On December 1, the National Development and Reform Commission (NDRC) released the "Industry Scope List for Infrastructure Real Estate Investment Trusts (REITs) Projects (2025 Edition)" (hereinafter referred to as the "List"). The notice stated that to enhance the role of infrastructure REITs in revitalizing existing assets and promoting a virtuous investment cycle, the NDRC has further expanded the scope of eligible projects for REITs issuance.
The List specifies that in the energy infrastructure sector, eligible projects include clean energy initiatives such as wind power, solar power, hydroelectric power, natural gas power, biomass power, and nuclear power, as well as energy storage facilities, clean and flexible coal-fired power (including combined heat and power), ultra-high voltage transmission projects, incremental distribution networks, microgrids, and charging infrastructure.
For coal-fired power projects to qualify, they must meet one or more of the following conditions: minimum power output under pure condensation conditions at or below 30% of rated capacity; co-firing of biomass, hydrogen, ammonia, or other low-carbon fuels with a heat proportion of no less than 10%; or installation of large-scale carbon capture, utilization, and storage (CCUS) equipment.
Coal-ammonia co-firing power generation has already received multiple policy supports. In 2024, the NDRC's notice on promoting regular REITs issuance included coal-fired power projects co-firing low-carbon fuels (such as biomass, hydrogen, or ammonia) with a heat proportion of at least 10%. The "Coal Power Low-Carbon Transformation Action Plan (2024–2027)" also listed coal-ammonia co-firing projects (with at least 10% ammonia) as eligible for low-carbon transformation support, emphasizing the role of government investment in leveraging ultra-long-term special bonds and other funding channels.
Additionally, policies such as the "Measures to Strengthen Support for Large-Scale Equipment Renewal and Consumer Goods Replacement" and the "Action Plan to Boost Consumption" have expanded support to energy and power equipment upgrades, lowering application thresholds and streamlining approval processes.
REITs can serve as a stable funding mechanism for hydrogen-related projects, given their reliance on long-term power purchase agreements or service contracts that ensure steady cash flows. While China already has several clean energy REITs—such as AVIC Jinneng Photovoltaic REIT (including wind assets), Harvest China Power Construction Clean Energy REIT (Wuyiqiao Hydropower Station), and Penghua Shenzhen Energy REIT—projects in energy storage, coal co-firing, ultra-high voltage transmission, microgrids, charging infrastructure, and nuclear power remain in preparatory or application stages.
Coal-fired power projects face higher entry barriers as REITs underlying assets, requiring compliance with low-load operation, low-carbon co-firing, or CCUS installation. These conditions aim to facilitate the transition of traditional energy sources like coal toward cleaner alternatives while ensuring grid stability and flexibility.
Although China has launched multiple coal-hydrogen/ammonia co-firing pilot projects, none have yet been publicly listed as REITs. The inclusion of such projects in the NDRC's List, alongside ultra-long-term bonds, is expected to broaden funding channels for hydrogen-related initiatives, providing long-term capital to support innovation and industrial growth.
The full List covers 15 sectors, including transportation, energy, municipal facilities, eco-environmental projects, logistics parks, industrial parks, new infrastructure, rental housing, water conservancy, cultural tourism, consumer infrastructure, commercial offices, elderly care, urban renewal, and other strategic infrastructure projects. Specific conditions apply to each category, such as restrictions on mixed-use assets and developer qualifications.
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