COMMENTARY: China poised to evolve from rule-taker to rule-shaper at ICAO Assembly

As the 42nd ICAO Assembly convenes in Montreal, China’s civil aviation sector is undergoing a dynamic and policy-driven green transition. Domestically, implementation is accelerating – from carbon peaking action plans and market instruments to regional pilots and industry-wide standards. This surge in regulatory momentum and technological innovation is positioning China not merely as a participant in global aviation climate governance, but as a proactive contributor and institutional designer. China is poised to play a transformative role in shaping the future of sustainable aviation, writes David Ma. It will offer proposals rooted in Chinese characteristics, development-oriented logic and equity principles. This shift reflects not only the transformation of China’s civil aviation sector but also its broader international climate responsibility.

China’s green aviation transition is anchored in top-level policy design and systemic reform. In recent years, the Civil Aviation Administration of China (CAAC) has introduced a comprehensive framework that links strategic vision with operational mechanisms.

The 14th Five-Year Plan for Civil Aviation Development aligns closely with the national 14th Five-Year Plan and the Outline for Building China into a Transportation Power. The accompanying Green Civil Aviation Development Plan further refines the roadmap, setting clear targets for reducing carbon intensity, accelerating green airport construction, piloting sustainable aviation fuels (SAF) and exploring carbon market mechanisms. Regulatory instruments such as the Green Terminal Standards and the Guidelines for Monitoring Carbon Emissions from Flight Activities are gradually building a standardised framework for green aviation.

To enhance cross-sectoral coordination, CAAC established a Leading Group on Carbon Peaking and Carbon Neutrality. At its second meeting in February 2025, the Group emphasised the need to:

• Elevate green and low-carbon transition to the core of high-quality civil aviation development;

• Promote coordinated progress in low-carbon energy adoption, carbon market development, and operational efficiency;

• Balance development and emission reduction, autonomous action and international cooperation; and

• Actively engage in global aviation climate governance and contribute “Chinese wisdom and Chinese solutions”.

Technology-driven innovation

Technological innovation serves as the second pillar of China’s green aviation strategy. The sector is advancing key technologies and deploying them across operational scenarios, with a particular focus on SAF and energy efficiency.

In air traffic management, route optimisation and refined scheduling have saved 360,000 tons of aviation fuel over five years. More than 30% of airport vehicles are electric, APU replacement equipment usage exceeds 95% and annual photovoltaic generation surpasses 60 million kWh – collectively reducing emissions by approximately 3.5 million tons annually.

SAF development has been integrated into multiple national-level plans, including the Carbon Peaking Action Plan before 2030, the Bioeconomy Development Plan, the Energy Technology Innovation Plan and the Green Civil Aviation Development Plan. These documents call for:

• Accelerated R&D and industrialisation across the SAF value chain, including feedstock cultivation, refining, certification, logistics and fuelling;

• Deep integration of innovation and industrial ecosystems to build a full lifecycle framework; and

• Implementation of tax incentives across VAT, corporate income tax and consumption tax to reduce enterprise costs and stimulate market demand.

In 2024, CAAC and the National Development and Reform Commission jointly launched SAF pilot programmes involving major carriers Air China, China Eastern and China Southern, and airports such as Beijing Daxing, Chengdu Shuangliu, Zhengzhou Xinzheng and Ningbo Lishe. Phase II will begin in 2025, with an estimated 42,000 flights completed.

Market-driven mechanisms

Market mechanisms are emerging as the third driver of China’s civil aviation decarbonisation. The country is steadily advancing its national carbon market and has signalled its intent to include the aviation sector in future expansions. This reflects China’s strategic emphasis on carbon pricing and its desire to retain autonomy over emissions governance.

In the aviation domain, China is developing a domestic carbon market covering aviation transport activities, with pathways for integration into the national emissions trading system. Policy frameworks call for a mechanism that is “operationally feasible, regulatorily controllable, and internationally communicable,” while enhancing the recognition of China’s Certified Emission Reduction (CCER) projects within global offset systems.

By contrast, ICAO’s CORSIA mechanism continues to face scepticism from developing countries. Its reliance on “incremental offsetting” has been criticised for overlooking disparities in development stages and historical responsibility. Chinese experts argue that CORSIA’s one-size-fits-all design risks undermining development rights and exacerbating competitive imbalances in global aviation.

China has made its position clear: it is committed to building a carbon market system with Chinese characteristics and incorporating the aviation sector therein. If ICAO’s current framework fails to address China’s core concerns – fairness, flexibility, development space and institutional autonomy – China may adopt a “strategic shelving” approach: maintaining technical readiness and institutional evaluation without full alignment or mandatory participation.

This stance reflects not only a prudent response to international mechanisms but also China’s growing institutional agency and strategic initiative in shaping global aviation climate governance.

Global engagement and strategic outlook

The 42nd ICAO Assembly presents a pivotal opportunity for China to showcase its civil aviation green transition on the global stage. Domestically, the push toward carbon neutrality is in full swing, backed by robust policy execution and technological innovation. This momentum is strengthening China’s confidence and voice in international aviation climate discourse.

Historically, China’s role in ICAO and other multilateral mechanisms has often been characterised by passive compliance or technical alignment. Today, however, China has built a comprehensive domestic governance framework for green aviation and is actively proposing replicable, system-level “Chinese solutions” across multiple domains, including green airport evaluation systems, SAF value chain development and carbon market mechanism design.

China has submitted Working Paper A42-WP/112 EX/51, which reaffirms its longstanding positions on the principles of the UNFCCC and Paris Agreement, the development rights of developing countries and the need for financial and technological support from developed nations. Notably, the paper dedicates specific sections to China’s domestic achievements in green aviation and offers critical responses to ICAO’s climate targets and the CORSIA mechanism.

China argues that both the Carbon Neutral Growth (CNG 2020) and Long-Term Aspirational Goal (LTAG 2050) lack sufficient technical and economic feasibility analysis and may impose disproportionate burdens on developing countries. It calls for LTAG monitoring and reporting (LMR) to be implemented at the national level, integrated with assessments of financial and technological support. CORSIA, in turn, should be optimised and revised to allow countries greater autonomy in determining baselines, offset products and standards.

Against this backdrop, China is expected to advance several strategic propositions at the Assembly:

• Decoupling participation from prescriptive timelines: ICAO’s LTAG 2050 and the 2027 enforcement phase of CORSIA may carry procedural significance, but they should not be interpreted as binding deadlines for China’s participation. Until ICAO formally addresses China’s concerns, these targets will remain subject to ongoing evaluation. China will continue to assess its carbon neutrality timeline and engagement pathway based on domestic progress, technological maturity, negotiation outcomes and fairness assessments – ensuring a balanced approach to national interests and global responsibilities.

• Proposing “Domestic effort as equivalent international contribution”: While China may not adhere to ICAO’s prescribed timelines for CORSIA participation, it intends to treat domestic achievements – such as carbon market development, SAF deployment, and operational efficiency gains – as equivalent contributions toward ICAO’s climate goals. China plans to submit a revised Framework of the Nationally Determined Plans to Implement the CORSIA (NDPIC 2.0), aligned with domestic actions, for ICAO’s review and consideration.

• Advancing regional cooperation mechanisms: In Working Paper A42-WP/452 EX/203, China proposed the joint development of a ‘Green Air Silk Road’, a landmark initiative that underscores its leadership in green aviation. China aims to establish cooperative platforms with regional aviation organisations across ASEAN, Central Asia, Africa, Latin America and the Middle East. This inclusive global mechanism will enhance China’s leadership role and foster South-South collaboration in sustainable aviation.

• Showcasing new productive forces and technological achievements: Through demonstrations of green airport construction, SAF pilot programmes and electrified airport operations, China seeks to reinforce its influence in ICAO’s technical standard-setting processes and highlight its contributions to global innovation.

At the 42nd ICAO Assembly, China is poised to evolve from participant to rule-shaper – offering institutional proposals rooted in Chinese characteristics, development-oriented logic and equity principles. This shift reflects not only the transformation of China’s civil aviation sector but also its broader role in global climate governance.

As domestic carbon neutrality efforts deepen and institutional innovations continue to emerge, China will present more systematic and actionable “Chinese solutions” on the international stage. These proposals will not only address China’s development needs but also offer new governance pathways for the global aviation sector. China is no longer a passive participant – it is a proactive contributor and institutional architect. The world is watching, and China is ready to lead.

About the author

David Ma

Dr Xiangshan (David) Ma, who has long worked in China’s civil aviation industry, has been involved in tackling climate change and has experienced the historical transition of China’s civil aviation from energy conservation and emission reduction to carbon neutrality. After leaving the civil aviation industry, he has worked with the Global CCS Institute, Energy Foundation China, GIZ, and FutureCoal (formerly World Coal Association) on CCU/S and energy transition. Currently, he serves as an independent consultant on energy transition and climate change. He can be contacted at maxiangshan.2010@tsinghua.org.cn.

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