TL;DR: Taiwan’s carbon exchange recorded only 5 trades over 1.5 years, which looks like market failure. But SSBTi’s position and Prof. Tung Ching-Pin’s analysis are unambiguous: the NT$300 carbon fee was designed to force companies to reduce emissions themselves, not to push them into buying carbon credits. Three carbon prices in the same supply chain (NT$300 / NT$3,000–4,000 / CBAM ~NT$2,790) fracture corporate readiness, not policy logic. Real “carbon-economy thinking” means companies proactively raising their internal shadow price, not waiting for the government to act, and aligning with SBTi / TNFD / CDP triple-track third-party verification. This is SSBTi’s consistent position.
The same supply chain. The same metric ton of carbon. Three different prices, all in Taiwan, all today.
Paid to the government as a carbon fee: NT$300 per ton. Purchased as a carbon credit on the exchange platform: NT$3,000 to NT$4,000 per ton. And if your product is headed for the EU, CBAM works out to roughly NT$2,790 per ton in equivalent carbon cost (based on the 2026 Q1 certificate price of €75.36/t).
Last week’s “Sunshine Action” feature in UDN reported a number that stopped many readers cold: the carbon exchange’s fixed-price trading platform had recorded just five transactions, totaling 69 metric tons, in its first year and a half.
The instinctive reaction from most commentators was “market failure.” SSBTi and Prof. Tung Ching-Pin, Professor at NTU’s Department of Bioenvironmental Systems Engineering and SSBTi Honorary Director, read it the opposite way: this is not failure; it is evidence that the policy design is working. This article is my attempt to explain that counterintuitive judgment clearly, and to lay out what companies should actually be doing.
5 Transactions Isn’t Market Failure. It’s Policy Success
In a message to SSBTi dated 2026-05-12, Prof. Tung Ching-Pin was direct:
“The carbon fee is only NT$300, with preferential rate options on top of that, so there is no real incentive to buy carbon credits. Carbon neutrality is also very difficult to achieve, which further reduces demand. Under a net-zero pathway, offset credits can only be used for residual emissions after 2050, and only removal credits qualify. All of these factors structurally constrain carbon credit development.”
SSBTi Chairman Raymond Wang elaborated SSBTi’s position in a public Facebook post on 2026-05-12:
“Carbon credits are not emission reduction. Corporate management and third-party verification are what truly deliver net-zero.”
The core logic here: the NT$300 carbon fee, combined with preferential rates of NT$50–100 for voluntary reduction, was never meant to make buying credits an attractive option. It was a deliberate policy boundary: invest in reducing emissions at your own facility, rather than purchasing someone else’s reductions on the market.
In other words, five transactions doesn’t mean the market is sick. It means the policy is doing what it was designed to do. The problem is that most Taiwanese companies haven’t received that signal yet. They are still approaching a system built to force self-reduction with the old mental model of finding the cheapest compliance path.
Three Prices, Two Worlds: What’s Fractured Is Corporate Readiness
Place those three prices inside a supply chain that exports to Europe, and something interesting becomes visible.
Taiwanese manufacturers selling to the EU are already being pushed to international standards by CBAM (~NT$2,790) and the carbon provisions in their European customer contracts. Taiwanese companies selling only domestically face a policy that requires nothing more than the NT$300 carbon fee. The gap in the strength of the price signal between these two worlds is nearly ninefold. That gap is not evidence of a weak policy signal. It is a mirror reflecting two very different levels of corporate readiness.
Export-oriented companies have been forced by the market to build internal carbon accounting capacity, third-party verification systems, and supply chain carbon data governance. These are exactly the “third-party verification + data governance” capabilities SSBTi has been advocating for. Domestically focused companies see only the NT$300 fee and keep their thinking at the level of “pay it if it’s cheaper than the alternative.”
This is why I say: what is fracturing Taiwan’s supply chains is not the price differential itself. It’s the readiness gap. The same company might run CBAM-grade processes for its EU lines and NT$300-grade logic for its domestic lines, with two incompatible investment frameworks pulling in opposite directions. The solution to that contradiction is not waiting for the government to raise domestic carbon prices. It is a company deciding for itself: I will apply the same standard across both lines and build a unified internal carbon economics framework.
“Carbon-Economy Thinking” Is an Internal Corporate Framing. Not a Policy Bet
I call that internal corporate framing “carbon-economy thinking.” It stands in contrast to three other mindsets that are common today.
Carbon-compliance thinking treats carbon as a cost to manage. “The government says pay, so I pay. The government says report, so I report.” The goal is the lowest compliant threshold. Most domestically focused Taiwanese companies are stuck here: because NT$300 is cheap, they pay and move on.
Carbon-technology thinking treats carbon as an engineering problem to solve. “Upgrade the energy-efficiency equipment, optimize the process, make the ESG report look good.” In-house ESG teams and consultants know this playbook well. The blind spot: without an economic rationale, the technology never actually gets deployed.
Carbon-ethics thinking treats carbon as the right thing to do. “Good for the planet, good for future generations, corporate social responsibility.” For most small and mid-sized companies still running cost-benefit calculations, that motivation doesn’t move much.
Carbon-economy thinking treats carbon as an investable internal asset. The central question shifts from “when will the government raise the carbon price?” to “should I, as a company, proactively raise my internal shadow price to international levels, say, the CBAM benchmark of NT$2,790, so that every internal investment decision around emission reduction is evaluated against that NPV?”
The critical distinction: carbon-economy thinking requires no change in government policy. It is a decision made jointly by the CFO and the Chief Sustainability Officer: we will adopt internal carbon pricing, because doing so is what allows us to stay aligned with EU customers over the long term and to build a reduction pathway that can be verified by SBTi, CDP, and TNFD.
This is the same logic behind what Prof. Tung and Raymond Wang are saying: “corporate management and third-party verification are what truly deliver net-zero.” The responsibility sits with companies, not with policy.
The Technologies Already Exist. They’re Stuck in Corporate Spreadsheets
Working as SSBTi’s circular economy partner over these years, one thing has become clear to me: the decarbonization technologies already exist.
Manufacturers can lower electricity intensity, switch to lower-carbon fuels, recover waste heat, optimize compressed air systems. The technology is there. So are the sites. But many companies haven’t moved, because the number sitting in the owner’s mental spreadsheet is NT$300 per ton.
A concrete example: a mid-sized manufacturer evaluates a waste heat recovery system projected to cut 1,000 tons of CO₂ annually, with an estimated capital cost of NT$10 million. Calculated at NT$300 per ton, the annual “carbon value” is NT$300,000, a payback period of 33 years. The project dies.
Now suppose the company itself decides to set its internal shadow price at NT$2,790 per ton, adopting the CBAM rate as an internal investment benchmark. The same project generates an annual “carbon value” of NT$2.79 million. Payback: 3.6 years. The project moves from uninvestable to viable.
Everything turns on those four words: “the company itself decides.” Not waiting for a carbon fee hike, but recognizing: “EU compliance will eventually require this level anyway. SBTi alignment requires it. CDP disclosure requires it.” Then writing that number into internal investment decisions. That is carbon-economy thinking in practice.
SSBTi’s Three-Track Solution: TNFD / SBTi / CDP. Not More Carbon Credits
Faced with the reality that carbon credits are hard to acquire, don’t count for much, and carry greenwashing risk, SSBTi’s formal solution is not more carbon credits. It is a return to corporate management fundamentals through three science-based pathways:
1. TNFD (Taskforce on Nature-related Financial Disclosures)
Entering through the lens of biodiversity. Reforestation and habitat conservation are no longer about purchasing carbon credits. They become disclosures of natural capital. For manufacturers managing upstream supply chains in agriculture, forestry, and fisheries, this track carries particular practical weight.
2. SBTi (Science Based Targets initiative)
Entering through the lens of what SBTi calls the Environmental Mainframe. The focus is corporate carbon accounting verified by third-party auditors under ISO 14064-1, ISO 14067, and ISO 14044. Real decarbonization credibility comes from a verifiable, science-based pathway, not from purchasing credits. The SBTi Net-Zero Standard specifies that a 1.5°C pathway requires 90–95% physical emission reductions, with only 5–10% residual emissions eligible for permanent carbon removal (DAC, enhanced weathering, biochar). Avoidance credits are not recognized as net-zero instruments.
3. CDP / Disclosure System Integration
Entering through the lens of buyer-side reporting systems: CDP, EcoVadis, brand customer questionnaires. This track converts verified emission reductions into disclosure data that purchasing companies recognize. SSBTi has accumulated multiple successful cases in this area.
The common backbone across all three tracks is third-party verification: companies building internally auditable carbon data capacity. Carbon credits are a supplementary tool, not the main course.
The Same Supply Chain Axis as the CBAM Piece on Carbon Data Sovereignty
My earlier CBAM article introduced a concept I called “carbon data sovereignty”: whoever controls your carbon data controls who gets to price you. That article worked along the international axis. When the EU uses its 2,400-page default values document to define your emissions, the pricing power sits entirely on the other side of the table.
This article is the domestic companion. When a company still benchmarks internal investment decisions against NT$300 per ton, the entire supply chain’s decarbonization investment logic is locked at that level. The underlying argument in both articles is the same: companies need to proactively build their own carbon data capabilities and set their own internal shadow prices. They cannot afford to let someone else define those numbers for them.
- CBAM article: don’t let the EU define your carbon emissions figures
- This article: don’t let the government define the price benchmark for your decarbonization investments
- Together: third-party verification + carbon-economy thinking = complete supply chain carbon governance
Conclusion: Carbon Credits Are Not Decarbonization. Corporate Management and Third-Party Verification Are
Back to UDN’s 5 trades, 69 metric tons.
This is not market failure. It is evidence that the policy design is working: the government set NT$300 to tell companies “invest in reducing your own emissions, not in buying someone else’s reductions on the market.” The problem is that most Taiwanese companies haven’t received that message yet, and are still applying compliance thinking to a system designed to force self-reduction.
The way forward doesn’t require more carbon credit projects, and it doesn’t require a higher carbon fee. It requires a different framing: carbon-economy thinking. CFOs and Chief Sustainability Officers working together to raise the internal shadow price to international levels, treating decarbonization as an investment portfolio that can be verified by SBTi / TNFD / CDP third parties.
This is exactly what SSBTi has consistently advocated:
Carbon credits are not emission reduction. Corporate management and third-party verification are what truly deliver net-zero.
Carbon credits are one tool for the final mile, removal credits covering the 5–10% of residual emissions at the end of a net-zero pathway. They are not the main course. The main course is always the company’s own internal accounting, verification, and measurable physical emission reductions.
And that whole approach starts with acknowledging one thing: NT$300 does not define the government’s policy ambition. It defines whether each company chooses to move beyond compliance thinking and adopt a carbon-economy mindset on its own terms.
When a company still runs internal investment decisions against NT$300 per ton, it is telling every decarbonization technology provider, every climate-focused investor, every clean-tech startup: this problem isn’t worth much inside our walls. Then we ask why Taiwan has no decarbonization unicorns, why clean energy technology clusters in Europe, why our supply chains can’t meet international ESG standards.
The answer isn’t on the government’s price tag. It’s on each company’s own spreadsheet.
📌 SSBTi Official Position Statement
This article extends SSBTi’s official position on carbon credit markets as stated on 2026-05-12: “Carbon credits are not emission reduction. Corporate management and third-party verification are what truly deliver net-zero.”
The full position statement was formally published by SSBTi Chairman Raymond Wang (汪瑞民) and references Prof. Tung Ching-Pin’s (NTU Department of Bioenvironmental Systems Engineering; SSBTi Honorary Director) assessment of four structural constraints on the carbon credit market. For any questions about SSBTi’s official stance, the authoritative version is SSBTi’s formally published text (SSBTi Facebook public post, 2026-05-12 / SSBTi official website).
This article represents the author’s personal observations as an SSBTi circular economy partner, developed in alignment with SSBTi’s position. Specific phrasing and examples reflect the author’s own writing judgment.
This article extends from the UDN Sunshine Action feature “Supply-Demand Imbalance: Fixed-Price Carbon Credit Trading Records Only 5 Transactions in 18 Months” (2026-05-12). It is a companion piece to my earlier article on CBAM and Carbon Data Sovereignty: that article addresses the international data front; this one addresses the framing shift required on the domestic corporate side. Together, they reflect SSBTi’s core position: third-party verification and corporate management as the foundation of credible decarbonization.
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