carbon footprints. Electricity data therefore provides an effective basis for estimating indirect emissions (Scope 2).

Second, for chain retail and telecommunications sectors with a large number of outlets—such as convenience stores, supermarkets, and telecom service providers—the inclusion criteria are as follows:

1. A combined total of 100 or more directly operated and franchised outlets.

This standard accounts for the multiplicative effect of site density and aggregate operational energy consumption. Even if individual outlets have relatively low energy use, the cumulative emissions from a large number of dispersed locations can be substantial. Moreover, such business models demonstrate strong feasibility for centralized data collection and group-level management.

For medical institutions, the scope of inclusion is limited to:
(content to be continued as specified in subsequent sections of the announcement).

2. Hospitals Accredited as “Medical Centers” by the Ministry of Health and Welfare

Hospitals accredited as medical centers by the Ministry of Health and Welfare are typically large in scale and equipped with energy-intensive medical facilities and 24-hour operating systems. A single hospital campus may exceed 10 million kWh of annual electricity consumption, classifying such institutions as typical energy-intensive non-industrial entities.

Transportation Sector

In the transportation sector, the regulated entities include intercity highway passenger transport, urban bus services, tour bus operators, and freight transport operators. The inclusion criterion is as follows:

1. A total of 200 or more vehicles used for business operations.

As vehicles directly combust diesel or gasoline, their emissions fall under Scope 1 (direct emissions). Accordingly, the total number of vehicles serves as a key quantitative indicator for regulatory determination. This threshold is designed to be simple and practical, enabling competent authorities to rapidly identify fleets with high emissions.

Small and Medium-Sized Manufacturing Enterprises

Finally, for small and medium-sized manufacturing enterprises that are not covered under the existing scope of the “Major Emission Sources” announcement, inclusion may still be required if their energy consumption meets any of the specified thresholds set forth in this announcement.

1. Annual coal consumption ≥ 4,000 metric tons;

2. Annual fuel oil consumption ≥ 3,200 kiloliters;

3. Annual natural gas consumption ≥ 5 million cubic meters;

4. Total thermal capacity of a single emission outlet ≥ 10 million kilocalories per hour;

5. Total annual purchased electricity ≥ 20 million kWh (20 GWh).

The above thresholds integrate two major categories of indicators—physical fossil fuel consumption and electricity usage—while taking into account both process-related emissions and energy-related emissions. As such, they are considered representative, measurable, and operationally feasible.

Overall, the design of these regulatory thresholds emphasizes clarity, quantifiability, and cross-industry applicability, and is based on data from the preceding fiscal year to ensure timeliness and stability. Enterprises may conduct a preliminary self-assessment using existing operational data—such as energy bills, number of facilities, and fleet size—to determine whether they are potentially subject to regulation, and to initiate early data consolidation and internal coordination efforts.

2.3 GHG Inventory Registration Requirements for Multi-Site Enterprises

Under the Ministry of Environment’s announced policy on greenhouse gas (GHG) inventory registration, multi-site enterprises constitute a key category that cannot be overlooked. Many enterprises operate under a business model consisting of a corporate headquarters combined with a large number of branches, outlets, or operating sites. Although their GHG emissions are geographically dispersed, their total energy consumption and aggregate emissions are often substantial.

Accordingly, the government explicitly stipulates that enterprises meeting the announced inclusion thresholds may not evade inventory obligations by treating individual sites separately. Instead, the parent company or headquarters must assume overall responsibility for GHG inventory registration and reporting.

According to the supplementary provisions of the announcement, enterprises that operate subsidiaries, branches, offices, franchised outlets, affiliated stores, campuses, or other operational sites are required to centrally consolidate and report emission data for all sites under the parent entity. Individual sites are not permitted to independently register or submit fragmented inventories. This approach reflects the government’s understanding of modern corporate operating structures and reinforces the principle of corporate-level carbon governance responsibility.

Specifically, for the following types of enterprises, inventory registration responsibility shall rest with the corporate headquarters:

1. Chain convenience stores, supermarkets, and telecommunications retailers:
   The total number of both directly operated and franchised outlets shall be calculated in aggregate, with inventory registration handled centrally by headquarters.

2. Department stores, mass retailers, chain food service providers, and information service companies:
   Even if individual stores or sites operate as separate legal entities or business units, inventory registration must be submitted uniformly under the parent company or central operating division.

3. Universities and higher education systems:
   Including branch campuses, affiliated institutions, and research centers, all entities shall be centrally registered and reported by the main university administration.

4. Logistics and transportation enterprises:
   Regional warehouses, fleet depots, and fixed operating locations shall be incorporated into the parent company’s fleet statistics and overall emissions boundary.

Healthcare Systems

Where hospitals operate as legal foundations or as part of a medical center system, they shall likewise be consolidated and calculated under the parent organization for the purpose of GHG inventory registration.

This integrated reporting approach carries several key implications and challenges for enterprises:

1. Enhanced Data Integration Requirements
   Enterprises must collect key operational data—such as electricity consumption, energy use, fleet size, and total floor area—from multiple sites or subsidiaries, and conduct consolidated analysis. Reliance on single-site estimates is no longer sufficient.

2. Cross-Unit Coordination and Clear Accountability
   As inventory preparation involves multiple operational units across different locations, enterprises must establish standardized reporting templates and internal workflows. Failure to do so may increase the risks of misreporting and data omissions.

3. Higher Demand for Internal Institutional Frameworks
   Enterprises are encouraged to gradually establish internal guidelines for emissions data inventory and registration, and to integrate these processes into sustainability reporting and ESG governance frameworks.

The Ministry of Environment further clarifies that if an enterprise meets the inclusion criteria at any point during the reporting year, it must be included in the inventory scope, regardless of whether the threshold is met throughout the entire year. This implies that enterprises should not rely solely on year-end aggregated statistics for self-assessment. Instead, they are advised to monitor monthly or seasonal operational peaks in advance to ensure sufficient preparation time.

Strategic Recommendation by Bu-Jhen Low-Carbon Strategy
Multi-site enterprises are advised to proactively adopt emissions data management systems (such as GHG Management Information Systems, GHG MIS) or cloud-based inventory platforms, integrated with Energy Management Systems (EMS) or existing ERP architectures. Through hierarchical authorization and data consolidation, enterprises can align with the policy principle of “centralized headquarters oversight, site-level reporting, and unified disclosure.”

For corporate groups, this represents not only a compliance requirement but also a critical opportunity to demonstrate governance capability to ESG-focused investors.

Chapter 3  Inventory Registration Procedures and Operational Guidelines 

With the implementation of the Announcement on Emission Sources for the Inventory and Registration of Greenhouse Gas Emissions by Business Entities, enterprises are required to clearly understand the operational workflow and key timelines for inventory registration, so as to fulfill their statutory obligations in a timely manner once the system is activated.This chapter outlines the key operational steps, platform procedures, emissions calculation elements, and common issues associated with inventory registration, with the aim of supporting enterprises in effectively implementing the requirements in practice.

3.1 Annual Operational Schedule and Key Deadlines

According to announcements issued by the Ministry of Environment, starting from Year 115 of the Republic of China (2026), all business entities that meet the inclusion criteria shall, in accordance with the Regulations Governing the Inventory, Registration, and Verification Management of Greenhouse Gas Emissions, complete the inventory compilation and registration of emissions data for the preceding year within the prescribed annual timeframe.

The core statutory schedule is as follows:

3.1.1 Key Statutory Timeline

1. Inventory Period
   Enterprises shall conduct a full-year compilation and calculation of emissions data for the previous calendar year (e.g., 2025).

2. Registration Deadline
   Registration and submission of the previous year’s data shall be completed no later than April 30 of the following year (e.g., April 30, 2026).

This requirement—completion of registration by the end of April of the following year—provides enterprises with approximately four months of preparation time, including data consolidation, emissions calculation, internal review, and final submission.

However, if an enterprise meets the inclusion criteria at any point during the reporting year, it is still required to complete a full inventory and registration for that year, even if the criteria are not met throughout the entire year. This provision is particularly important for enterprises with seasonal or fluctuating operational patterns.

3.1.2 Recommended Internal Operational Schedule (for Enterprises)

• Early January to Mid-February
  Consolidate baseline data from the previous year, including energy consumption, vehicle operations, and the number of operational sites or outlets.

• Late February to End of March
  Conduct emissions calculations for Scope 1 and Scope 2, and complete internal review and verification procedures.

• Early April to April 30
  Log in to the designated platform to complete data registration and submission, and generate archived records.

• From May onwards
  Utilize the consolidated results as a basis for internal carbon management, ESG reporting, or carbon cost and risk analysis.

3.1.3 Extended Applications and Future Risks

Although the inventory data completed by enterprises at the current stage does not require third-party verification and is not directly used for carbon fee calculation, it is highly likely to serve as a foundational reference in the future for:

• the expansion of carbon pricing mechanisms,

• carbon fee assessment and emissions trading systems, and

• regulatory review and policy escalation.

3.1.4 Phased Implementation Recommendations

We recommend that enterprises formally incorporate greenhouse gas (GHG) inventory activities into their annual sustainability work plans and designate a dedicated coordination window to integrate data across departments.
For enterprises with highly dispersed operational sites or complex operating structures, it is advisable to establish a GHG Inventory Review Task Force responsible for data consolidation and internal review. All data uploads should be completed one to two weeks prior to April 30, allowing sufficient time for revisions and final confirmation.

3.2 Registration Platform Overview and User Guidance

To support enterprises in fulfilling their statutory GHG inventory registration obligations, the Ministry of Environment has established the Business Greenhouse Gas Emissions Information Platform, which serves as the official operational platform for all enterprises subject to the regulatory announcement.
The platform integrates functions such as electricity data interfaces, inventory boundary guidance, and historical record retention, and will continue to expand auxiliary modules and calculation tools applicable to various industries.

Basic Platform Information

1. Platform Name: Business Greenhouse Gas Emissions Information Platform

2. Competent Authority: Climate Change Administration, Ministry of Environment

3. Access URL: To be announced separately by the Ministry of Environment through regulatory briefings and official website notifications

4. Login Method: Login using a company or legal entity Business Registration Certificate
   (Personal natural person certificates are not permitted)

This platform serves as a nationwide centralized registration interface, featuring hierarchical access control and organizational binding mechanisms. It allows the parent company to act as the primary entity, authorizing subsidiaries or operational sites to input data, followed by consolidated review and final submission by the responsible supervisory unit.
This design is particularly advantageous for enterprises with multiple operational sites.

Overview of Platform Operation Steps

1. System Login

Log in to the platform using the Business Registration Certificate of the company’s responsible person or IT administrator.
Upon login, establish the company’s dedicated account and define user roles and access permissions.

2. Setup of Basic Inventory Information

Enter the organizational structure, list of operational sites, primary business categories, site attributes
(e.g., directly operated, franchised, branch campus), and types of energy usage.

3. Data Entry and Upload

Complete the entry of energy consumption data for each operational site in accordance with the regulatory requirements, including electricity consumption, fuel usage, and number of vehicles.
Enterprises may utilize the Excel calculation tools provided by the Ministry of Environment or the platform’s built-in online calculation modules to automatically convert activity data into CO₂e emissions.

4. Data Consolidation, Verification, and Submission

All entered data must be reviewed and confirmed by authorized internal personnel before submission.
Upon submission, the system will generate a registration reference number and a summary report, which can be downloaded for record-keeping and audit purposes.

5. Record Retention and Traceability

After completion of registration, the platform will automatically archive historical records for future verification, correction, or traceability.
Data may also be exported in PDF or Excel format for internal documentation or as supporting evidence for sustainability and ESG reporting.

Integration of Electricity Data: Connection with Taipower Databases

The platform is equipped with an interface that connects to the electricity consumption data systems of Taiwan Power Company (Taipower).
Upon user authorization, annual electricity consumption data associated with specific meter numbers can be retrieved directly, significantly reducing manual data entry errors.
This function is particularly beneficial for chain enterprises with a large number of operational sites, as it substantially accelerates multi-site inventory preparation.

Common Interfaces and Supporting Functions

1. “Reporting Progress Tracking” Function
   Enables the primary account holder to monitor whether data submission for each operational site has been completed.

2. “One-Click Duplication of Previous-Year Site Data” Function
   Improves year-over-year inventory efficiency by allowing prior-year site data to be copied and updated.

3. “Emission Estimation Tool” Function
   Allows users to input electricity or fuel consumption data and instantly obtain the corresponding emissions,
   with calculations automatically updated based on the latest emission factors.

4. “Multi-Site Consolidated Download/Upload” Function
   Supports Excel-based data import and batch uploads for multiple sites.

Implementation Recommendations

To support operational execution and future policy extensions
(such as carbon pricing, carbon disclosure, and ESG-related investor questionnaires),
enterprises are advised to designate IT personnel or sustainability managers to become fully familiar with the platform interface and functionalities.
During initial implementation, internal SOP documentation should be established to ensure future repeatability, audit readiness, and compliance with regulatory requirements.

3.3 Calculation Methodology for Scope 1 and Scope 2 Emissions

In accordance with the Regulations Governing Greenhouse Gas Emissions Inventory Registration and Verification and official announcements issued by the Ministry of Environment,
enterprises conducting greenhouse gas inventories are required to cover both Scope 1 and Scope 2 emission sources.

These two categories represent the most fundamental and commonly applied inventory boundaries for corporate GHG accounting,
characterized by high controllability and traceability,
and serve as the core calculation basis for future carbon pricing mechanisms and mandatory disclosure frameworks.

Scope 1: Direct Emissions

Definition

Scope 1 emissions refer to greenhouse gas emissions that occur from sources owned or controlled by the enterprise, arising from the direct combustion of fuels or from on-site emission-generating processes.

Common Sources Include

1. Combustion of gasoline or diesel in company-owned vehicles;

2. Fuel combustion in stationary equipment, such as boilers, generators, and furnaces using fuel oil or natural gas;

3. Fugitive emissions from refrigerants released during the operation of cooling equipment
   (e.g., air conditioners, refrigerators, and cold storage systems);

4. Emissions from waste incinerators or special process reactions
   (applicable mainly to manufacturing industries).

Calculation Methodology

Each fuel type or emission source shall be calculated by multiplying:

• Activity Data,

• Emission Factor, and

• the corresponding Global Warming Potential (GWP).

The general formula is as follows:

Emissions (tCO₂e)=Activity Data×Emission Factor×GWP 

Example

If the CO₂ emission factor for diesel fuel is 2.6 kg CO₂e per liter
(as announced by the Ministry of Environment),

and the annual diesel consumption is 10,000 liters, then:

10,000×2.6÷1,000=26 tCO₂e10{,}000 \times 2.6 \div 1{,}000 = 26 \text{ tCO₂e}10,000×2.6÷1,000=26 tCO₂e 

Scope 2: Indirect Energy Emissions

Definition

Scope 2 emissions refer to greenhouse gas emissions generated from the production of purchased energy, such as electricity, steam, and hot water, that is consumed by the enterprise.
Although the emissions physically occur at the energy supplier’s facilities (e.g., Taiwan Power Company), they are attributed to the energy-consuming organization.

Key Considerations in the Taiwan Context

Under current practice in Taiwan, purchased electricity is the primary source of Scope 2 emissions.
According to announcements by the Ministry of Environment, starting from 2025, enterprises shall apply the most recent annual Taiwan electricity emission factor for calculation.

For example, the emission factor for calendar year 2023 is:

0.494 kg CO₂e / kWh

Calculation Formula :

Annual emissions (tCO₂e) = annual electricity consumption (kWh) × Emission factor (kg/kWh) ÷ 1,000 

If a company's total annual electricity consumption is 1,200,000 kWh (1.2 GWh), its Scope 2 emissions are: 

1,200,000 × 0.494 ÷ 1,000 = 592.8 metric tons of CO₂e 

  Other technical points 

1. Refrigerant fugitive calculation: Confirm the type of refrigerant (e.g., R-134a, R-410A) and fill volume, and use the refrigerant-specific GWP coefficient conversion (most of them are above 1000). 

2. Vehicle emissions: The number of vehicles and annual fuel consumption need to be registered, which can be supported by using fuel invoice estimation or GPS system export data. 

3. Power source: It is recommended to focus on Taipower or the building energy monitoring system (BEMS) to avoid estimation errors. 

4. Emission Factor Update: The Ministry of Environment announces the latest version of the domestic emission factor every year, and it is recommended to check the latest annual value to avoid using expired versions. 

Bu-Jhen suggests that

 Bu-Jhen's low-carbon strategy suggest that companies establish an internal "carbon emission data form template" and compile it according to the site level, and automatically calculate and track the change trend over the years in accordance with the emission factor and GWP announcement value. In addition, data corroboration files, such as invoices, Taipower bills, energy contracts, and refrigerant maintenance records, should be created for internal verification or third-party verification. 

3.4 Common Issues and Precautions In the process of performing greenhouse gas emission inventory and registration, enterprises often face challenges such as confusion of concepts, incomplete data preparation, and unfamiliarity with platform operations. Especially for service industries, transportation industries or educational institutions that are included in the scope of inventory announcements for the first time, how to correctly understand the "management conditions", obtain "verifiable data" and complete the "complete registration" is the key. The following summarizes several common practical problems and corresponding precautions for enterprises to deal with in advance: 

Question 1: Do I belong to the public institution that should be registered?

 Judgment focus: 

1.whether it belongs to the industries specified in the announcement (such as department stores, convenience stores, colleges and universities, transportation industry, etc.)

2.whether the thresholds such as electricity, fuel, number of vehicles or number of stores are met in the "previous year";

3.if it is a group enterprise, whether the overall group meets the total threshold. 

Suggested countermeasures: 

1.Take stock of the energy and operational data of the entire company and all branches in 2024 as soon as possible;

2.You can refer to the trial calculation of the "Self-Judgment Tool for Accepting Objects" provided by the Ministry of Environment

3.Cooperate with accounting departments and facility management units to obtain energy usage details. 

Question 2: If only some months of the year meet the standard, do I still need to register?

 Response principle: 

• Yes, according to the provisions of the announcement: "If the conditions have been met in the current year, they are also applicable", even if the standard is not met in the whole year, the inventory registration should be completed in the following year.

 For example, 

• a convenience store chain system opened its 100th store in July 2024 and has since reached the threshold, so it still needs to check the data for the whole year of 2024. Question 3: I have no experience in carbon emission calculation, how can I conduct an inventory? 

Recommended steps: 

1.Collect basic activity data: electricity consumption, fuel purchases, vehicle refueling records, refrigerant maintenance records, etc.

2.Compare the type of emission source, refer to the official emission factor

3.Use the spreadsheet provided by the Ministry of Environment or the built-in tools of the platform to automatically calculate

4.If you are unsure how to classify your emission sources, you can refer to the "Inventory Guidelines" or seek advice from consultants. 

Tooltip: 

• The Ministry of Environment provides an "Excel calculation tool" and a "calculation module" that can be converted into CO₂e emissions by entering basic data. 

Question 4: Will I face carbon fees or penalties after the inventory? 

Current situation: 

1.This announcement adopts the principle of "three noes and one no", which means that there is no need for inspection, no outsourcing, no trouble, and no fees for the time being; 

2.However, inventory data will become an important basis for future carbon fee levies, carbon trading systems, and even green procurement and ESG evaluation. 

Bu-Jhen suggested : 

1.Even if there is no current fee, enterprises should regard inventory as part of internal risk management

2.It is recommended that annual inventory be included in the sustainability report or disclosed in the board of directors' sustainability report. 

3.In the long run, data transparency will benefit brand image and investment relationships. 

Other precautions  

When assisting companies in conducting inventory and guidance, Buzhen Low Carbon Strategy recommends that enterprises should establish a "sustainability data responsible person system" within the enterprise, with the information department or engineering unit coordinating data integration, the sustainability department leading reporting and analysis, and regularly tracking emissions changes over the years to meet the needs of more carbon reduction and carbon pricing policies in the future. 

Chapter 4 Professional Guidance and Resources for Bu-Jhen Low-Carbon Strategies  

4.1 Low-carbon professional practical courses and case workshops 

In the face of the official expansion and launch of the greenhouse gas inventory system, many enterprises and non-traditional industrial sectors (such as service industries, transportation industries, and educational and medical institutions) that have been included in the regulation for the first time often face the challenge of "not knowing where to start". In order to help enterprises quickly understand policy requirements, establish internal implementation capabilities, and practical operation logic, Buzhen Low Carbon Strategy Co., Ltd. has designed a series of low-carbon professional courses and case-oriented workshops with "learning by doing" as the core.

 Curriculum Design Concept 

The main axis of the curriculum is based on the following three core values: 

1.Knowledge-to-Action: Extending from policies, regulations, and technical guidance to actual inventory form operations. 

2.Hands-on Practice: Uses actual electricity, fuel, refrigerant, or vehicle data provided by the company as an example.

3. Capacity Building: The course is not limited to teaching, but also aims to enable students to promote the company's inventory plan after class. 

We understand that many companies lack dedicated personnel in sustainability or carbon management, so the course is designed to be accessible to non-engineering students, combining theoretical lectures, practical calculations, and case studies. 

List of course types Introductory course: 

1.Introductory course: Greenhouse gas inventory and disclosure basic course 

(1)Understanding the GHG Protocol and ISO 14064-1 architecture 

(2)Scope 1 and 2 emission source determination and data requirements 

(3)How to understand the provisions of the announcement and the management standards 

2.Advanced courses: enterprise inventory practice and platform simulation class 

(1)Use the simulation platform to complete the inventory of the document and fill in the data 

(2)Learn estimation techniques for complex items such as refrigerant runaway, fuel consumption, and more 

(3)Create an internal inventory database form schema 

3.Theme Workshop: Industry-specific case classes (suitable for HR, legal, and operational units) 

(1)Exclusive example operation for hospitals, convenience stores, and colleges 

(2)Multi-site aggregation and authorization system design 

(3)An explanatory template that combines sustainability reports with carbon fee risk disclosures 

4.in-house training customized courses 

(1)Design the curriculum based on the company's operating type, number of bases, and current ESG process 

(2)It can be used with the inventory annual timetable for "introductory tutoring and teaching" 

(3)Provide after-class technical support and progress tracking services 

Course Effectiveness and Feedback Highlights 

1.Many chain retail and logistics companies have reported that "I didn't know how to calculate carbon emissions at all, but I was able to conduct a preliminary self-inventory through the Buzhen workshop." 

2.A medium-sized manufacturing owner said, "I was worried about outsourcing, but through the three-day advanced course, the internal engineering department could take over the carbon inventory task." 

Bu-zhen's courses are not based on cramming teaching, but on "what companies really need" as the starting point, helping participants clarify concepts, gain operational confidence, and establish institutionalized thinking. 

After-course extension: with consulting services and evaluation reports

 All courses can be combined with subsequent consulting services, including: 

1.inventory trial calculation and accuracy evaluation; 

2.report review and internal review assistance; 

3.Integrate the inventory data output required for ESG disclosure, carbon disclosure, CDP, or RE100 reporting. 

4.2 Carbon Emissions Calculation Tools and Platforms Support 

One of the most common practical challenges in greenhouse gas inventory operations is how to accurately convert complex, multi-source energy use data into standardized carbon dioxide equivalent (tCO₂e) emissions data. Especially for companies conducting inventory for the first time, they are often at a loss when faced with various fuel, refrigerant, and electricity consumption data. The Bu-Jhen Low Carbon Strategy team is well aware of this, so we not only provide manual counseling services, but also build a series of professional inventory tools and automated platform support to help companies improve efficiency, reduce error rates, and comply with policy requirements. 

Tool development concept 

Our tool design is designed with "user-oriented" at its core, emphasizing the following three principles: 

1.Comply with the announcement specifications: fully correspond to the emission factors, GWP values and the latest regulatory conditions announced by the Ministry of Environment; 

2.Intuitive and easy to operate: even non-technical personnel can quickly start typing and interpreting; 

3.Support Site Integration: Specially designed for the aggregation needs of multi-site enterprises, supporting Excel or platform interfaces. 

Bu-Jhen Development of In-house GHG Inventory Toolkits

1. GHG Excel Calculation Sheet (Bu-Jhen Version)

(1)Column design structured by Scope 1 and Scope 2 classifications
The calculation template is structured according to Scope 1 and Scope 2 emission categories, ensuring consistency with regulatory inventory requirements.

(2)Built-in emission factors for common energy sources
The tool incorporates predefined emission factors, including the Taiwan electricity emission factor, as well as commonly used fuels such as diesel, gasoline, and natural gas, which are automatically applied during calculation.

(3)Automatic annual updates of total emissions and emission ratios
The spreadsheet supports year-by-year updates of total greenhouse gas emissions and proportional breakdowns, making it applicable across different industries and organizational types.

2. Refrigerant Emissions Estimation Module

(1)Automatic application of GWP values based on refrigerant type
The module automatically assigns the corresponding Global Warming Potential (GWP) values according to refrigerant types (e.g., R-134a, R-410A).

(2)Multiple estimation methodologies supported
The system supports various estimation approaches, including the charge-based method and the annual leakage rate method, allowing flexibility depending on data availability and equipment characteristics.

(3)Aggregation support for high-refrigerant-demand equipment
The module is designed to handle aggregated calculations for refrigeration-intensive equipment, such as cold storage facilities and chiller systems.

3. Simplified Vehicle Fuel Emissions Calculator

(1)Automatic estimation based on fleet size and average fuel consumption
Annual emissions can be estimated using the number of vehicles by type combined with average fuel consumption assumptions.

(2)Optional integration of detailed operational data
More precise calculations can be achieved by importing fleet GPS data or monthly fuel card transaction records.

4. Multi-site Consolidated Output Tables

(1)Hierarchical aggregation by organizational structure
Emissions data can be consolidated and reported by headquarters, subsidiaries, or franchise outlets.

(2)Decentralized data entry with centralized consolidation
Each site may complete its own data input independently, after which the master table enables one-click consolidation and conversion into the official registration format.

Platform support and automation integration

Bu-Jhen Low Carbon strategy can also provide cloud platform integration modules, including the following functions: 

1.Users of the Carbon Inventory Cloud Reporting System (Beta)

(1)Users can log in online and automatically display the corresponding emission sources according to their industry. 

(2)The bilingual interface supports both Chinese and English versions, making it convenient for multinational enterprises to operate

(3)The registration data can be converted into GHG annual emissions report schedule format (CSV, PDF) with one click. 

2.API connection service (suitable for large enterprise/group customers) 

(1)can be connected to Taipower's power system, enterprise ERP system, and energy management system (EMS); 

(2)reduce manual work and improve immediacy and accuracy;

(3)It is suitable for long-term tracking of carbon management indicators for corporate sustainability. 

The auxiliary chart and EXCEL report automatic generation 

Bu-Jhen tool are equipped with the chart auto-generation module, which can quickly output the following information for internal viewing or reporting: 

1. pie chart of the proportion of each emission source (add settings as needed);

2.  Annual emission trend line chart (set according to demand); 

3. Comparison chart of carbon intensity (carbon intensity) of each site/department (set according to demand); 

4. Industry benchmark comparison chart (can be used as a reference for future disclosure/additional settings as needed).

Practical Implementation Results:

 Many companies have used Bu-Jhen low-carbon design and development tools to complete internal initial inventory work, which have been successfully integrated into sustainability reports or CDP carbon disclosure basis. For example, a company automatically exports data into the EXCEL module through fuel consumption records and vehicle management systems, automatically updates fleet carbon emissions every month and calculates annual trends, saving more than 80% of manual processing time. 

4.3 Professional Certification and Capability Appraisal Assistance 

As climate governance and carbon management gradually become an integral part of corporate business strategies, how to establish a stable, reliable, and responsive internal "sustainable execution" that can respond to policy changes is the key for enterprises to move from compliance-oriented to competitive advantage. In fact, the introduction of the inventory system is only the first step, and the ability to truly internalize, normalize, and strategize it relies on the cultivation of professional talents and the institutionalized ability appraisal mechanism.

 In this context, Buzhen's low-carbon strategy not only assists companies in completing one-time inventory operations, but also emphasizes assisting companies in building a long-term replicable carbon inventory talent system, introducing internal training, professional certifications, and personnel system design as part of sustainable governance capabilities. 

What "carbon management talents" do companies need? 

Based on Bu-Jhen's practical observation and counseling experience, a company that can effectively implement greenhouse gas inventory, formulate carbon reduction strategies, and integrate ESG disclosure should include at least the following three types of core competencies: 

1.Carbon inventory practitioners (GHG Reporting Officers) are familiar with the logic of Scope 1 and 2 emissions calculations, have the ability to collect, estimate and compile reports, and can interpret the provisions announced by the Ministry of Environment and classify emissions according to different business units 

1. GHG Reporting Officer

1. Solid understanding of Scope 1 and Scope 2 emissions accounting logic
   Demonstrates a clear grasp of energy consumption structures and the calculation logic for direct and indirect greenhouse gas emissions.

2. Capability in data collection, emissions estimation, and reporting preparation
   Possesses the ability to collect activity data, perform emissions calculations, and compile summary reports in accordance with regulatory requirements.

3. Ability to interpret official announcements and regulatory provisions issued by the Ministry of Environment
   Capable of classifying emission sources across different business units in compliance with regulatory definitions and sector-specific guidance.

2. GHG Internal Verifier

1. Ability to conduct preliminary reviews of site-level or departmental emissions results
   Performs initial checks on compiled emissions data to ensure completeness, consistency, and internal coherence.

2. Capability to identify high-risk items with lower data reliability
   Able to recognize data sources or calculation items with elevated uncertainty or potential misstatement risks.

3. Establishment of materiality thresholds and internal verification mechanisms
   Develops materiality criteria, sampling review checklists, and internal supporting documentation procedures

3. ESG Program Integrator

1. Ability to translate GHG inventory data into ESG disclosures and climate programs
   Converts emissions inventory results into inputs for ESG reports, carbon disclosure platforms (e.g., CDP), SBTi targets, and RE100 transition pathways.

2. Capability to communicate emissions management outcomes to senior management and key stakeholders
   Effectively presents internal carbon management performance to executives and decision-makers.

3. Integration of GHG inventory results with green procurement and climate-related financial risk analysis
   Links emissions data with sustainable procurement strategies and climate-related financial assessments.

These roles may be designed flexibly according to organizational scale, ranging from a single individual holding multiple functions to a segmented, multi-role structure. Stepwise supports enterprises in establishing a comprehensive GHG talent role map and competency framework, serving as a foundation for future training and professional development.

Certification and Training Pathway Design: From Entry Level to Advanced

Bu-Jhen further proposes a tiered competency and certification-aligned training structure, matching the above roles with progressive skill development pathways.

Integration with domestic and foreign professional certification systems 

Bu-Jhen also assists companies in connecting with third-party or internationally recognized professional carbon management certificates, such as: 

1.ISO 14064-1/14064-3 organization-level inventory and verification certificate (cooperative courses with impartial third-party verification agencies),

2.GHG Verifier/Lead Verifier Initial Competency Certification (simulated assessment according to UNFCCC/IAF guidelines). 

3.GRI Certified Sustainability Practitioner 

4.SBTi-related pathway construction and goal setting training

5. CDP questionnaire response practical competency training (according to CDP's annual update framework) 

These certifications can be used as a basis for internal talent evaluation, promotion, or external disclosure of talent certification, and can also help obtain additional points in ESG ratings. 

Practical Counseling Case: Transformation Benefits of Internal Inventory Institutionalization 

A chain restaurant customer was originally only responsible for registering electricity consumption data by the accounting department, but due to more than 500 operating points, data omissions and calculation errors often occurred. Bu-Jhen assisted it in designing an internal personnel capability model and trained 30 inventory windows and 6 internal auditors through a three-stage training program. After implementation, not only has the inventory efficiency tripled, but the data quality has also been stable, and it has also been successfully integrated into the parent group's ESG report disclosure project, enhancing overall sustainability transparency. 

Bu-Jhen's view: Carbon inventory certification is not only an investment, but also an insurance 

Company's domestic carbon fee, the EU CBAM carbon border adjustment mechanism, the CDP carbon disclosure project, downstream participation in SBT climate action, international or multinational large enterprise customers, and supply chain carbon reduction pressure. Carbon inventory is not a report, but a capability building project. Bu-Jhen assists enterprises in establishing a complete capability closed loop from process → tools → personnel → systems, turning one-time compliance behavior into a long-term competitive advantage .

4.4 Customized Counseling and Consulting Services 

With the legalization and large-scale expansion of the greenhouse gas inventory system, more and more companies are beginning to face multiple challenges such as "first-time inventory", "inexperienced manpower", "scattered bases", and "incomplete system construction". Although the Ministry of Environment provides a universal platform and tools, it still needs more flexible and in-depth support for internal processes, data sources, cross-departmental coordination, and disclosure logic encountered by various industries in practice. 

It is in this demand that Bu-Jhen Low-Carbon Strategy has established a consulting service model centered on "scenario-oriented + customized counseling + long-term companionship", assisting enterprises in forming a closed loop from initial construction, inventory operations, internal systems to disclosure and application, and adjusting and optimizing according to industry characteristics.

 What is "customized counseling"? 

Bu-Jhen customized services not only assist in filling out forms but also establish a sustainable carbon management structure based on the actual operation and management structure of the enterprise. Customized coaching typically involves the following core stages: 

1. Preliminary Assessment and Applicability Determination

1. Analyze whether the enterprise has been included in the latest list of regulated entities announced by the authority.

2. Assist in interpreting key compliance questions, including:

   • Whether the company meets the regulatory thresholds

   • Which sites are subject to management requirements

   • Whether consolidated (group-level) reporting is required

3. Define the appropriate organizational boundaries and emissions boundaries.

2. Data Inventory and Process Mapping

1. Review whether the enterprise already maintains internal databases or workflow forms covering electricity use, fuel consumption, refrigerants, vehicles, and other relevant activity data.

2. Assess data reliability, accessibility, and ownership, and define the roles and responsibilities of data-providing departments and inventory owners.

3. Establishment of a Corporate GHG Inventory Standard Operating Procedure (SOP)

1. Develop a complete operational guideline covering data collection, emissions estimation, data consolidation, internal review, and official registration.

2. Assist in defining standardized data templates, reporting frequency, designated reviewers, and the annual inventory timeline.

4. Deployment of Systematic Inventory Tools

1. For enterprises with sufficient internal IT capability, support the development of Excel-based templates or cloud-based GHG inventory platform modules.

2. For enterprises already operating BEMS or ERP systems, enable the integration of energy and operational data into GHG inventory tools through system interfaces.

5. Establishment of Internal Training and Verification Mechanisms

1. Design role-specific training programs for key departments and establish internal verification focal points.

2. Assist in establishing a four-stage internal assurance and review framework, including internal review, primary verification, confirmation, and disclosure.

6. Reporting and Disclosure Support

1. Prepare GHG inventory summary reports in compliance with ISO 14064-1:2018, CDP, GRI, and other recognized disclosure frameworks.

2. Support the preparation of climate-related sections for ESG reports (e.g., GRI 305, IFRS S2) or assist with completing reporting templates required by supervisory authorities.

Common Client Case Types 

Long-term consulting services: not just a one-time solution

 Bu-Jhen provides various types of long-term cooperation consulting models: 

1.Inventory consultant annual contract: annual fixed support inventory, data review, registration operation and improvement report 

2.Sustainability disclosure consultant: integrated CDP questionnaire, TCFD analysis, SBTi application and carbon inventory data integration 

3.carbon fee risk consultant: assists in estimating future carbon fee exposure, formulating carbon reduction pathways and internal carbon price models 

All cooperation provides "operating system filing + document form migration + capability internalization training" to ensure that the company can be led by an internal team and assisted by consultants within three years. Customer Empirical Results Sharing A large public transportation company originally only used energy master tables to estimate emissions, resulting in incomplete inventory of refrigerants, vehicles, and purchased electricity. After Bu-Jhen assisted in the introduction of a complete summary module and annual inventory process, it was successfully achieved within one year: 

1.Establish a refrigerant filling record system;

2.Vehicles use fuel consumption reports to establish a Scope 1 emissions database

3. Complete the branch power registration of more than 40 station locations;

4.The inventory results are simultaneously applied to the CDP Climate Change questionnaire. 

Bu-Jhen's view: Inventory is a capability and a strategy 

Carbon inventory does not exist to "fill in a table", but is an enterprise risk warning mechanism and a strategic decision-making tool. Buzhen not only helps enterprises pass the test, but also hopes to help enterprises build a capability structure that can be used for a long time and produce results. We believe that "carbon management capabilities" will become a key asset for companies in the future climate economy, and the role of "mentors" is to help you stand firm at this starting point and go further.  

Chapter 5  Enterprise Response Strategies and Suggestions  

In the face of increasingly mature carbon inventory systems and escalating disclosure requirements, companies should not only stop at the step of "completing registration" but should further integrate carbon emission management into their internal governance and sustainable development strategies. Establishing an internal carbon management framework that is standardized, systematic, and strategically linked, from institutional, organizational, and operational aspects, will be the key for companies to respond to the trend of net-zero transformation and future carbon fee systems and ESG disclosures. This chapter proposes five major response strategies compiled by the Buzhen Low-Carbon Strategy based on practical counseling experience as process suggestions for enterprises to improve their climate resilience and carbon governance capabilities. 

5.1 Steps to establish an internal carbon management system 

Greenhouse gas inventory is not a single-year project task, but a continuous management work that spans departments, periods, and is deeply linked to business strategies. Especially in an environment where carbon pricing, carbon fee systems, and sustainability disclosures are gradually institutionalized, if companies are still stuck in the stages of "outsourcing processing" and "surprise disclosure", it will be difficult to meet the dual requirements of future regulatory and market requirements for the accuracy and timeliness of climate information. 

Therefore, the key purpose of "establishing an internal carbon management system" is to enable enterprises to gradually transform from "relying on external → regulations to internalize → capabilities autonomously", and ultimately truly link carbon information with operational decisions, transforming it into risk control and transformation opportunities. The following are the six steps proposed by Bu-Jhen: 

Step 1: Establish a responsible unit and an interdepartmental climate working group

 A successful carbon management system is the first step to clearly set responsibility. The board of directors or senior management team should formally appoint a responsible unit for sustainable development (such as the ESG Office, General Affairs Office, Compliance Department, etc.), and set up a "Climate Risk and Carbon Management Task Force." The group should cover: 

1.engineering or facility units (energy/refrigerant equipment)

2. Operations Department (Production/Logistics/Site Management)

3.Procurement and Accounting (Carbon Cost and Financial Disclosure);

4.Information Division (Data Integration); Marketing and Sustainability Department (external communication and ESG disclosure). 

5.Marketing and Sustainability Department (external communication and ESG disclosure). 

Designing a "climate task division map" and working meeting schedule can help promote internal consensus and enhance the initiative and accuracy of the inventory process. 

Step 2: Comprehensive inventory of available data and creation of "emission source inventory" 

The key to carbon inventory is "data-driven". Enterprises should comprehensively inventory the available energy, refrigerant, transportation, construction, and process data, including but not limited to: 

1.electricity bills, energy billing certificates, and Taipower interface data

2.fuel consumption, vehicle fuel card records, automatic refueling data export;

3. refrigerant filling and maintenance records, main equipment specifications

4. process calorific value statistics, boiler operation data, etc. 

It is recommended to create a "GHG activity data source table" (e.g., activity data source, unit, update frequency, person in charge, credibility assessment) to facilitate tracking and annual updates, and provide a supporting basis for future verification. 

Step 3: Formulate an internal inventory and audit operation manual (SOP procedure management document)

 If there is no consistent process and inspection standards for data collection, it will lead to data quality gaps. Buzhen suggested formulating the following system documents: 

1.inventory operation flow chart (including schedule, departmental responsibilities, and document delivery points); 

2.GHG inventory operation manual (clearly listing the calculation principles, emission factors, and estimation methods of Scope 1 and 2); 

3.materiality assessment principles (defining minimum reporting thresholds and estimated allowable ranges); 

4.checklist template (after the inventory, the second department should randomly check whether it is filled in correctly);

5. Annual inventory schedule (it is recommended to start in January every year and complete registration in April). 

After the establishment of the internal system, a sustainable institutional cycle can be formed, so that the inventory shifts from human dependence to process dependence. 

Step 4: Build replicable inventory tools and integration platforms 

The inventory data sources are scattered, and it will be extremely inefficient to start from scratch every year. Enterprises should introduce the following tool modules to create a "replicable and traceable" data processing system: 

1.inventory form template (design fields according to different emission sources, such as fuel consumption, vehicle type, refrigerant type, etc.); 

2.Summary table design (automatically merge data from each base, calculate the sum and proportion); 

3.Cloud platform or Excel API interface module (can import energy management system or Taipower API data); 

4.Data comparison chart over the years (analyzes carbon intensity trends and changes in hot spots). 

The GHG trial calculation and summary EXCEL developed by Buzhen (ERP web version system can also be purchased) has the above functions, and can be converted to ESG report disclosure format or competent authority registration form format with one click. 

Step 5: Establish a three-level verification system of "internal inspection + chief audit + approval" 

The accuracy of the data will directly affect the company's credit and carbon fee foundation, and it is recommended to establish a three-level verification process: 

1.Grassroots units (filling): First-hand information is filled in by each base or department

2.Middle-level supervisor (internal inspection): Cross-review based on supporting documents (such as comparison of electricity bills, fuel bills, etc.)

3.Responsible unit (chief reviewer): Calculate the total emissions, check whether the boundaries are met, and the use of factors is consistent

4.Senior management (approved): Submitted to the board of directors or senior management for approval after final confirmation.

 This mechanism not only improves data quality but also serves as a simulation verification system before the introduction of third-party inspection (ISO 14064-3) in the future. 

Step 6: Embedding carbon inventory results into risk management and strategic planning

 Finally, carbon inventory should not stop at disclosure but should be elevated to "risk management" and "capital decision-making" tools. It is recommended to apply the results of carbon inventory to: 

1.estimating carbon fee and carbon transaction cost exposure (can be combined with financial simulation tools); 

2.establish an internal carbon price system (shadow price, internal carbon budget allocation);

3. as the basis for disclosure of SBTi, CDP, and TCFD; 

4.Include annual operating KPIs or CSR performance reward indicators;

5. As the basis for the evaluation of supplier management and green procurement. 

According to Bu-zhen, carbon management is not only data registration, but also an extension of corporate operational strategy management. Through institutionalized internal inventory processes, tooled operation modules, and organizational capacity building, companies can move forward steadily in the rapidly changing climate economy and truly transform "carbon" into decision-making resources rather than compliance burdens. 

Gantt Chart Description: The following are steps 1 to 6 of internal carbon management system construction (refer to Figure 1: KPI Gantt Chart for Internal Carbon Management System Construction Steps) 

To establish a sustainable carbon management mechanism, enterprises should follow a set of top-down, cross-departmental, institutionalized and instrumental internal construction processes. The above Gantt chart clearly indicates that starting from the beginning of 2025, companies can promote six major phases in order to assist organizations in completing the capability building path from "inventory responsibility system" to "carbon risk strategy integration". The timeline suggestions presented in this diagram are as follows: 

1.Step 1 (early January): Establish responsibility for climate governance, establish a carbon management team, and integrate cross-departmental personnel and roles. 

2.Step 2 (mid-January to the end of January): Each unit takes stock of existing energy, vehicle, refrigerant, and process data to establish an emission source inventory. 

3.Step 3 (February): Formulate inventory and audit process SOPs, verification specifications and reporting formats.

4. Step 4 (early March): Import inventory tools or data systems to start aggregating and testing data operation processes. 

5.Step 5 (mid-March to the end of March): Design data credibility ratings, internal inspection processes, and master review mechanisms. 

6.Step 6 (full month April): Embed the inventory results into the climate risk management mechanism, combined with financial estimation, carbon fee simulation, and disclosure preparation.

 This schedule can be flexibly adjusted according to the size of the enterprise and the maturity of the department, but the key is to have a dedicated promotion mechanism and cross-departmental collaborative arrangements to make the inventory not only compliant, but also more strategic for transformation. 

Bu-Jhen Low Carbon Strategy recommends that companies promote annual inventory operation plans at this pace every year and include this progress chart in the annual calendar of internal sustainability governance to facilitate the integration of internal control processes and future carbon disclosure responsibility trajectories.  

Chart description: 2025 CDP/GRI/IFRS Sustainability Disclosure Alignment Timeline Chart (Figure 2: Sustainability Disclosure Alignment Timeline Gantt Chart) 

This chart shows the three major international sustainability disclosure systems that companies need to face in 2025 - CDP Carbon Disclosure Project, GRI Sustainability Reporting Initiative, and IFRS S1/S2 International Financial Reporting Standards - their preparation and corresponding timeline planning, which helps companies coordinate their overall disclosure strategy and internal operational rhythm in sync. The Gantt chart shows the "preparation period" and "submission/integration period" of each disclosure framework in segments according to the timeline, presenting the following key information:

 CDP Climate Questionnaire 

• Preparation period (January ~ May): Companies need to inventory data and update the draft questionnaire based on the previous year's carbon emissions, climate risk opportunities, governance, and strategies. 

• Reporting period (June ~ August): The CDP questionnaire is officially open for filling, and companies must submit the final version on the platform and respond to potential scoring verification. 

Bu-Jhen suggests: Closely connected with greenhouse gas inventory operations, the inventory results can be directly embedded in the questionnaire framework and used for scoring bonus points. 

• Sustainability Report GRI Disclosure Standards Preparation Period (February ~ June): It is recommended that companies complete the draft report and stakeholder feedback before Q2 in accordance with the GRI 2021 standards (especially 305 climate change-related disclosures) to lay the foundation for finalizing the annual report. 

Bu-Jhen suggested: In this issue, major theme identification, ESG data compilation can be carried out simultaneously, and the board of directors review process can be prepared in advance. 

IFRS S1 / S2 Sustainability Disclosure Standards 

• Information Integration Period (March ~ September): S1 focuses on sustainability-related financial information overview, S2 focuses on the disclosure of climate change risk opportunities, and companies need to restructure their data structure and design risk assessment reports. 

• Financial Disclosure Bridge Period (August ~ December): Combined disclosure with annual reports or financial reports, and work closely with the Finance Department and Compliance Department. 

Bu-Jhen suggested: IFRS disclosure is not only an additional report, but also affects the company's capital market image and capital costs, which should be regarded as a board-level issue.  

5.2 Implementing Carbon Inventory Systems and Digital Tools

 A. Five Core Reasons for Introducing Inventory Systems 

As the scope of organizational emissions data becomes wider and departmental collaboration becomes closer, carbon inventory is no longer applicable to traditional paper or Excel management models. The digital system can help enterprises centrally manage multi-site data, monitor carbon emission hotspots in real time, optimize operational processes, and save a lot of preparation and conversion time when responding to CDP, GRI, IFRS S2, and other disclosures. 

B. System Module Design and Functional Recommendations: 

The carbon inventory system should support user permission control, automatically classify emission sources according to categories, have built-in the latest emission factors from Taiwan and internationally, and be able to unify the input format and calculation logic. At the same time, it is necessary to provide a graphical interface for displaying carbon emission trends, intensity, hot spot analysis, etc., to assist senior executives in decision-making. 

C. Implementation Process and Implementation Suggestions

 Enterprises should first take stock of the current carbon emission data collection process and responsible units to confirm whether energy bills, fleet fuel, refrigerant maintenance, and fuel statistics are centralized at each site. It is recommended to pilot two to three core bases first, and then gradually expand it into a comprehensive inventory system, and establish education and training and problem reporting mechanisms simultaneously in the process. 

D. Practical Application Case Taking a retail industry as an example,

 Bu-zhen assisted it in importing Taipower's API data integration and integrating it into the carbon inventory platform, automatically updating the purchased electricity data for about 1,300 stores every month. A manufacturing plant has introduced a gas and refrigerant host data recording module to automatically calculate annual emissions and carbon fee estimates. 

E. Implementation of key success factors 

The key to the success of the system lies in cross-departmental coordination, high-level support, setting standard formats, data validation mechanisms, and sustainable SOP construction. In addition to IT department collaboration, sustainability management goal assessments should also be included, making carbon inventory one of the annual KPIs. 

F. Systematization of Benefits and Transformation Opportunities 

can help companies quickly respond to external audit and disclosure requirements, and can also be integrated with carbon cost management, reduction plan monitoring, and voluntary disclosure such as CDP and RE100. It can also be embedded in financial decision-making, improving capital utilization efficiency and reducing climate risk losses. 

G. Scalable Application Scenarios 

The data of the carbon inventory system can be extended to SBTi target progress tracking, TCFD scenario analysis, IFRS S2 climate financial risk disclosure, carbon balance sheet simulation, green procurement decision support, etc., to truly introduce carbon data into decision-making. 

5.3 Strategies for Preparing for Future Carbon Fees and Carbon Trading Systems 

With the official implementation of the Climate Change Response Act in 2023, Taiwan has entered a turning point in the era of carbon pricing. According to the authorization of this regulation, the Ministry of Environment has embarked on a dual-track parallel policy of "carbon fee system" and "carbon credit trading system", on the one hand, to promote the internalization of environmental costs by high-emitting enterprises through carbon fees, and on the other hand, to establish a domestic voluntary carbon market (DVCM) to encourage private participation in reduction and industrial innovation. In the face of this institutional change, if companies only handle inventory and disclosure work with a "compliance obligation" mindset, they will miss out on the key window for capital risk control, the use of policy tools, and the grasp of transformational value. Therefore, understanding the structure of the carbon fee system, grasping the development trends of the carbon market, and establishing strategic response plans will be key to whether companies can operate smoothly and continue to create sustainable value in the next 3 to 5 years. 

A. Overview and Forecast Analysis of Taiwan's Carbon Fee System 

According to the draft and policy direction released by the Ministry of Environment, Taiwan's carbon fee system will initially adopt an "administrative pricing" model, multiplying the government's announced unit price by verified emissions for cost calculation. Key plans include: 

1.Applicable objects (initial management): Specific emission source enterprises that emit more than 25,000 metric tons of CO₂e per year (most of them are high-emission industries such as energy, steel, chemicals, cement, and transportation). 

2.Calculation method: Multiply the annual inventory results (calculated and verified by ISO 14064-1:2018 standards) by the announced carbon fee price. 

3.Estimated rate: Based on dialogue between academia and industry-government, the current estimated price is between NT$300 per ton (the preferential measures plan can be discussed in a special chapter on the low rate A~C), and will be adjusted on a rolling basis every three years based on domestic carbon reduction goals and industry affordability. 

4.Purpose of fees: After the carbon fee is collected, it will be classified into the "Climate Change Response Fund" and used for carbon reduction technology research and development, industry guidance, low-carbon transition subsidies, etc., forming a redistribution mechanism of "taking from high emissions and using it for transformation". 

Currently, Taiwan has not specified a mandatory fee payment schedule for small and medium-sized enterprises or service industries, but inventory data will be used as a basis for future policy expansion. If companies neglect inventory and data quality control, they may face unfair collection or risk rating downgrades due to false estimates of emissions. 

B. Trends and Opportunities for Participation in the Carbon Trading System 

In addition to the carbon fee system, the Ministry of Environment also plans to establish a "Domestic Voluntary Emission Reduction Quota Registration and Trading Platform" as the basis for the future development of the carbon credit market and offset system. This move aims to align with international trends (such as the EU's CBAM, UNFCCC Article 6 cross-border carbon trading) and build an incentive structure for enterprises to invest in carbon asset management. Specific channels for enterprises to participate include: 

1.applying for the development of voluntary reduction projects (such as energy-saving equipment replacement, renewable energy introduction, process improvement, carbon sink afforestation, etc.);

2. Verified Emission Reductions (VERs) that have been verified and registered by a third party; 

3.It is used to offset its own carbon fees, or sold to other companies on the carbon trading market for quota adjustment. 

Potential benefits include:

1. reducing the actual total carbon fee to be paid; 

2.Create additional sources of income (the market price of carbon credits is volatile, if it can be reduced at a low price and sold at a high price, it will form an arbitrage opportunity); 

3.Strengthen the performance and reputation of enterprises in ESG evaluation and supply chain carbon reduction assessment.

 At present, domestic companies (such as the steel industry and semiconductor industry) have entrusted consulting companies to conduct the development and verification process of voluntary reduction allowances, pre-arrange carbon credit asset layout, and plan to integrate with overseas carbon markets (such as Verra and Gold Standard). 

C. Three major response strategies for enterprises: from risk to active management 

In order to assist enterprises in deploying the implementation of carbon fees and carbon credit systems in advance, the low-carbon strategy suggests establishing an integrated response system from the following three directions: 

1. Establish a carbon fee risk simulation model 

1. Based on the company's inventory data over the years, design a carbon fee scenario model (e.g., rate 300/800/1500 yuan);

2.  Simulate the impact of rate changes on operating costs, gross margins, and product unit costs; 

3. Establish a "carbon fee risk heat map" by department or site, supplemented by an automated "carbon fee dashboard" for senior management teams to grasp.

 The purpose is to understand the potential financial pressure of carbon fees in the next 3~5 years in advance and develop feasible investment plans for cost absorption or reduction. 

2. Build a carbon asset and carbon credit strategy library 

1. to identify potential projects that can apply for carbon credits from the company's current equipment and operating models. 

2. Compile voluntary reduction standards (such as Verra, Gold Standard, Taiwan Voluntary Reduction Management Regulations) and conduct qualification judgments; 

3. Evaluate the costs, carbon price trends, and return on investment (ROI) required for the verification and registration process.

 The purpose is to enable enterprises to have "carbon asset leverage capabilities" and flexibly adjust emission pressures and manage carbon capital structures.  

3.Introduce an internal carbon pricing system 

1. set up a "shadow price" as a project evaluation indicator. 

2. Design an "internal carbon budget (internal carbon fee)" and configure the allowable emission limit per unit of output;

3.  Adopt the "Simulated Carbon Fee Expense" system to cultivate the department's climate financial thinking and sense of responsibility. 

The purpose is to make carbon a "price signal" for internal management, enhance the department's motivation for independent improvement, and accelerate the accuracy of the transformation payback period assessment. 

Conclusion: Carbon fees are a warning sign and the beginning of opportunity 

The carbon pricing system is essentially a "monetization label for climate risks", which is not only a punishment for past emissions, but also a new system design that encourages transformation and value creation. If companies can face the challenge head-on from the perspective of risk management

1. they will have the opportunity to improve the attractiveness of green financing and ESG investment through emission information, carbon asset management, and data transparency.

2.reduce the cost of policy and market carbon emissions; 

3.Establish governance capabilities for a "net-zero operating model". 

Carbon fees are not only a cost, but also a transformation lever for companies to think about how to "exchange less emissions for more value". The next wave of leaders will be those companies that know how to move from inventory data to carbon strategy management now. 

A. Overview and Predictive Analysis of Taiwan's Carbon Fee System

 After the passage of the Climate Change Response Act, the carbon fee system has entered the substantive promotion stage. Starting in 2024, specific emission sources will be announced, and the tax is expected to be levied in 2025~2026, and the initial management target will be public institutions emitting more than 2.5 tons of CO₂e, with administrative pricing, with an estimated price of 300~800 yuan/ton. The inventory data will be used as the basis for carbon fee collection, and the scope of management will be gradually expanded to small and medium-sized enterprises and service industries. (Please refer to Figure 3: Taiwan Carbon Fee Risk Simulation Dashboard) 

B. Carbon Trading System Trends and Participation Opportunities

 In the future, Taiwan may introduce the Carbon Trading Market (ETS), combining voluntary reduction projects (VERs) with carbon credit registration systems. If companies can plan in advance to register carbon reduction projects and develop quotas, they can not only offset carbon fees, but also have market trading potential and corporate ESG asset benefits. 

C. Three major corporate response strategies 

1. Establish a carbon fee risk simulation model: Estimate corporate cost exposure with multi-scenario rates, and generate heat maps and carbon fee dashboards.

 2. Build a carbon asset and carbon credit strategy library: Take stock of carbon reduction potential, plan project registration and offset quota development. 

3. Introduce an internal carbon pricing system: Establish a shadow carbon price and carbon budget system to incorporate it into capital decision-making and project evaluation basis. 

The above strategies can be used as governance tools for companies to move towards carbon neutrality and financial integration, and to cultivate resilience in the climate economy in advance.  

Taiwan's carbon fee simulation description and dashboard design conditions (please refer to it) 

1. Scope and scope of carbon fee application 

According to the Ministry of Environment's plan, the carbon fee system is currently only levied on "Scope 1" and "Scope 2" emission sources, excluding "Scope 3" upstream and downstream emissions. 

This simulation excludes Scope 3 and focuses on the emission items that will actually be included in the carbon fee levy. 

2. Carbon fee simulation setting 

emission assumptions are as follows: 

(1)Scope 1 (own fuel): 1,200 tCO₂e 

(2) Scope 2 (purchased electricity): 2,500 tCO₂e

 Simulated rate setting: 

1. Preferential A: 50 yuan/ton 

2. Preferential B case: 100 yuan/ton

3. Benchmark C case: 300 yuan/ton 

4. Policy scenario: 800 yuan/ton

5. High-intensity scenario: 1,500 yuan/ton

 3. Application purpose 

This simulation can help enterprises predict the potential carbon fee burden under different policy scenarios based on actual emission levels, and serve as a basis for budgeting, risk disclosure, and departmental performance improvement. 

4. Supplementary explanation

 If enterprises achieve voluntary reductions or propose clear transformation plans, they can strive to be included in the Ministry of Environment's preferential program (case A or B) to reduce the initial rate pressure. 

Chapter 6 Conclusion: From Inventory to Sustainable Transformation  

6.1 Inventory as a starting point for corporate sustainable development

 After the passage of Taiwan's "Climate Change Response Act" in 2023, the legal foundation for the "carbon fee system" was officially laid, and the Ministry of Environment initiated the phased implementation. According to the plan, specific high-emission source projects will be announced from 2024, and carbon fees will be gradually introduced between 2025~2026. At the same time, the competent authority is also considering the establishment of a domestic voluntary carbon credit and carbon trading system in the future. These systems will significantly change the cost structure of corporate carbon emissions, and will also affect future financial ratings, supply chain supplier selection, ESG investment performance, and policy compliance risks. Therefore, "carbon fee risk management" and "carbon asset layout" will become the core issues of the next sustainable competitiveness of enterprises. This section will explore how companies can prepare for response from three levels: 

1.Carbon fee system analysis and cost simulation 

2.carbon trading system trends and participation opportunities 

3.Internal corporate response strategic planning

 A. Overview and predictive analysis of Taiwan's carbon fee system 

The core of the carbon fee system is "polluter pay", that is, companies calculate fees based on their actual emissions (metric tons of CO₂e), and the government sets up a special carbon fee account to subsidize carbon reduction and technological transformation.

 Up to now, the main features of the carbon fee system include:  

Bu-Jhen observed: Although the carbon fee system is mainly for high-emission businesses in the early stage, small and medium-sized manufacturing and service industries will gradually expand to include in the later stage, and their inventory data will become the basis for the carbon fee forecast list. 

B. Carbon Trading System Trends and Participation Opportunities

 Based on international experience, most countries that have established carbon fees will eventually gradually promote the "Emissions Trading System (ETS)" to induce reductions in a market-oriented manner. Taiwan has also authorized the establishment of a voluntary carbon credit registration and trading mechanism in the "Climate Change Response Act", which may be developed into a cross-border carbon credit trading platform that 

1.connects some industry-based ETS pilots (such as electricity, steel, and cement) 

2.in the domestic voluntary carbon market (DVCM) 

3. international carbon markets (such as CORSIA, Article 6 ).

 Opportunity tip: If companies can register their own carbon reduction projects early and accumulate tradable carbon credits (VERs), they can not only offset carbon fees in the future, but also resell them to the market for additional income. 

C. Three key strategies for enterprises to deal with carbon fees and trading 

Bu-Zhen suggests that enterprises can start planning their carbon fee and carbon credit management framework from the following three directions: 

1. Establish a carbon fee risk simulation model

1.  based on the annual inventory results (tCO₂e) and use multiple rate scenarios (such as 300/800/1500 yuan) to simulate future financial impacts ,

2. incorporate three-year forecasts, revenue ratio and gross profit ratio analysis

3.  and combine carbon cost heat maps. 

Suggestions for tools to grasp high emission sources and prioritize improvements: Establish a "Carbon Fee Pressure Dashboard" as the content of the board's climate risk briefing 

2. Build a carbon asset and carbon credit strategy library 

1.  evaluate carbon reduction projects that can be developed in the supply chain (such as renewable energy, energy conservation improvements, alternative fuels, etc.)

2. collect various offset certification qualifications (such as voluntary reduction projects, international standard carbon credits such as VCS/Gold Standard)

3.  plan to apply for domestic carbon credit registration, Third-party verification and trading platform resale path 

strategy tips: Carbon credits will become part of the company's future ESG assets, with the triple value of fee reduction, transaction, and reputation bonus 

3. Introduce an internal carbon pricing system

1.  to set an internal carbon price (you can refer to the government's recommended price range) 

2. Build a carbon budget system based on investment evaluation, equipment replacement, and project prioritization , 

3. and give practical application to departments or sites emission quotas :

 It can be integrated with the SBTi pathway, carbon neutrality strategy, and departmental energy conservation plan to establish quantitative targets and incentive mechanisms

Bu-Zhen's point of view: Prophet first, carbon risk management is asset management, 

and the carbon fee system is not a punishment, but a pricing of risk signals. When companies can predict risks, control costs, and activate carbon assets from carbon data, carbon management is no longer just a "matter for environmental protection units" but a corporate competition project jointly promoted by the Finance Department, Strategy Department, and Chief Sustainability Officer. 

Bu-zhen suggested that companies incorporate carbon fee strategies into their medium-term business plans and build a complete "carbon accounting framework" - from emission data→ risk simulation→ internal pricing→ offset planning→ trading strategies, and grasp the pace of net-zero transformation throughout the entire process in order to win steadily in the era of carbon economy.

6.2 Conclusion and Suggestions of Bu-Jhen Low-Carbon Strategy 

In today's world where carbon governance is gradually institutionalized and data transparency has become a corporate obligation, greenhouse gas inventory is no longer just a technical task of "disclosing a report" or "responding to regulations", but an honest disclosure of the environmental impact of a company's operation process, and a deep governance revolution related to risk control, business transformation, and social responsibility. 

The core message of this report can be condensed into one sentence: "Carbon inventory is not the end, but the starting point for enterprises to move towards net zero."

 6.2.1 Carbon inventory is the cornerstone of the disclosure system

from CDP questionnaires to GRI 305 emission indicators, from TCFD to IFRS S2, all mainstream disclosure frameworks around the world start with carbon emission information. Taiwan is about to implement a carbon fee system, and inventory data will be included as the basis for taxation. If companies do not establish traceable and verifiable emissions data processes, they will not only face compliance risks but also cannot participate in the increasingly emerging green finance and low-carbon procurement markets. 

Bu-zhen suggested that companies should regard inventory as "the first report of internal ESG governance" and rank their importance alongside financial reports and risk reports. 

6.2.2 Inventory is a cross-departmental organizational project 

Promoting greenhouse gas inventory is not a solitary task for sustainability departments. Successful companies often establish an operating model authorized by the board of directors, supported by senior executives, and cross-departmental collaboration, combined with administration, engineering, finance, information, and legal departments. The six internal construction steps and Gantt chart framework proposed in this report are designed to help companies advance their inventory systems with project management logic and ensure annual stability, data consistency, and organizational memory continuity.

 6.2.3 Digitalization is a necessary condition for carbon management to move towards the decision

making level Digital tools for carbon inventory are no longer a plus option but a basic condition. From data collection, evidence tracking, departmental responsibility traceback, report transfer, disclosure simulation, and risk scenario assessment, data platforms must be efficiently integrated. The introduction of the platform can also establish a "carbon operation indicator dashboard" for enterprises, strengthen the basis for board decision-making, and lay the foundation for aligning with financial disclosures such as SBTi and IFRS S2.

 6.2.4 Carbon fees and carbon trading are costs and opportunities

 In the future, whether it is a carbon fee price of 300, 800, or 1,500 yuan/ton, companies must prepare financial simulations and hot spot management in advance. More importantly, carbon costs are no longer one-way expenses, but can be transformed into "strategic bargaining chips" through carbon credit development, internal carbon price strategies, and energy improvement investments for recovery and risk offset. If companies can deploy ahead of time, such as establishing internal carbon fee models, participating in carbon credit applications, and allocating carbon disclosure talents, they have the opportunity to become beneficiaries of the "first responder advantage" after carbon pricing policies are formed. 

6.2.5 BuJhen's view: Let carbon become an asset, not a burden 

Carbon is not a burden for enterprises, but an unmanaged risk and unreleased value. The Buzhen Low Carbon Strategy calls on all companies that are moving towards sustainability: 

1. starting from the inventory, incorporating carbon into the core of governance; 

2. use data to speak and turn carbon reduction into performance indicators;

3.  rely on the implementation of the system to turn carbon disclosure into reputation and trust;

4.  Connect carbon to finance and turn climate action into a competitive strategy. Inventory is a current regulatory requirement, but it is also the basic language expected by the future market. 

If enterprises can master the structural logic and strategic application of carbon inventory, they can take the initiative in the transformation process and become the leader of the new climate economy.