TL;DR — Taiwan’s carbon exchange recorded only 5 trades in 18 months. Looks like market failure. But SSBTi’s position and Prof. Tung’s view are clear: the NT$300 carbon fee is by design — to push firms to reduce themselves, not to buy credits. Three prices across one supply chain (NT$300 / 3,000–4,000 / CBAM ~2,790) reflect firm readiness, not policy weakness. Real “carbon economy thinking” isn’t waiting for government to raise prices — it’s firms proactively raising their own internal shadow prices and pursuing SBTi / TNFD / CDP three-track third-party verification. This is SSBTi’s consistent position.

The same supply chain, the same tonne of carbon — in Taiwan today, three different prices.

Pay it as a carbon fee, NT$300/tonne. Buy a credit on the Taiwan Carbon Solution Exchange, NT$3,000–4,000/tonne. Ship to the EU and CBAM converts your implied carbon cost to around NT$2,790/tonne (based on Q1 2026 certificate price €75.36/t).

Last week’s UDN “Sunshine Project” investigation reported a number that made a lot of people stop: Taiwan’s carbon exchange has recorded a grand total of five trades, 69 tonnes in 18 months.

Most reflexive reactions: “The market is failing.” But SSBTi’s position — backed by Prof. Ching-Pin Tung (NTU Bioenvironmental Systems Engineering, SSBTi honorary director) — is the opposite: this isn’t failure, it’s evidence the policy design is working as intended. Today’s piece spells out this counterintuitive view and what firms should actually do.

Five Trades Isn’t Market Failure — It’s the System Succeeding

Prof. Tung’s message to SSBTi on 2026-05-12 cut to the point:

“The carbon fee is only NT$300, with discount rates available, so it can’t drive demand for carbon credits; carbon neutrality is too hard, which also reduces credit demand; net-zero only allows removal credits for 2050 residual emissions. All of these limit credit market development.”

SSBTi President Raymond Wang’s 2026-05-12 Facebook post further articulated the official position:

“Carbon credits aren’t decarbonization. Corporate management and third-party verification are what actually deliver net-zero target reductions.”

The key insight: the NT$300 carbon fee — with NT$50–100 discount rates for approved self-reduction plans — isn’t a “cheap option to buy out of.” It’s the policy drawing a red line: invest your money in your own factory’s decarbonization, not into the market buying someone else’s reductions to comply.

In other words, 5 trades isn’t a sick market — it’s the system functioning as designed. The problem isn’t weak policy signals; it’s that most Taiwanese firms haven’t received the signal yet. They’re still using “find the cheapest compliance path” old thinking against a regulation that says “reduce it yourself.”

Three Prices, Two Worlds: What’s Torn Is Firm Readiness

Place the three prices into an EU-bound supply chain and something interesting emerges.

EU-export Taiwanese manufacturers are already forced onto international-grade pricing by CBAM (~NT$2,790) and European customer supply chain contracts. Domestic-only firms see only NT$300. The price signal strength differs by nearly 9x — but this gap isn’t proof that “signals are too weak.” It’s a mirror of two levels of firm readiness.

EU-facing firms have already been pushed by the market to build internal carbon inventory capacity, third-party verification, supply chain carbon data governance — exactly what SSBTi has long advocated as “third-party verification + data governance.” Domestic-only firms see only NT$300 and stay at the “compliance if cheap enough” level.

This is why I say: what’s really tearing Taiwan’s supply chain isn’t price, it’s readiness. One company may run CBAM specs on its EU line and NT$300 specs on its domestic line, with the two investment logics warring against each other. But the answer isn’t “wait for government to raise domestic prices” — it’s: the firm itself decides to apply EU-export standards to domestic operations too, building unified internal carbon economic logic.

”Carbon Economy Thinking” Is an Internal Framing, Not Waiting for Government

I call this internal framing carbon economy thinking. It contrasts cleanly with three other mainstream mindsets:

Carbon compliance thinking treats carbon as a cost to be managed. “Government says pay, we pay; says report, we report.” Targets the minimum compliance bar. Most domestic Taiwanese firms are stuck here — because NT$300 is cheap, they pay and move on.

Carbon technology thinking treats carbon as an engineering problem. “Swap the equipment, optimize the process, polish the ESG report.” Familiar territory for in-house ESG teams — blind spot: without economic motivation, the technology doesn’t get deployed.

Carbon morality thinking treats carbon as the right thing to do. “Good for the planet, good for the next generation, CSR.” For most mid-sized firms doing margin math, motivation is thin.

Carbon economy thinking treats carbon as an internally-investable corporate asset. Its core question isn’t “should government raise the price?” but “as a firm, should I proactively raise my own internal shadow price to international-grade (e.g. CBAM NT$2,790), so all my internal decarbonization investment NPV calculations use that price?”

Critical difference: carbon economy thinking doesn’t require waiting for government policy change. It’s a decision the CFO and Chief Sustainability Officer make together: we adopt internal carbon pricing because that’s the only way to stay aligned with EU clients long-term, and to build a decarbonization path that can be verified by SBTi, CDP, and TNFD.

This aligns directly with Prof. Tung and Raymond Wang’s argument that “corporate management and third-party verification are what actually deliver net-zero” — the responsibility sits on the corporate side, not the policy side.

The Technology Has Always Existed — What’s Stuck Is the Corporate Spreadsheet

A clear feeling from years as SSBTi’s circular economy partner: the technology to decarbonize has always existed.

Manufacturers can lower electricity intensity, switch to lower-carbon fuels, recover waste heat, optimize compressed air — the technologies are here, the case sites are here. But many firms haven’t moved, because the spreadsheet in the executive’s head uses NT$300 as the carbon price.

A typical case: a mid-sized manufacturer evaluates a waste heat recovery system, projected to cut 1,000 tonnes CO₂/year, estimated investment NT$10M. At NT$300/tonne, the annual “carbon value” is just NT$300K — 33-year payback, project killed.

But if the firm itself decides to raise its internal shadow price to NT$2,790 (adopting CBAM’s international level as the internal investment benchmark), the same engineering’s annual “carbon value” becomes NT$2.8M, payback drops to 3.6 years, from uninvestable to investable.

The key is the four words “the firm itself decides.” Not waiting for government to raise the carbon fee, but the firm recognizing “EU compliance will eventually demand this level, SBTi pathway needs this level, CDP filings need this level” — and proactively writing this price into internal investment decisions. That’s “carbon economy thinking” in practice.

SSBTi’s Three Pathways: TNFD / SBTi / CDP, Not More Carbon Credits

Faced with the bind of “credits unavailable, credits don’t count even if bought, and credits carry greenwashing risk,” SSBTi’s official answer isn’t more credits — it’s a return to the fundamentals of corporate management, through three scientific pathways:

1. TNFD (Taskforce on Nature-related Financial Disclosures)

Enter through biodiversity. Reforestation and habitat protection stop being “credit swaps” and become “natural capital” disclosure. This pathway has real substance for manufacturing supply chains, especially upstream agriculture/forestry/fisheries.

2. SBTi (Science-Based Targets initiative)

Enter through the Environmental Mainframe. The point is the firm’s own carbon inventory passing third-party verification (ISO 14064-1 / 14067 / 14044). Real decarbonization credibility comes from scientifically verifiable pathways, not from buying credits. SBTi Net-Zero Standard mandates 90–95% physical reduction on the 1.5°C path; only 5–10% residual can be offset with permanent carbon removal (DAC, enhanced weathering, biochar). Avoidance credits are not recognized as net-zero tools.

3. CDP / Disclosure System Integration

Enter through customer-side disclosure systems (CDP, EcoVadis, brand customer questionnaires). Translate decarbonization outcomes into auditable disclosure data buyers accept. SSBTi has accumulated multiple success cases here.

The shared spine of these three pathways is “third-party verification” — firms building externally-auditable carbon data capability themselves. Buying credits is a complement, not the main course.

Same Supply Chain Axis as the CBAM Piece’s “Carbon Data Sovereignty”

My previous CBAM piece introduced “carbon data sovereignty” — whoever controls your carbon data controls who can price you. That was the international axis: when the EU defines your emissions through 2,400 pages of default values, your pricing power is in someone else’s hands.

This piece is the domestic-axis companion: when firms still use NT$300 as the carbon price benchmark in internal spreadsheets, their entire supply chain investment logic gets locked at that level. Both pieces share the same core argument — firms need to proactively build their own carbon data capability and set their own internal shadow price; they can’t wait for someone else to define their pricing.

  • CBAM piece: don’t let the EU define your carbon emissions
  • This piece: don’t let government define your internal decarbonization investment threshold
  • Together: third-party verification + internal carbon economy thinking = complete supply chain carbon governance

Conclusion: Carbon Credits Aren’t Decarbonization — Corporate Management + Third-Party Verification Is

Back to UDN’s 5 trades, 69 tonnes.

This isn’t market failure, it’s evidence of policy design succeeding — government uses NT$300 to tell firms “you should invest in cutting your own emissions, not come to market to buy someone else’s reductions.” The problem is most Taiwanese firms haven’t received the signal, still bringing “compliance thinking” to a regulation that says “cut it yourself.”

The way out isn’t more carbon credit projects or higher carbon fees — it’s a different framing: carbon economy thinking. CFOs and Chief Sustainability Officers together raise internal shadow prices to international levels, treating decarbonization as an investment portfolio that can be third-party verified by SBTi / TNFD / CDP.

This is exactly SSBTi’s consistent position:

Carbon credits aren’t decarbonization. Corporate management and third-party verification are what actually deliver net-zero target reductions.

Carbon credits are only one tool for the “last mile” (the 5–10% residual emissions on the net-zero path covered by removal credits). They’re not the main course. The main course is always the firm’s own inventory, verification, and quantifiable physical reduction.

And the starting point of this thinking is admitting one thing: NT$300 doesn’t decide the strength of government policy — it tests whether firms will proactively step out of compliance thinking and put on carbon economy thinking themselves.

When a firm still uses NT$300 in its internal investment spreadsheet, it’s telling every decarbonization technology provider, every decarbonization investor, every decarbonization startup — this isn’t worth much at our company. Then we complain “why doesn’t Taiwan have a decarbonization unicorn,” “why are all the green technologies in Europe,” “why doesn’t our supply chain keep up with international ESG standards.”

The answer isn’t on the government’s price tag — it’s on every firm’s own spreadsheet.

📌 SSBTi Official Position Statement

This piece extends SSBTi’s official position on the carbon credit market issued 2026-05-12: “Carbon credits aren’t decarbonization. Corporate management and third-party verification are what actually deliver net-zero target reductions.”

The full position document was formally published by SSBTi President Raymond Wang, citing Prof. Ching-Pin Tung’s (NTU Bioenvironmental Systems Engineering, SSBTi honorary director) analysis of four structural constraints on the carbon credit market. For any disputes regarding SSBTi’s official discourse, the SSBTi-published version is authoritative (SSBTi Facebook public post 2026-05-12 / SSBTi official site).

This piece is the author’s individual extension as an SSBTi circular economy partner. The argumentative direction aligns with SSBTi’s position; specific phrasing and examples reflect the author’s writing choices.

This piece extends from UDN’s “Sunshine Project” investigation: “Supply-demand mismatch — Taiwan’s carbon credit pricing market records only 5 trades in 18 months” (2026-05-12). It is the companion to CBAM and Carbon Data Sovereignty — the former covers international data-end contestation, this covers the domestic corporate framing shift. Both echo SSBTi’s core position of “third-party verification + corporate management.”