The Guidelines for the Implementation of Ecology-Oriented Development (EOD) Projects (Trial) (hereinafter referred to as the “Guidelines”), issued in December 2023, have clearly outlined the shift in the EOD model from a focus on “pollution control” to a fundamental logic centered on “realizing the value of ecological products.” In February 2025, the Notice on Further Promoting the Implementation of the EOD Model (hereinafter referred to as the “Notice”) further accelerated the establishment of a closed-loop market mechanism for ecological product value realization. This was achieved through adjustments to the management framework, refinement of project screening criteria, and the strengthening of policy tools such as factor guarantees.This paper analyzes the key requirements of the Notice and its potential impacts, focusing on policy shifts and the core challenges of ecological product value realization.
ⅠEOD Project 2024: Implementation Progress and Key Challenges
In 2024, the Guidelines were officially issued, providing clearer policy direction and standardization for EOD projects, significantly advancing the development of the EOD model. As shown in Figure 1, from a market scale perspective, a total of 106 EOD projects were launched in 2024, of which 72 became operational and 29 were tendered, with a total investment exceeding 181.5 billion yuan. The average investment per project was 2.24 billion yuan, and the total annual investment in EOD projects is expected to surpass 200 billion yuan.A comparison with data from the past two years reveals a rising trend in both the number of EOD projects and total investment, while the average investment per project is decreasing. This suggests a shift in project design from a broad-scale approach to a more refined and precise model.In terms of project types, the scope of industries associated with EOD projects further expanded in 2024. Beyond traditional ecological sectors such as eco-agriculture, tourism, and recreation, EOD projects increasingly incorporated environmentally sensitive industries, including the digital economy, biomedicine, and electronic components. From the perspective of local implementation, policy support for EOD projects continues to strengthen nationwide. For instance, Jiangsu Province, after introducing its provincial EOD work program and implementation guidelines, has further explored the integration of urban renewal with the EOD model. This includes developing a full-chain implementation system that extends from district-level planning to project execution. Similarly, Zhejiang Province has issued a series of policy documents—such as EOD project entry guidelines, project management regulations, and implementation evaluation rules—to provide more systematic and comprehensive guidance on critical aspects of EOD projects, including pre-investigation and logical analysis frameworks.
Figure 1: Number of EOD Projects and Investment Scale (2022–2024)
At the same time, despite the rapid development of EOD projects, several significant challenges have emerged.Firstly, the number of rejected or unsuccessful EOD projects has increased. According to incomplete statistics, since 2024, approximately 13 EOD projects have failed to pass approval or have been unsuccessful, involving a total investment of nearly 30 billion RMB.Secondly, EOD projects typically require substantial investment, have slow returns, and possess certain public welfare attributes. Although central enterprises, state-owned enterprises, and private enterprises all participate in the bidding process, projects are ultimately awarded primarily to entities with stronger financial capabilities. Central or state-owned enterprises account for 90% of all successful bids.
II. Changes and requirements of the Notice
As mentioned in the previous section, the Guidelines have established a fundamental shift in the EOD model’s logic from “pollution control” to the “realization of ecological product value.” The recently issued Notice places greater emphasis on the market mechanisms driving this realization process.Firstly, regarding project screening, the Notice introduces a clear requirement to align projects with the ecological objectives of the “15th Five-Year Plan,” emphasizing “small yet high-quality” individual projects. It also encourages financial institutions to engage early in the process to enhance project financing feasibility.Secondly, in terms of project implementation management, the Notice introduces a “project legal entity responsibility system,” which holds project entities fully accountable for risk management. It also promotes the institutionalization of self-assessment mechanisms, reinforcing the responsibilities of market participants and mitigating uncertainties in ecological product returns.Finally, regarding the development of market participants, the Notice explicitly states that all types of business entities will be treated equally, encouraging private enterprises to actively participate. Additionally, responsibility for project-related technical guidance will be delegated to provincial ecological and environmental departments, with the Ministry of Ecology and Environment ceasing its direct involvement in database technical guidance.
Table 1: Key Differences Between the Notice and the Guidelines
III. Outlook for Future Trends
The year 2025 marks the final year of the 14th Five-Year Plan and a crucial phase in building a "Beautiful China." Against the backdrop of improving mechanisms for realizing the value of ecological products and the continuous advancement of relevant policies, the future development of EOD projects is likely to follow these key trends:
1. Strengthening the Protection of Ecological Rights and Interests: From "Right to Use" to "Exclusive Rights and Interests"
The protection of ecological rights and interests will continue to evolve. While the Guidelines only stipulate that “land and sea rights should belong to the same entity” (Article 11), the Notice further mandates that “the project legal entity bears full responsibility for financial operations, project quality, and management.” This shift effectively transforms the public nature of ecological governance into marketable project value through a legal rights and responsibilities framework.In traditional pollution control projects, governance entities merely held rights to project revenue. Under the Notice, however, project operators can capture long-term value gains from ecological improvements—such as land appreciation and environmentally sensitive industry franchises—addressing the longstanding challenge of governance investments failing to capture external benefits.
2. Financial Institutions: From "Credit Support" to "Product Innovation"
Currently, EOD projects primarily rely on credit support. In the future, as the foundational work on natural resource rights and ecological product value accounting progresses, financial institutions will be able to develop more green financial products and services. For example, new models such as “ecological asset equity mortgages + project loans” could be explored, facilitating both ecological environment improvement and the development of eco-industries in targeted regions.
3. Expanding the Market Scale of Ecological Product Value Realization
With the renewed push to encourage private sector participation, EOD projects are expected to attract a broader range of market players. Beyond the Guidelines, which emphasize non-discriminatory treatment of all business ownership structures, specific regional initiatives are emerging. For example, Jiangsu Province has issued Guidelines for Private Capital Participation in Environmental Protection and Ecology-Oriented Development (EOD) Projects, explicitly supporting private investment through sole proprietorships or joint ventures. Similar policies are anticipated across other regions, providing clear pathways and safeguards for private enterprises to engage in EOD projects.
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