Environmental Resource Management under the "Dual Carbon" Goals

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From energy consumption dual-control to carbon emission dual-control — environmental management for data centers is undergoing a paradigm shift.

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Policy Context: From Energy Dual-Control to Carbon Dual-Control

China is undergoing a major transition in energy management policy. The State Council's 2024 Opinions on Accelerating Comprehensive Green Transition of Economic and Social Development explicitly advances the shift from total energy consumption and intensity dual-control (energy dual-control) to total carbon emission and intensity dual-control (carbon dual-control).

This has profound implications for the data center industry:

Policy Phase	Core Metrics	Impact on Data Centers
Energy Dual-Control	Total energy consumption + Energy consumption per unit GDP	PUE becomes the core constraint indicator · Energy quota limitations
Carbon Dual-Control	Total carbon emissions + Carbon emissions per unit GDP	Carbon offset effects of green electricity procurement formally recognized · Carbon accounting becomes a compliance necessity
Future Trend	Carbon market coverage of data centers	CCER carbon credits become tradable assets · Carbon emission costs internalized

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Energy Management

PUE Requirements

Region	PUE Cap	Basis
National computing hub nodes ("East Data West Compute")	≤ 1.25 (new large and above ≤ 1.20)	发改高技〔2021〕1742号
Other regions	≤ 1.30 (annual average)	GB 40879-2021 Grade 2 energy efficiency
Beijing and other Tier-1 cities	≤ 1.35 (punitive electricity pricing above this)	Local policy

Renewable Energy Procurement

- Green Electricity Certificates (GECs): Purchased through Beijing/Guangzhou Power Exchange Centers, offsetting Scope 2 carbon emissions

- Green electricity trading: Direct purchase of wind/solar PPAs to obtain Green Electricity Certificates

- Source-Grid-Load-Storage integration: Western hub nodes require ≥ 60% green electricity for new DCs

Carbon Credit Pathways

Mechanism	Current Status
CCER (China Certified Emission Reduction)	Restarted October 2023; data center methodology not yet released — monitor closely
Carbon Inclusive (碳普惠)	Piloted in Beijing, Shenzhen, and elsewhere; small-scale offsets available
National Carbon Market (ETS)	Phase III (2026–2030) plans to include data centers — threshold of > 26,000 tCO₂/year under discussion

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Water Resources Management

WUE (Water Usage Effectiveness)

Target: ≤ 1.0 L/kWh (annual average, Tier 2 "Community Mutual Benefit" requirement). Tier 3 encourages better performance.

Cooling Methods & Water Stress

Water Stress Level	Cooling Method Options
Low–Medium	Air cooling · Closed-loop cooling — both acceptable
Medium–High	Air cooling or closed-loop cooling only — evaporative/once-through cooling prohibited
Extremely High	Closed-loop dry cooling only — mandatory water balance replenishment

Assessment basis: WRI Aqueduct or water stress evaluations published by local water resource authorities.

Water Rights Trading & Balance Replenishment

In water rights trading pilot regions (Ningxia, Inner Mongolia, etc.), data centers can achieve equivalent water balance replenishment through water rights purchases. Non-pilot regions are encouraged to achieve equivalent replenishment through water infrastructure restoration (pipe network leakage remediation, agricultural drip irrigation retrofitting) or wetland recovery.

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Waste Heat Utilization

Utilization Pathways

Pathway	Applicable Scenario	Technical Requirements
District Heating	Northern heating cities	Output water temperature ≥ 60°C — heat pump boosting required
Greenhouse Agriculture	Suburban agricultural facilities	Output water temperature ≥ 30°C — direct use
Industrial Preheating	Adjacent factories	Customized to process requirements
Seasonal Thermal Storage	Summer waste heat stored → winter utilization	Borehole thermal storage or large-scale water tank thermal storage

Reference Cases

- Alibaba Zhangbei Data Center — waste heat recovery for office buildings and surrounding facilities heating

- Tencent Tianjin Data Center — waste heat recovery for greenhouse agriculture

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PFAS & New Pollutants Management

Current Status

The potential risks of PFAS (per- and polyfluoroalkyl substances) in data center cooling systems are attracting global attention — primarily manifesting in coolants, firefighting foams, and construction materials.

⚠️ China's PFAS Regulatory Status: China has brought PFAS-type substances under regulatory purview through the New Pollutants Governance Action Plan (2022), and the Ministry of Ecology and Environment has published the List of Key Controlled New Pollutants (2023 edition). However, there is currently no dedicated mandatory standard for PFAS emissions from data centers, representing a different regulatory stage and development pathway compared to the US EPA's PFAS MCL and the EU REACH PFAS restrictions.

This Framework's Recommendations

- In areas where unified Chinese standards are absent, reference international mainstream standards for selecting low-PFAS or PFAS-free coolants and materials

- Incorporate PFAS management into the Environmental Management System (EMS)

- Publicly disclose the composition inventory of coolants and firefighting materials used

- Track the latest developments in MEE's new pollutants governance

📅 Data as of: June 2026. China's New Pollutants Governance Action Plan and List of Key Controlled New Pollutants are under continuous updates; periodic verification of the latest versions is recommended.

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