Global Public Policy and Governance (2023) 3:219–242

https://doi.org/10.1007/s43508-023-00071-4

RESEARCH ARTICLE

National stances and governance systems: a comparative

study of low carbon governance in Germany, the United
States, and China

Rong Tan1 · Yujie Zhu1

Received: 18 January 2023 / Accepted: 1 July 2023 / Published online: 26 July 2023
© The Author(s), under exclusive licence to Institute for Global Public Policy, Fudan University 2023

Abstract
Due to the growing threat of global warming, low carbon governance has become a
worldwide challenge. However, there is great variation in low carbon performance
across countries, which can seriously affect the achievement of global low carbon
governance targets. To address this issue, this study analyzes the distinctions in
climate stances and low carbon governance systems among Germany, the United
States, and China. Then, a comparative analysis of these countries is presented, pay-
ing attention to their climate stances, their vertical governmental structure, and the
interaction of government, market, and society. We find that it is no single factor
but rather the combination of critical distinctions in climate stances and governance
systems that creates the heterogeneity of national climate actions and performances.
Finally, we put forward suggestions on how to further promote global climate
governance.

Keywords Low carbon governance · National stance · Climate governance system ·

Comparative study

1 Introduction

Low carbon governance is highly prone to shifting responsibilities, as it essentially

aims to address externalities at a global scale, which implies that achieving a joint
force in global climate governance is not easy (Puppim De Oliveira & Qian, 2023;
Tan, 2021). Different countries have different concerns based on national interests,
leading them to take different stances on climate governance. To gain more interna-
tional influence, countries with the same or similar interests form “groups", and the
current leading groups include the European Union (EU), the Umbrella Group, and

* Yujie Zhu
12122084@zju.edu.cn
1
School of Public Affairs, Zhejiang University, Hangzhou, China

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220 R. Tan, Y. Zhu

the BASIC countries. While it is impossible for any two countries to be on the same
page for every climate issue, membership in the same group can certainly be taken
as evidence of shared positions on some important climate issues.
The EU has long been committed to leading global climate negotiations and has
consistently taken a proactive attitude toward low carbon governance (Bäckstrand
& Elgström, 2013). Due to the close ties between the member countries in politics
and economy, they elaborate common positions on climate issues. Promoting global
climate governance is beneficial to the economic interests of EU member countries,
as they are already in pioneering positions in developing clean energy and emission
reduction technologies. The extremely high level of social support also makes cli-
mate action imperative in the EU. Therefore, since the early 1990s, the EU has been
seeking ways to establish a legally binding international climate institution system
(Cross, 2018) and formulate ambitious international goals on climate governance
(Oberthür & Groen, 2018).
The Umbrella Group is a loose coalition of non-EU industrialized countries, such
as the United States, Japan, Canada, and Australia. Most of the Umbrella Group
members are countries whose domestic economies are highly dependent on fos-
sil energy, and strict implementation of emission reduction policies will inevitably
affect their economic growth and national competitiveness. Thus, similar inter-
ests have brought these countries together in international negotiations on climate
governance. In previous climate negotiations, the Umbrella Group members have
been reluctant to make serious emission reduction commitments. Instead, they have
tended to rely on approaches such as the Clean Development Mechanism (CDM)
without making any substantive changes (Gao, 2010), which also reflects the rela-
tively passive stance of these members toward low carbon governance.
The BASIC is a group of four fast-growing developing countries: Brazil, South
Africa, India, and China, all of which face the difficult challenge of balancing devel-
oping-country roots with an “emerging powers” image. On the one hand, unlike
developed countries that have already entered the postindustrial era, these four
countries need to solve domestic development problems and face multiple dilem-
mas, such as poverty eradication, livelihood improvement, and economic develop-
ment (Hallding et al., 2013); nevertheless, unlike other developing countries, the
BASIC countries, which are in the rapid growth stage, already account for more than
1/3 of the total global GHG emissions and have become a vital force in promoting
global low carbon governance actions. The rise of comprehensive national power
also gives these countries greater ambition to improve their international stand-
ing, and climate governance is seen as a vital approach. These common conditions
have led the BASIC countries to align on key power distribution issues in the global
public sphere. While all four countries note that developed countries should take
more responsibility for climate governance due to their high historical emissions,
the BASIC countries have also undertaken significant and ambitious reforms of their
domestic climate policies (Hallding et al., 2011).
Through arduous negotiations, a consistent goal has been reached worldwide to
“limit the rise of average global temperatures to no more than 2 °C above preindus-
trial levels” after the Paris Agreement in 2015. To date, 194 countries have submit-
ted nationally determined contributions (NDCs) with domestic mitigation plans and

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National stances and governance systems: a comparative study… 221

targets. Nevertheless, it is controversial whether these countries have sufficient moti-

vation and capacity to achieve these targets (den Elzen et al., 2019; Roelfsema et al.,
2020). This paper selects Germany, the United States, and China as typical cases of
the EU, the Umbrella Group, and the BASIC countries. These three countries are also
the largest carbon emitters in these climate groups, which makes the analysis and com-
parison of their low carbon governance systems highly valuable for achieving climate
goals. By comparing the national stances, as well as the internal low carbon govern-
ance systems of these countries, this paper tries to determine how the diverse combi-
nations of external and internal features could affect the concrete action and outcome
of national climate governance and make some contributions to the pursuit of better
global climate governance.

2 Theoretical framework and hypothesis

The formulation and implementation of policies are not the consequence of one or a
few isolated factors, nor is innovation on blank paper, but rather the continuous joint
effects of all relevant factors (Bressers & Klok, 1988). The interaction can be seen as an
evolution resulting from the game between external and internal factors (Aoki, 2001).
For example, economic development stage, political system, and administrative and
institutional mechanisms should all be considered in policy design and analysis (Tan,
2021). Therefore, this paper tries to summarize the low carbon governance systems of
countries from two aspects, the national stance and the domestic governance structure,
and discusses how their evolution ultimately influences the outcome of low carbon gov-
ernance through comparative analysis.
The literature review on the EU, the Umbrella countries, and the BASIC countries
indicates that countries’ climate stances can be influenced by a combination of fac-
tors, including national economic characteristics, social values, diplomatic politics, and
physical vulnerability. Moreover, the national stances at the diplomatic level can be
internalized to shape the national climate governance target, which can also influence
and be influenced by the domestic climate governance system.
This paper further hypothesizes that the domestic climate governance system can
be distinguished into two parts: the vertical structure of climate governance and the
interaction of the government, market, and society. Comprising the central low carbon
governance structure and the distribution of power and interests between the central
and local departments, the vertical governmental structure influences the choice of
policy instruments in low carbon governance and determines the interaction relation-
ship between the government, the market, and social actors. Under the combined influ-
ence of climate stances and governance systems, countries take relatively aggressive or
negative, effective or ineffective climate actions and impact the eventual fate of global
climate governance (Fig. 1).

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222 R. Tan, Y. Zhu

Domestic Climate
Governance System
Stances Climate
Targets
on Vertical Interaction of
Carbon Structure of Government,
Reduction Climate Market and
Governance Society

Actions of Low Carbon Governance

Fig. 1  Theoretical framework

3 The low carbon governance system in Germany

Germany is the forerunner in European and international climate governance and

an essential leader in climate mitigation (Joergensen et al., 2015). Beginning with
the Kyoto Protocol, low carbon governance in Germany has been carried out for
more than 20 years. Germany constructed a climate governance system with Ger-
man characteristics during this period by merging energy policy with climate policy.
Moreover, Germany has achieved impressive greenhouse gas emission reduction
through its institutional and technological strengths.

3.1 Climate targets of Germany

The severe pollution problems incurred during industrialization and the shocks of
two petroleum crises in 1973 and 1979 gave Germany the desire to wean itself off
fossil fuels as soon as possible. Moreover, the Chernobyl disaster of 1986 led the
vast majority of German society to oppose nuclear power (Mez, 2012). Driven by
these events, Germany, as a country with multiparty governance, reached a cross-
party consensus on promoting GHG emissions reduction (Monstadt & Scheiner,
2014).
As a core member of the EU, climate targets in Germany are closely aligned with
policies and regulations at the EU level, in addition to nationally endogenous fac-
tors. At the EU level, the Effort-Sharing Regulation and the European Climate Law
were established, setting legally binding GHG emissions targets for each Member
State annually as well as the target of net zero greenhouse gas emissions by 2050.
Driven by both internal and external motivations, Germany has set ambitious cli-
mate governance targets. In 2021, the German federal government passed a resolu-
tion to adjust the Climate Protection Act, setting an economy-wide emissions reduc-
tion target of at least 65% by 2030 and at least 88% by 2040 compared to 1990
levels. The country aims to reach climate neutrality by 2045 (5 years earlier than the
EU target) and achieve negative greenhouse gas emissions after 2050.

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National stances and governance systems: a comparative study… 223

3.2 Vertical structure of climate governance in Germany

As a federal country with a parliamentary republican system of government, Germa-

ny’s administrative system is divided into the three levels of federal, state, and local,
and this paper mainly focuses on the vertical interaction of the federal and state lev-
els (Fig. 2). The executive core of the federal government, generally known as the
Cabinet, is mainly comprised of the Federal Chancellor and the Federal Minister.
In the hierarchy of the Cabinet, the Federal Chancellor is responsible for nominat-
ing Federal Ministers and setting policy guidelines and norms for each department,
within which the Federal Ministers can independently lead their respective depart-
ments. State governments have considerable autonomy thanks to the distribution of
power between the federal and state governments. Under the federal system, Ger-
many has 16 independent federal states, all of which have constitutions, sovereignty,
and partial financial power.
In response to the public’s growing concern about the environment, climate, and
nuclear safety, the Federal Ministry for the Environment, Nature Conservation,
Building, and Nuclear Safety was established in 1986 to integrate the environmental
authorities of the Federal Government under a single ministry. In 1990, the Ger-
man federal government formed an interministerial working group on carbon diox-
ide reduction to promote cooperation between the governing parties and the parlia-
ment members of opposition parties (Mez, 2012). In 2019, the Climate Cabinet was
established under German Chancellor Angela Merkel’s direct leadership to improve
climate legislation and contribute to reaching the climate target. Members of the
Climate Cabinet are to meet regularly and discuss the development of policies and
regulations. By creating a communication mechanism between the federal govern-
ment and the ministers of critical sectors, the Climate Cabinet tries to help achieve
expedited consensus on climate targets and actions.

Federal Level State Level

Bicameral Parliament
Federal Council State Diet
Federal Diet (Bundestag)
(Bundesrat)
Minister-President (Landtag)

Environment Environment
Department Department of State
Chancellor
Targets Energy Department
Energy Department
of State
Climate Cabinet ĂĂ ĂĂ
Transport Transport
Department Department of State

Enfranchised People (18 years or older)

Implement on Elect or appoint

agreement

Fig. 2  Overview of the vertical structure of climate governance in Germany

13
224 R. Tan, Y. Zhu

In practice, the federal government allocated emission reduction tasks by sec-

tors, such as building, energy, industry, transportation, and agriculture, by issuing
climate plans, which also specified rigid annual targets and legal mechanisms for
target adjustment and regular evaluation (Ding & Zhang, 2022). By holding Min-
isterial Conferences, where federal ministers can discuss climate policies with state
ministers, the climate targets of every federal sector are transmitted top–down to the
state sectors. Ministers unable to meet their sectoral targets may face penalties in the
form of budget reduction and are required to submit contingency plans to optimize
emission reduction measures within 3 months.

3.3 The interaction between government, market, and society in the low carbon
governance of Germany

3.3.1 The role of the government

Proportional representation and a relatively generous public funding system for

political parties are the fundamental features of the electoral system in Germany.
Political parties can win representation in parliament and public funding once they
receive 5% or more of the total votes, making it impossible for any single party to
gain enough seats in the parliament to form a government by itself (Mez, 2012).
Therefore, the German government at all levels prefers negotiation and cooperation
to command and develop a policy style of consensus politics in climate change. The
government plays the role of facilitator in climate governance, using market inter-
ventions, such as ecological taxes and feed-in tariffs (FIT), to support renewable
energy and incentivize the participation of all sectors in low carbon governance.
Ecological tax reform was formally introduced to Germany with the decree on the
Introduction of the Ecological Tax Reform in 1999 (BMF, 1999). Right afterward, in
2000, Germany enacted its first Renewable Energy Act, establishing the Fixed Feed-
in Tariff policy, meaning that grid operators have to acquire electricity produced by
renewable energy sources preferentially at a higher specified price (Butler & Neu-
hoff, 2008; Cansino et al., 2010). Moreover, state governments have developed a
competitive mechanism regarding some common interests related to the renewable
energy industry, such as private investment, trade taxation, return distribution, and
regional added value (Ohlhorst, 2015). The competitive interstate mechanism has
provided sustainable motivation for the growth of renewable energy in Germany,
resulting in the rapid expansion of wind power and photovoltaic industries.

3.3.2 The role of the market

Market mechanisms are a practical approach for the EU and its member countries to
achieve their climate commitments. The EU officially launched the European Union
Emissions Trading System (EU-ETS) in 2005, the world’s first carbon trading mar-
ket. As one of the first members to join the EU-ETS, Germany published its Climate
Action Programme 2030 in 2019, proposing to put a price on carbon emissions for

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National stances and governance systems: a comparative study… 225

sectors with high emissions but not included in the EU-ETS, such as the transport
and building sectors. As a complement rather than a replacement for the EU-ETS,
the carbon trading system in Germany aims to expand the scope of carbon pricing to
facilitate broader domestic action.

3.3.3 The role of society

Environmental issues have always been a crucial public issue in Germany due to the
pollution and health damage caused by industrial development in the early stage and
other historical and physical factors. German statistics show that during the 1970s
alone, there were no fewer than 2000 public environmental campaigns in Germany
(Guggenberger, 1980). In the 1980s, the Chernobyl disaster and the general eleva-
tion in the awareness of global warming led to numerous voices for climate protec-
tion and nuclear elimination, which were the main drivers for the initial expansion
of renewable energy production in Germany (Ohlhorst, 2015).
Due to the overwhelming public concern for climate issues, policies that are envi-
ronmentally friendly and climate supportive have long been able to quickly receive
the support of the German public. Hence, all major parties actively legislate laws
and regulations on environmental and climate issues to win a good impression
among constituents (Chen et al., 2019; Wassermann et al., 2015).
In addition, environmental nongovernmental organizations (ENGOs) play an
essential role in low carbon governance. Unlike many other countries, ENGOs
in Germany quickly integrated into the government due to its proportional repre-
sentation electoral system. The first representative of the green party, the Bremer
Green List, entered the parliament of the city-state of Bremen in 1979. The party
later entered more state parliaments, and in 1983, it reached the national parliament
(Mez, 2012). Integrating ENGOs and their supporters into government institutions
and policy agendas is one of the primary reasons for the emergence of the coopera-
tive character in German climate policy (Weidner & Mez, 2008).

3.4 The low carbon governance actions in Germany

Climate Action Tracker (CAT) is an independent scientific analysis produced by two

research organizations, Climate Analytics and the New Climate Institution, which
tracks climate actions for a total of 32 countries that cover approximately 80% of
global carbon emissions. This paper refers to the CAT to assess whether countries
are making sufficient efforts in global low carbon governance for the common target
of the Paris Agreement.
According to the most recent CAT assessment of Germany in November 2022,1
current low carbon governance policies and actions in Germany will lead to a
49–51% reduction in carbon emissions by 2030 compared to the emission level in
1990, which fails to meet the 65% standard set by the German government. How-
ever, the new government in Germany is providing a growing number of detailed

1
https://​clima​teact​iontr​acker.​org/​count​ries/​germa​ny/.

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226 R. Tan, Y. Zhu

climate governance plans in different sectors, including policies to upgrade renew-

able energy technology, and increasing the proportion of electric vehicles and pub-
lic traffic in the transportation sector. If these plans can be effectively promoted,
according to CAT’s estimates, Germany’s emissions in 2030 will be 57–63% lower
than the emission level in 1990, which is close to the 2030 target. As a result, CAT
rated Germany “almost sufficient".

4 Low carbon governance system in the United States

As a major producer of carbon emissions historically and currently, the United States
is responsible for 25% of the total carbon emitted into the atmosphere by human-
ity (Mildenberger, 2021). Without the active participation of the US, global climate
governance will be extremely challenging or even exist only in name. However, the
US has not made a consistent commitment to climate governance. The US is consid-
ered a volatile actor in global climate governance. When the team in power changes,
the US shows noncontinuous fluctuations in its participation in climate governance,
which makes it difficult for the United States to undertake sustained and systemic
reform of the domestic climate system (Mildenberger, 2021).

4.1 Climate targets of the United States

The target of low carbon governance in the US exhibits a characteristic of apparent

discontinuity, as requirements could suddenly move forward or backward with the
change in the party in power. Since the signing of the United Nations Convention
on Climate Change (UNCCC), the US has gone through the Clinton and Obama
periods of active promotion and the Bush and Trump periods of passive resistance.
During the presidency of Joseph Robinette Biden, the US turned aggressive on
low carbon governance and set higher emission reduction targets. In 2021, Biden
signed the Executive Order on Tackling the Climate Crisis at Home and Abroad,
which indicates the aim for the United States to achieve carbon neutrality by 2050
and carbon-free and net zero emissions in the electricity sector by 2035. In the same
year, the US government pledged at the World Leaders Climate Summit to reduce
US greenhouse gas emissions from 50 to 52% by 2030 compared to the 2005 emis-
sion level.

4.2 Vertical structure of climate governance in the United States

The national governance system of the United States follows the system of three
powers; i.e., legislative, executive, and judicial powers are exercised by three dif-
ferent state agencies. Legislative power is vested in the Congress, composed of the
Senate and the House of Representatives; executive power is vested in the federal
government under the president; and judicial power is vested in the Federal Supreme
Court.

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National stances and governance systems: a comparative study… 227

Federal Level State Level

DoE/ EPA
DoE/ EPA
Legislation Regulation Regional Offices State Laws/
Financial Incentives Regulations
State
Congress President Executive Orders State Governors Legislature

Enfranchised People (18 years or older)

Enforce/ Stimulate Elect Affect (Inspire)

Fig. 3  Overview of the vertical structure of climate governance in the United States

At the federal level, the president leads the executive branch, which is respon-
sible for implementing the law and providing various administrative services.
There are two channels for the implementation of low carbon governance poli-
cies. First, under the authorization and supervision of the US Congress, low car-
bon governance acts are implemented through agencies. As independent admin-
istrative departments, the Environmental Protection Agency (EPA) and the
Department of Energy (DoE) take on the main tasks, and the president directly
appoints their ministers. The EPA is the primary low carbon governance admin-
istration in the US, with ten regional offices responsible for implementing state
GHG emission reduction efforts. In addition, the DoE is responsible for formu-
lating energy-related policies (Gong et al., 2020). Second, the executive order
is the other route for the president of the United States to manage the branch of
government and release climate policies (Ding & Zhang, 2022). This approach
does not need the approval of the US Congress. However, there are potential
risks that an executive order may be overturned after a change in office (Lu
et al., 2021) (Fig. 3).
Under the influence of powerful interest groups, the US federal government
has made slow progress in climate change legislation, which makes top–down
climate governance in the US lacking in binding force. With the relative absence
of federal leadership, some states considering themselves leaders on the climate
issue have actively covered the position (Basseches et al., 2022). Several inter-
state low carbon governance partnerships have been formed in the US, for exam-
ple, the Regional Greenhouse Gas Initiative and the Pledge: We Are Still In, a
commitment signed by half of the states after Trump’s withdrawal from the Paris
Agreement. However, due to the increasingly polarized political situation in the
US, there is also great diversity in climate governance across states. Democrat-
controlled states tend to be proactive in adopting climate policies in the two-
party system. In contrast, in some Republican-led states, there have been many
anti-climate policies, including resistance to the federal government’s Clean
Power Plan, further subsidies to the fossil fuel industry, and reduced incentives
for renewable energy (Basseches et al., 2022).

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228 R. Tan, Y. Zhu

4.3 The interaction between government, market, and society in the low carbon
governance of the United States

4.3.1 The role of government

With the political polarization in Congress in recent years, laws related to low
carbon governance are complicated to pass in Congress, which forces the fed-
eral government to manage in an almost legal vacuum, playing a limited role in
low carbon governance (Fiorino & Weted, 2020). Moreover, due to the decen-
tralization of power and responsibilities, state and local governments play a more
significant driving role in low carbon governance (Gilmore & St. Clair, 2018).
Because of the lack of federal financial support, however, states have suffered
from a shortage of funds for climate change mitigation. In most states, low carbon
governance expenditures are less than 1% of total budget expenditures (Gilmore
& St. Clair, 2018). Consequently, state governments have turned their attention to
market-based policy systems that are efficient in low carbon governance and can
bring enormous economic benefits.

4.3.2 The role of the market

In the absence of effective central support, state governments, especially those

confronted with higher social requests for climate protection, tend to establish
market systems. The market-based regulation of low carbon governance in the
United States began with a “carbon pricing” approach, mainly achieved through
the issuance of cap-and-trade programs. In April 2003, after the Bush Adminis-
tration refused to sign the Kyoto Protocol, the Governor of New York invited 11
governors of states in the Northeast US to sign an agreement on trading carbon
allowances in the electricity sector. In July 2003, nine northeastern US states’
energy and environmental departments agreed to establish the Regional Green-
house Gas Initiative (RGGI), declaring a cap-and-trade program for 70 power
plants generating more than 25 megawatts of electricity. These cross-state cap-
and-trade cooperations marked the formal beginning of the bottom-up carbon
trading system in the US and ended the prolonged absence of a carbon trading
system (Wang & Jiao, 2021).
Some state governments use market-based bundled approaches, such as the
Renewable Portfolio Standard (RPS) and the Clean Energy Standards (CES), to
ensure a diverse and reliable low-carbon energy supply. The RPS is a policy that
requires electric utilities to generate a certain percentage of electricity from renew-
able sources. In addition to the minimum percentage mandated, electric utilities
can receive tradable renewable energy credits (RECs) for every MWh of electricity,
which significantly reduces the total cost of meeting the share standard (Cleary &
Palmer, 2019). The CES is conceptually similar to the RPS, requiring utilities to use
a certain amount of “clean energy” for electricity generation. The difference lies in
the definition and scope of “renewable” and “clean” energy. For example, nuclear
energy is clean but not renewable (NCSL, 2021).

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National stances and governance systems: a comparative study… 229

4.3.3 The role of society

Over the last decades, nongovernmental climate governance activities in the United
States have increased sharply. Many ENGOs are actively involved in climate change
mitigation. In addition to providing technical assistance, these ENGOs lead the leg-
islative process and influence the national agenda to some extent. For example, the
Environmental Defense Fund (EFD) helped the state of California develop legisla-
tion on GHG economy-wide caps, which has been instrumental in promoting the use
of clean energy and reducing carbon emissions. In addition, some active ENGOs,
such as Earth Justice and 350.Org, use public protests and the media to pressure
politicians on specific climate policies and initiate lawsuits to enforce national low
carbon policies (Gong et al., 2020).
The general public tends to exhibit characteristics of high support for action but
little concern for climate change in general (Harrison, 2010). Nevertheless, in some
states with a high level of physical vulnerability, the public is more concerned about
climate issues, and the common concern in the population can push state govern-
ments to adopt climate policy (Basseches et al., 2022).

4.4 Low carbon governance actions in the United States

According to CAT’s most recent assessment of the US in August 2022,2 the current
low carbon policies and actions of the US will allow its carbon emissions to reach
4.7 to 5.6 Gt C ­ O2 by 2030, which is approximately 12–35% higher than the NDC.
However, after taking office, Biden signed a series of acts related to low carbon gov-
ernance and implemented many clean energy projects (including solar panels, wind
turbines, batteries, and electric vehicles), arguably the most ambitious and poten-
tially influential climate policies in US history. However, due to the high degree of
uncertainty, CAT’s assessment remains “insufficient".

5 The low carbon governance system in China

As the largest annual emitter in the world currently, China is also a developing coun-
try on the rise and faces problems such as the poor quality of people’s lives and
unbalanced development across regions (Wang & Tan, 2018). Therefore, developing
the economy and improving people’s lives are also core issues China must face. All
of these, however, did not stop China from gradually adopting a proactive approach
to climate issues (Li & Wang, 2012). In recent years, China’s rapid success in limit-
ing carbon emissions has surprised many observers (Engels, 2018). As a key partici-
pant in international climate cooperation, China has built a low carbon governance
system with characteristics based on the national institutional logic (Teng & Wang,
2021).

2
https://​clima​teact​iontr​acker.​org/​count​ries/​usa/.

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230 R. Tan, Y. Zhu

5.1 Climate targets of China

Since the reform and opening-up, the economy of China has been growing at high
speed. While hundreds of millions of people were lifted out of poverty, issues of
environmental degradation, air pollution, and climate change were slowly revealed,
which put the government of China under enormous reputational pressure domesti-
cally and internationally. However, during this period, low carbon governance was
contradictory to the goal of achieving national economic prosperity within the con-
text of extensive growth (Tan et al., 2021). The importance of the environment gave
way to the urgent need for economic development (Hilton & Kerr, 2017). Thus, the
mitigation targets in China were considered too conservative at the time.
The new twist came in 2011 when China released the 12th Five-Year Plan. This
plan emphasized using various means, such as adjusting industrial and energy struc-
tures and improving energy efficiency, to reduce energy consumption and carbon
dioxide emission intensity. Since then, systemic changes in industrial development
have allowed China to gain rising competitiveness in the new energy industry. By
the time of the Paris climate summit in 2015, the fruits of the economic transforma-
tion had begun to emerge (Hilton & Kerr, 2017). In 2015, China submitted its first
NDC document to the UNFCCC Secretariat, setting an emissions reduction target of
peaking ­CO2 emissions by approximately 2030 and achieving a 60–65% reduction in
­CO2 emissions per unit of GDP compared to 2005 (NDC of China, 2015). The target
was further updated in 2021, with China proposing to reduce C ­ O2 emissions per unit
of GDP by more than 65% in 2030 compared to 2005. At the 75th session of the
General Assembly of the United Nations, Chinese President Xi Jinping announced
the goal of peaking ­CO2 emissions by 2030 and achieving carbon neutrality by 2060.

5.2 Vertical structure of climate governance in China

Centralization is a crucial feature of the Chinese governance structure. This is

mainly reflected in the command-based management system from the central gov-
ernment to the subordinate governments, which means that offices in the lower eche-
lon need to accomplish the tasks given by their superiors effectively to get promoted
(Wang, 2014).
At the central level, a National Leading Group for Climate Change, Energy Con-
servation, and Emission Reductions was established in 2007, mainly responsible for
the formulation of strategies and guidelines in low carbon governance, with mem-
bers consisting of ministers from various related departments. The specific work
is undertaken by the Development and Reform Commission and the Ministry of
Ecology and Environment following their duty and functions. Prior to 2018, energy
conservation and GHG emissions were primarily the responsibility of the Develop-
ment and Reform Commission, while the Ministry of Environment Protection was
primarily responsible for the reduction in pollutant emissions. GHGs and air pol-
lutants are usually associated with the use of fossil energy, and the split control sys-
tem of pollutants and GHGs was not conducive to integrated planning (Tian et al.,
2013). Following the abolition of the Ministry of Environmental Protection and the

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National stances and governance systems: a comparative study… 231

CCP State Council of the Republic of China

National
Level

Provincial
Level Department of Provincial Development
Environment and and Reform
Ecology Commission

Municipal Government

Assessment and Profession vertical

Evaluation leadership

Fig. 4  Overview of the vertical structure of climate governance in China

establishment of the Ministry of Ecology and Environment of the People’s Republic

of China in 2018, the duties of the Development and Reform Commission on cli-
mate change and emission reduction were incorporated into the Ministry of Ecology
and Environment, so that carbon emissions, which are not pollutants, are included
in the scope of supervision of the Ministry of Ecology and Environment. The Devel-
opment and Reform Commission retains the Department of Resource Conservation
and Environmental Protection to undertake the specific duties of energy conserva-
tion. After the carbon peaking and carbon neutrality goals were officially proposed
in 2020, the National Leading Group for Carbon Peaking and Carbon Neutral was
formally unveiled in 2021 to systematically coordinate and guide relevant work (The
State Council Information Office of the People’s Republic of China, 2021).
From the national to the provincial level, the implementation of low carbon gov-
ernance tasks is mainly achieved by establishing a target-oriented responsibility sys-
tem and an evaluation system of energy saving and emission reduction. Based on the
development stage of each province, the central government categorically allocates
emission reduction targets from the top–down. Negotiations of the allocation are
similar to international climate negotiations, following the principle of common but
differentiated responsibilities (CBDR). Afterward, each province formulates plans,
programs, or opinions on greenhouse gas emission targets according to its respective
emission targets (Ministry of Ecology and Environment of the People’s Republic

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232 R. Tan, Y. Zhu

of China, 2021) and decomposes the responsibility of emission reduction to cit-

ies, counties, and key energy-consuming enterprises (Schreurs, 2017). For exam-
ple, under the carbon peaking and carbon neutrality goals, the governments of each
province, autonomous region, and municipality are required to scientifically formu-
late action plans in accordance with national deployment, which are reviewed by
the National Leading Group for Carbon Peaking and Carbon Neutrality (Chinese
State Council, 2021). In addition, the State Council arranges annual assessments of
the provincial government’s performance in GHG emission reduction, the result of
which is an essential part of the leading group’s assessment as well as a vital indica-
tor for officials’ appointment and promotion (Fig. 4).

5.3 The interaction between the government, market, and society in the low
carbon governance of China

5.3.1 The role of government

The government is undoubtedly in the core position of low carbon governance in

China, especially the central government, which has absolute discretionary author-
ity to direct and regulate the low carbon governance issues of provinces, coun-
ties, and state-owned enterprises (Wang et al., 2018). Those administrative meas-
ures are effective but have high institutional costs (Tan et al., 2012; Xiong et al.,
2021; Zhang, 2015). For example, during the 11th Five-Year Plan, the primary
approach to achieve climate targets was to close inefficient industries and reduce
outdated production capacity. However, faced with the pressure of assessment, many
local officials adopted extreme and even illegal means, such as cutting off electricity
and shutting down power plants arbitrarily, resulting in severe social impacts (Zhang
et al., 2020). Therefore, there is an urgent need to expand other governance paths.
The first is market intervention, which is also called the invisible hand, and includes
the FIT policy (Liang et al., 2018) and protective subsidies for renewable energy
(Wang et al., 2018). The second new path is the design of policy instruments, so
that the government can promote the participation of nongovernment actors in low-
carbon transition, providing more diverse and multilevel solutions for climate gov-
ernance in China (Wang et al., 2018).

5.3.2 The role of the market

The market mechanism has a crucial driving effect on the low-carbon transition of
China. By stimulating the market mechanism, enterprises can eliminate the dilemma
of path dependence and are motivated to put clear and compelling energy into
research and development (Zhang et al., 2020). Moreover, the establishment of car-
bon markets has shifted some of the responsibility for low carbon governance from
local governments to verification companies and emitters, so that the role of local
government can be more focused (Zhang et al., 2020; Xiong et al., 2018).
In 2011, the 12th Five-Year Plan proposed gradually establishing a carbon emis-
sion market and chose the Emissions Trading System as the starting point of the

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National stances and governance systems: a comparative study… 233

marketization of low carbon governance. By 2013, emissions trading systems were

formally launched in five pilot cities, Beijing, Shanghai, Tianjin, Chongqing, and
Shenzhen, and in two pilot provinces, Guangdong and Hubei (National Develop-
ment & Reform Commission, 2011). The central government delegated the author-
ity of making related regulations to the offices of provinces and municipalities to
accommodate the differences in resource endowments, energy consumption pat-
terns, and economic foundation (Ying & Sovacool, 2021). After 8 years of piloting,
China officially launched the national carbon emission trading market in 2021. By
October 21, 2022, the cumulative volume of carbon emission allowances traded in
the national carbon market had reached 196 million tons, and the cumulative turno-
ver had reached 8.58 billion yuan (Ministry of Ecology and Environment of the Peo-
ple’s Republic of China, 2022).

5.3.3 The role of society

According to statistics, 26% of energy consumption in China is directly used in pub-

lic life, resulting in more than 30% of carbon emissions (National Development &
Reform Commission, 2021). This shows that social participation is a crucial part of
China’s low carbon governance that cannot be ignored.
NGOs play an inescapable role as lobbyists, activists, educators, advocates, and
monitors for forming both climate-related policy and public values, having a com-
plementary relationship with the government (Liu et al., 2017). For example, the
China Business Council for Sustainable Development (CBCSD: China Business
Council for Sustainable Development), as an NGO, has formulated and published
many GHG emission accounting guidelines, some of which were even certified as a
national standard by the government (Liu et al., 2017).
While the value of climate protection is more likely to spread from the govern-
ment to citizens, the general public still influences low carbon governance in a con-
stant and silent manner, which is reflected in the CPC’s people-centered philosophy
of governance in particular. As a critical reason for the Chinese government to put
low carbon governance at the forefront, the people-centered philosophy reflects the
determination of the Chinese government to guarantee a high quality of life for both
current and future generations. Moreover, the participation of the general public
in low carbon governance is reflected in the supervisory right of the public (Tan,
2021). Although the institutional design of citizen participation is inadequate, with
the popularization of social media and the reform of the service-oriented govern-
ment, governments at all levels are beginning to pay more attention to the feedback
of public opinion.

5.4 Low carbon governance actions in China

According to the most recent CAT assessment of China in November 2022,3 China
is likely to surpass its NDC targets related to energy and carbon reduction under the

3
https://​clima​teact​iontr​acker.​org/​count​ries/​china/.

13
234 R. Tan, Y. Zhu

projections based on the current policy. Nevertheless, according to the simulation of

current policy, the low carbon governance in China still fails to meet the common
goal of keeping global warming well below preindustrial levels of 1.5–2 °C by the
end of the century but rather approaches global warming of more than 2 °C or even
as high as 3 °C. Therefore, the CAT assessment of China remains “insufficient".
However, it is worth noting that China is classified as a non-Annex I country in
the UNFCCC and Kyoto Protocol, which means that it is not expected to take a bind-
ing responsibility. Thus, CAT also notes that to move forward with more ambitious
low carbon governance targets as a developing country, China needs more interna-
tional support in finance or technology and should not fight the battle alone.

6 Comparison among the three countries

6.1 Comparison of the stances on climate governance

National stances on climate governance are coinfluenced by political, economic,

social, and natural characteristics. Due to differences in natural vulnerability, energy
industry development, international reputation, and social value orientation, Ger-
many, the United States, and China are in different groups in international climate
negotiations, representing their different attitudes in global climate governance.
Despite the increasing doubt about whether the EU can continue to lead in global
climate cooperation (Bäckstrand & Elgström, 2013), the EU has been leading and
playing a vital catalytic role in global climate negotiations. As a member country
of the EU, on the one hand, Germany is affected by international reputation pres-
sure to maintain its leading position in global climate governance (Vogelphl et al.,
2017), as well as domestic pressure from the public’s consensus on climate protec-
tion. Moreover, as the forerunner in the renewable energy sector, the substantial
first-runner advantage makes it a real bargain for Germany to promote global cli-
mate governance.
In contrast, the Umbrella Group, composed of developed countries, including the
US as the leading country in particular, is far more passive in climate governance.
With a highly vested interest in fossil energy and traditional industries, these coun-
tries prefer to take less responsibility in international climate cooperation. Moreover,
as the name “Umbrella Group” metaphorically implies, these countries would like to
protect their economic development and national competitiveness from global cli-
mate governance initiatives (Gnaś, 2015).
In addition to the developed countries mentioned above, the BASIC group of four
developing countries plays an increasingly important role in international climate
governance due to its rapidly emerging economy and huge development potential
(Hallding et al., 2011). As the world’s largest developing country, China has taken
a leading role in energy transformation. As a result, promoting global climate gov-
ernance benefits its future development and the whole economy. Moreover, its fast-
growing economy has given China a grander ambition for international status in cli-
mate governance (Qi, 2011), increasing its reputation pressure. Another important
reason is that the people-centered ideology of the Communist Party of China has

13
National stances and governance systems: a comparative study… 235

made advancing sustainable development one of its governing priorities under its
long-term strategy.

6.2 Comparison of the vertical structure

The vertical governance structures of low carbon governance in Germany, the

United States, and China are significantly different. This section will analyze the
vertical structures comparatively from two perspectives: the institutional stability
of the central government and the interaction between the central government and
localities.
The differences in the stability of low carbon governance policies are mainly
influenced by domestic institutional characteristics as well as the climate govern-
ance structure at the central level.
Although the climate commitment of the Chinese government has gone through
a shift from conservative to ambitious with the transition of the economic growth
mode and the reconfiguration of industry, under the leadership of the CPC, China’s
climate policies are stable and continuous. Germany, as the forerunner in low carbon
governance, also has a steady climate policy system regardless of the turnover of
the ruling party. With the institutional characteristic of the coalition government,
Germany has a strong policy coherence on climate change (Weidner & Mez, 2008).
However, the climate policy system in the US has been criticized for lack of con-
sistency. As a two-party country, the US is highly polarized on environmental and
many other issues (Fiorino & Weted, 2020). A report by the Pew Research Center
in 2014 indicated that the division of ideology between Republicans and Democrats
is currently more profound and broader than at any time in the past two decades
(Pew Research Center, 2014). When one party steps down, the other party will over-
turn all the accumulations of previous climate policies, leaving the US stalled in the
development of the climate regime (Dunlap et al., 2016). Furthermore, the polariza-
tion of parties makes it difficult to pass climate proposals in Congress. Thus, there
is a lack of national legislation, related institutions, and procedures on climate gov-
ernance in the US, leaving the party in power with enormous authority in adjusting
climate policies through executive orders by the president (Mildenberger, 2021).
The interaction between the central and local governments greatly influences the
top–down implementation efficiency of low carbon policies. As a centralized coun-
try, the central government of China has significant power to assign governance tasks
downward, mainly through command-based approaches, with energy conservation and
emission reduction included as mandatory targets (Zhan et al., 2022). However, this
approach has high institutional costs. Some local officials may collude and cheat in the
verification of targets (Zhang et al., 2020); this possibility has led to the introduction
of market mechanisms as a new policy instrument. Comparatively, Germany and the
United States, as federal states, tend to adopt approaches such as budget incentive or the
carbon emission market to promote local climate performance. Germany has developed
a consensus on climate governance at all levels of government, so there is little resist-
ance to policy implementation. In the US, however, some relatively traditional states
are opposed to low carbon policies, and the intense polarization of political parties

13
236 R. Tan, Y. Zhu

regarding climate change complicates the implementation of top–down climate policy.

Therefore, climate governance in the US is more likely to be driven by state-sponsored
or interstate cooperation.

6.3 Comparison of the interaction of the government, the market, and society

The choices of governance instruments for climate are related to the heterogeneity of
the governance system, which is reflected in interaction relationships between the gov-
ernment, market, and society across countries.
Because of the substantial institutional costs of binding administrative policies, all
three countries choose to incorporate market mechanisms into low carbon governance.
Nonetheless, the differences in government systems result in different market character-
istics of each country (Liu et al., 2023). EU membership gives Germany great advan-
tages, as it joined the European Emissions Trading System (EU-ETS) early and can
be considered a pioneer in exploring the carbon emissions trading system. Undoubt-
edly, the market system has played an essential driving role in low carbon governance
in Germany. As a cautious beginner, China established the national carbon emission
market in 2021 after 8 years of piloting. Although it has been established for a short
time, the carbon trading market has also gradually become one of the core policy tools
for China to achieve its low carbon governance target. Unlike China or Germany, the
absence of central administrative guidelines leave the US without a national-level car-
bon emission market system. Driven by some state governments concerned about cli-
mate, a few state-based markets have been established spontaneously, which play an
essential role in US climate governance.
In terms of the interaction between society and government, public opinion has the
most significant influence in Germany, which is due to the German political system.
The coalition government system and the integration of green parties into departments
give the shared value of climate protection in society immense influence on govern-
ment policy-making. The US is also built on the electoral system. However, high politi-
cal contributions make the federal government strongly influenced by the will of inter-
est groups, such that it shows proportionally less concern about the public’s opinion.
In China, the influence of citizens on the government is mainly reflected in the self-
imposed demands for achieving sustainable development goals (SDGs) at the national
level. Given China’s institutional structure and stage of development, the value of
climate protection is more likely to be disseminated from the government to the pub-
lic, such as the eco-friendly slogan “Green mountains are golden mountains” used to
reduce resistance to implementing low carbon policies.

6.4 Comparison of action and performance

According to Climate Action Tracker (CAT), Germany’s climate governance action

was assessed as “almost sufficient," while the US and China were assessed as “insuf-
ficient." Germany has made significant progress in reducing GHG emissions. How-
ever, it is also leading the way in terms of comprehensive progress in climate gov-
ernance, such as institutional design, knowledge and awareness, and technology

13
National stances and governance systems: a comparative study… 237

research related to climate. Furthermore, the worldwide dissemination of innovative

German policy instruments, such as the FIT policy, demonstrates Germany’s rec-
ognition of its frontrunner position in climate change governance (Weidner & Mez,
2008). In the case of the United States, a country that once withdrew from the Kyoto
Protocol and the Paris Agreement, the future uncertainty of climate policy has led
to a crisis of confidence, especially given the strong ties between climate stances
and party ideology. The evaluation of China’s climate governance behavior should
consider two aspects.
On the one hand, China is generally considered capable of accomplishing its low
carbon governance goals on time or even ahead of schedule. On the other hand,
China is a developing country and the world’s largest carbon emitter. The emis-
sion reduction targets at this stage can be compatible with the developmental phase.
However, for the present, the low carbon governance targets of China make it dif-
ficult to compete with the targets of developed economies that have already entered
the postindustrial stage (Table 1).

7 Conclusion

As climate warming poses unprecedented challenges to humans, climate govern-

ance has become one of the most critical global affairs. This paper compares the
climate stances and low carbon governance systems and assesses their mitigation
actions in Germany, the United States, and China. In addition, it digs deep into how
a national stances and domestic low carbon governance system influence its actions
and performance.
National stance is related to a combination of four domains: economic, political,
natural, and social. The main factor in the economic domain is "national competi-
tiveness", i.e., how climate governance will affect a country’s future national com-
petitiveness. For example, for countries with more competitive fossil energy indus-
tries, such as the United States, climate governance will significantly shock their
domestic traditional energy industries. Thus, they are less motivated to seek a low-
carbon transition. The main factor in the political domain is "international reputa-
tion", i.e., whether a country faces international reputational pressure. For example,
Germany always sees itself as the leader in climate governance, and China is the
world’s highest carbon emitter. As a result, these two countries are both under inter-
national reputational pressure. However, even though the climate governance of the
US has also received worldwide attention as the only superpower in the world, the
climate issue has a limited impact on its international status. Moreover, countries
that are more vulnerable to the negative impacts of global warming in the natural
domain and those that have formed a shared value for climate governance in the
social domain are more willing to take an active position.
The domestic governance system mainly contains two aspects: the vertical rela-
tionship between central and local governments and the relationship among the gov-
ernment, the market, and societal actors. Germany and the US are both federal states,
but their low carbon governance systems are very different. Germany has adopted
a consensus-oriented, multiparty governance system. Accordingly, the public has a

13
 238

13
Table 1  Comparison of the low carbon governance systems among the three countries
Items Germany The United States China

National stances (1) First-mover advantages in renewable (1) Vested interest in fossil energy (1) Leader in renewable energy production
energy (2) Under reputational pressure with limited (2) Under reputational pressure as the largest
(2) Under reputational pressure as the forerun- influence annual emitter
ner (3) Lack of value orientation in society (3) Top–down climate protection value guid-
(3) Strong value orientation in society (4) Relatively low physical vulnerability ance
(4) High physical vulnerability (4) High ecological vulnerability
Vertical structure (1) Well-established legal and institutional (1) Lack of legislation or stable institution in (1) Well-established legal and institutional
system in the federal government the federal government system in the central government
(2) Consensus reached on climate governance (2) High heterogeneity in climate governance (2) Top–down administrative constraints and
with significant autonomy of state govern- with significant autonomy of state govern- monitoring from central to local governments
ments ments
Interaction of govern- (1) EU-ETS and national market for carbon (1) Some state-based markets for carbon (1) Province-based pilots and national market
ment, market, and emission as a supplement emission for carbon emissions
society (2) Consensus on the value of climate govern- (2) Lack of concern about climate change in (2) Mainly reflect on the government-imposed
ance in society, which can significantly society requirement for sustainable development
influence government decisions
Action and performance Almost sufficient Insufficient Insufficient
R. Tan, Y. Zhu
National stances and governance systems: a comparative study… 239

more prominent voice in low carbon governance, and the federal government may
implement low carbon policies smoothly. The US is a two-party state with severe
partisan political rivalry. There is considerable heterogeneity in the acceptance of
climate policies among states due to different political parties. Therefore, low car-
bon policies must face significant resistance in their establishment and implementa-
tion. Compared to Germany and the US, China relies on top–down, binding policies
at the national level for low carbon governance. However, this approach faces high
institutional costs due to misrepresentation and collusion among local governments,
so China has introduced the market mechanism as a compliment.
Finally, the comparative analysis reveals that a combination of highly complex
factors influences domestic low carbon governance actions. To further promote
global low carbon governance, it is necessary to establish a shared value system
for climate protection. Moreover, given the high cost and complexity of national
top–down climate governance, in addition to providing more incentives in terms of
reputation and economics, international efforts should pay more attention to non-
state stakeholders. Multiple actors, such as local governments, enterprises, the pub-
lic, and scientific institutions, need to be included in global climate governance.

Funding This research was supported by The National Key R&D Program "Research on Sustainable
Transformation Models in Response to Global Changes", funded by the Ministry of Science and Technol-
ogy (No. 2020YFA0608600 Project).

Data availability This paper does not analyse data or undertake quantitative research and is unable to
provide data avaliability statement.

Declarations
Conflict of interest The authors claim that there is no conflict of interest in this article.

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