Rational and constructive policy

  • The world’s climate policies are falling short.1 It’s time for a pragmatic approach using product-level carbon-intensity standards to incentivize production of low-carbon-intensity products.2
  • Product-level standards have been used to solve a multitude of tough challenges, and they can help create an efficient marketplace for products with low-emissions intensity.
  • Carbon-intensity standards can be tightened over time as technology improves, reducing the cost of lowering emissions, encouraging producers to invest, and ensuring demand is met.
  • To be effective, intensity standards must be underpinned by a well-designed carbon emissions accounting framework that reliably tracks CO2 emissions.
  • Rational and constructive policies that encourage the full range of technologies are key to lowering global emissions and meeting society’s needs for critical products and services. 

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Framing the challenge

The International Energy Agency reports that global energy use grew almost 50% since 2000.3 At the same time, GHG emissions have continued to rise4 despite significant government subsidies fueling the growth of renewable energy.5

  • Global CO2 emissions are up 7.5% over the past decade.6
  • Only 15 of 195 countries have updated their nationally determined contributions (NDCs) under the Paris Agreement.7
  • Only 3 of 50+ technologies needed to support net-zero emissions by 2050 are “on track.”8

Our Global Outlook forecasts energy use will increase another 15% by 2050. The growing needs of a rising population in the developing world drive this increase as economies develop and living standards improve. A better quality of life and lowering energy poverty rates drives higher energy consumption. This highlights the need for a new approach to help ensure CO2 is appropriately managed as prosperity grows.

Product-level carbon-intensity standards – a pragmatic approach

Today, countries around the world set thousands of standards for products.9 Products sold into these countries must meet these standards irrespective of where the product is made. 

There are many examples of product standards that have proven effective and allowed ample time for technology to improve and costs to come down. They include energy efficiency standards on appliances, food safety, and fuel economy.

These standards work by setting limits on certain product characteristics. They can be tightened over time, which incentivizes producers to meet increasingly stringent requirements.

Standards like the following have prompted markets to adopt new technologies and enabled capital to flow to the most cost-effective solutions, while still meeting demand.


“To achieve a lower-emissions future, government GHG policy should set carbon-intensity standards on products. We believe this is the best way to engage the collective efforts of industry and leverage competitive market forces. To drive further innovation and reduce the most emissions at the lowest cost, policies must remain technology agnostic. Governments should not pick winners and losers. Intensity standards establish a level playing field and have a strong precedent.”
Darren Woods
Chairman and CEO

Example: marine fuel

In the 2010s, the International Maritime Organization (IMO) required that the limit for sulfur content in marine fuels be lowered from 3.5% to 0.5%. The feasibility of the change was studied with industry involvement, and the change was messaged to the industry over more than 10 years. This gave shippers and their suppliers time to consider how to best meet the new standard. A variety of solutions were implemented. They included fuel hydrotreating, alternate feeds to marine fuels, onboard scrubbers, and alternate fuel vessels. In 2020, when the standard became effective, only 55 cases of non-compliance were reported among the 60,000 ships driving global trade, according to the IMO.10

In the marine fuel example, demand for the product continued to be driven by the underlying market. However, shippers were required to meet technically achievable standards. Fuel producers had a key role in finding ways to meet the market need affordably with the cost of compliance embedded in the price of the product, while the shippers retrofitted their ships with scrubbers to meet the standard. Using similar approaches, society has been able to address a multitude of environmental and safety challenges.

A carbon-intensity standard could be similarly effective in lowering emissions by creating market-forming policies.

The example below provides additional lessons that can be applied to carbon emissions intensity.

Ultra-low-sulfur diesel (road transport)

Background:
Until the 1990s and early 2000s, sulfur dioxide emissions from diesel fuel use were identified as a contributor to acid rain, which had become a growing public environmental concern.11

Application of product standard:
The European Union and U.S. regulators established limits for sulfur content in diesel fuel. Implementation allowed different regions to reduce sulfur content in various ways.12

Lessons learned:
Collectively, diesel standards reduce sulfur emissions from diesel on- and off-road by more than 90%.13 This has contributed to the significant decline in acid rain and improvement in air quality.14 The standards had several positive features:

  • Allowing different regions to make progress in their own way reflecting local conditions and involvement of industry groups in setting timelines.15
  • Industry collaboration spurring a market mechanism where over-performers exchanged and blended material with under-performers to meet the standards.16 

Incorporating carbon intensity into product-level standards

The global population and demand for reliable, affordable energy will continue to grow. To help emerging and developing nations improve quality of life, we need rational and constructive policies that help lower CO2 emissions and still meet demand for critical products and services.

When governments or international bodies have applied standards to individual products or categories of products, without picking technology winners and losers, producers and sellers have efficiently competed to develop products that meet the emissions-intensity standard at the lowest price.

Governments can require that products must meet these carbon intensity standards to be sold in the market. They can decide the starting point and how to make the standard more stringent over time. Market-forming policies help create demand for lower-emission intensity products, and they help encourage producers to invest in decarbonization efforts.

Policy makers can start with the products that could drive large amounts of global CO2 emission reductions, such as steel, cement, and aviation fuel, where even small changes in carbon intensity would have big impacts.17

This approach embeds the cost of reducing emissions in the product’s price rather than as an explicit tax. The regulated application of carbon-intensity standards would require all entities selling technologies and products into a market to comply with the standard, unlocking innovation, competition, and capital.

Over time, as demand for these lower-carbon-intensity products grows, governments can step back from incentives and let markets handle compliance costs. Producers can use any viable solution to reduce carbon intensity, leading to faster and cheaper emission reductions as technologies are deployed and scaled.

Like technology, policy improvements can help catalyze cost-effective actions to lower emissions by enabling:

  • Different technologies to compete.
  • Market-based trading.
  • Consumer choice.
  • Clear, durable market signals for investment.
  • Consistent policy application at the country level.

 

Why does the approach need to be technology neutral?

Successful policies avoid picking winners and losers. They let technologies compete.

Take the example of low-carbon hydrogen.

Hydrogen produced from natural gas with CCS is a cost-effective, scalable, and rapidly deployable alternative to other low-carbon intensity options.

Intuitively, you might think hydrogen produced using renewable sources like wind and solar would have zero GHG emissions. But as the chart below shows, that’s not the case.

To compare alternatives, you have to consider the life cycle GHG emissions of each. For example, the mining, manufacturing, and transportation needed to build wind turbines, solar panels, and renewable power plants all result in direct GHG emissions and should be accounted.

Natural gas can be used to produce hydrogen using existing infrastructure. While it also involves direct emissions from extraction, processing, and transport, technology can be used to reduce these direct emissions. Additional technologies, such as CCS, can further reduce  emissions when natural gas is converted to hydrogen. 

Key features of effective product-level carbon-intensity standards

  • Product specific: Develop carbon-intensity standards for specific products (e.g., fuels, power, steel, cement) while considering regional factors and resources.
  • Gradual tightening: Set a baseline for carbon intensity and gradually adjust it over time based on regional, sectoral, technological, affordability, and demand factors.
  • Technology neutral: Allow producers to choose any carbon-reducing technology to meet standards, ensuring fair competition without bias.
  • Recognize over-performance: Encourage innovation by rewarding producers who exceed carbon emission intensity standards, allowing them to trade compliance credits within their sector.
  • Ease of implementation: Strategically assess and implement targets across value chains to involve a manageable number of participants (i.e., paper products vs. book printers or cement producers vs. builders) while maximizing emissions coverage.

Proper accounting can help identify today’s lowest-emission pathways for U.S. hydrogen production on an emissions accounting basis18

Image Proper accounting can help identify today’s lowest-emission pathways for U.S. hydrogen production on an emissions accounting basis18
Source: Argonne National Labs, 2025 
* ExxonMobil analysis using CCS and natural gas with reduced direct emissions intensity.
** Well-to-gate.

Successfully implementing product-level carbon-intensity standards will require a well-designed direct carbon-emissions accounting framework

The GHG Protocol, established more than 25 years ago, is often cited as the gold standard for carbon accounting. In our view, nothing could be further from the truth.19 The truth is that the GHG Protocol Corporate Accounting and Reporting Standard, was never designed as an accounting framework for products. It was designed as an inventory-based reporting tool for companies to report their emissions. It is structurally incapable of providing anything approximating an accurate tracking of CO2 as it moves through the economy, for the following reasons:

4 flaws of the GHG Protocol*

  1. Fails to accurately assess a company’s emissions efficiency.
    Holding producers accountable for their absolute emissions, without acknowledging carbon intensity as the most appropriate way of understanding how efficient an emitter is relative to the work it is doing, will simply force a company to produce less as the only way of lowering its GHG Protocol reporting. As a result, even the lowest-emitting companies must cut production or sell assets, which shrinks supply but not demand. That means the world could face shortages, or less efficient companies would step in to meet demand rather than more responsible operators, and global CO2 will rise as a likely consequence. 
  2. Lacks a meaningful way to compare alternatives.
    Because the GHG Protocol focuses on “absolute” measures, a small producer of high-emitting products will appear to be more efficient than a large producer of lower-emitting products. This can penalize companies just for being large, even if they are more efficient.     
  3. Double or even triple counts emissions.
    As designed, the GHG Protocol can account for ExxonMobil’s Scope 2 emissions as another company’s Scope 1 and as a consumer’s Scope 3. This double or triple counting means, by definition, no one can depend on the GHG Protocol to give an accurate picture of CO2 emissions. A system with these inherent flaws cannot be relied on by investors or other stakeholders to accurately gauge a company’s progress in positively (or not) impacting global CO2 emissions.
  4. Doesn’t allow for avoided emissions
    When coal is replaced by LNG in power generation, CO2 emissions can be reduced by up to 60%.20 In fact, the LNG producer risks reputational or financial damage when it’s labeled a “bad actor” because its Scope 1 emissions go up, even as the LNG it produces helps society’s emissions go down. To use another example, ExxonMobil’s current efforts to reduce CO2 emissions for our company and other industries have the potential to reduce carbon emissions by the equivalent of 10 million U.S. households.21,22 That’s a very good thing. But this work will result in a higher Scope 1 and/or 2 number. In this way, the GHG Protocol can actually disincentivize the very work it should be encouraging. 

*GHG Protocol is currently the underlying accounting framework for net-zero and GHG target-setting and disclosure standards such as ISO, CA100+, SBTi, and TPI, among others.

Quite clearly, the GHG Protocol is the wrong tool if the goal is to meet society’s objective of better living standards with reduced CO2 emissions. Despite this, it is often used as the basis for many of today’s policies and corporate disclosure frameworks that have resulted in an overly narrow focus on restricting supply, even as global demand and emissions continue to rise. 

For the world to achieve meaningful reductions in global CO2 emissions, it must have a well-designed carbon-emissions accounting (CEA) framework based on the principles of science and financial accounting that focuses on the product level – one that:

  • Makes clear where and when CO2 is counted in producing and using a product or service.
  • Informs policy decisions that incentivize low-carbon investments and encourage companies to meet society’s needs using the most effective technology options.
  • Enables secure supply of energy, products, and services to grow to meet demand. 

CEA is not financial reporting and should not be treated like financial disclosures. But it should use accounting principles to track and verify CO2 emissions across products, companies, and countries. For example:

  • CO2 should be counted only once. This would allow for an accurate accounting of direct CO2 produced at each stage in the life cycle of a product.
  • When the CO2 associated with each product and service is counted, that total should ultimately balance with the total CO2 emitted to the atmosphere. Think of it like a financial ledger or balancing a checkbook. 

The CEA framework, like other accounting frameworks, should have rules for countries, companies, and products. As mentioned above, CO2 should only be counted once by the product owner. CO2 can then be transferred between entities, but if it is, only the new owner accounts for it. 

A well-designed carbon-emissions accounting framework would more clearly track how reductions in the product-level carbon-intensity standards are impacting overall emissions. Without a standardized approach, society risks continuing down the current path of misguided and deeply flawed measures that fail to account for the true sources of carbon emissions and their relative impact.

Image

Successful transitions happen when policy, industry, and technology work together

An energy transition must begin at the product level. Effective policies engage industry participants and competitive markets to drive the best methods to achieve emission reductions at the lowest cost. Product-level carbon-intensity standards would do just that. 

The right policies can drive innovations and technologies that speed up lower-emission options by fueling competition. And they work in tandem with the broader landscape of energy and economic policy so progress toward one objective doesn’t undermine another.

When governments focus on the “what” rather than the “how,” they avoid picking winners and losers so that companies can develop and deploy a full range of strategies and technologies for lower-emission-intensity products and solutions.

Direct carbon emissions accounting goes hand-in-hand with carbon-intensity standards to bring all the market forces to bear in reducing emissions. Importantly, it enables emissions reductions in existing products and systems, thus spreading the cost across a very large, established base, which means you can maintain affordability and achieve higher levels of carbon reduction.

A business-led coalition that leverages its collective expertise and experience could help support this approach. If governments, the private sector, and others work together to implement policies that are  technology agnostic, competitive markets will develop and spur innovation. It’s been done before at the product level. We’re confident it can be done again to advance an energy transition that grows the supplies of affordable energy and products people need and moves the world toward a lower-emissions future.  

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FOOTNOTES:

  1. UN Climate Change, Global Stocktake: https://unfccc.int/topics/global-stocktake/about-the-global-stocktake/outcome-of-the-first-global-stocktake.
  2. The content that follows is informed by research and analysis from McKinsey & Company, in collaboration with ExxonMobil. Individual data points have not been independently verified.
  3. IEA World Energy Mix, Energy supply (2000-2022): https://www.iea.org/world/energy-mix#where-does-the-world-get-its-energy.
  4. ExxonMobil 2024 Global Outlook.
  5. IEA (2025), Global Energy Review 2025, IEA, Paris https://www.iea.org/reports/global-energy-review-2025, Licence: CC BY 4.0; Institute for Energy Research - Renewable Energy Received Record Subsidies in 2024: https://www.instituteforenergyresearch.org/renewable/renewable-energy-received-record-subsidies-in-2024/.
  6. IEA (2025), Global Energy Review 2025, IEA, Paris https://www.iea.org/reports/global-energy-review-2025, Licence: CC BY 4.0; Global CO2 emissions from energy combustion and industrial processes (2014-2024).
  7. NDC registry as of February 10, 2025: https://unfccc.int/NDCREG.
  8. IEA (2023), Tracking Clean Energy Progress 2023, IEA, Paris https://www.iea.org/reports/tracking-clean-energy-progress-2023, License: CC BY 4.0.
  9. ASTM standards, by category: https://store.astm.org/products-services/standards-and-publications/standards/standards-category-list.html.
  10. International Maritime Organization, January 28, 2021: https://www.imo.org/en/MediaCentre/PressBriefings/pages/02-IMO-2020.aspx.
  11. U.S. EPA Federal Register, Vol. 66, No. 12/Thursday, January 18, 2001/ Rules and Regulations, p. 5025 of https://www.govinfo.gov/content/pkg/FR-2001-01-18/pdf/01-2.pdf
  12. Ibid;. European Added Value in Action Briefing  (pg. 2): https://www.europarl.europa.eu/RegData/etudes/BRIE/2017/603237/EPRS_BRI(2017)603237_EN.pdf
  13. U.S. EPA diesel fuel standards and rulemakings: https://www.epa.gov/diesel-fuel-standards/diesel-fuel-standards-and-rulemakings#:~:text=Overview%20of%20Diesel%20Standards&text=EPA%20began%20regulating%20diesel%20fuel,low%20sulfur%20diesel%20(ULSD)
  14. U.S. EPA Student Center, Acid Rain: https://www3.epa.gov/acidrain/education/site_students/beingdone.html, https://www3.epa.gov/acidrain/education/site_students/whyharmful.html
  15. U.S. EPA Diesel Fuel Standards and Rule Making: https://www.epa.gov/diesel-fuel-standards/diesel-fuel-standards-and-rulemakings; Official Journal of the European Union (March 3, 2003): eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32003L0017&qid=1745552991151.
  16. U.S. EPA, Sulfur Averaging, Banking, and Trading (ABT) Program: https://www.epa.gov/renewable-fuel-standard-program/sulfur-averaging-banking-and-trading-abt-credit-data
  17. ExxonMobil 2024 Global Outlook. 
  18. Includes the embodied emissions with power generation.
  19. Roger S Ballentine, The unusual suspects: are well-meaning environmental stakeholders and institutions undercutting the contributions that companies can make to fighting climate change?, Oxford Open Climate Change, Volume 3, Issue 1, 2023, kgad009, https://doi.org/10.1093/oxfclm/kgad009.
  20. Based on ExxonMobil analysis for power plant use including EIA U.S. electricity net generation and resulting CO2 emissions: https://www.eia.gov/tools/faqs/faq.php?id=74&t=11. Reductions may vary based on regional differences and other variables.
  21. We see the opportunity to help other essential industries and customers achieve their goals to lower emissions. Estimates of GHG emissions are on a life cycle basis and include avoided and abated emissions from hydrogen, lower emission fuels, and carbon capture and storage. For example, customers could avoid up to 25 MTA of their GHG emissions if all of ExxonMobil’s projected 2030 supply to the market of lower-emission fuels displaces conventional fuel refined from crude oil. Calculation is an ExxonMobil analysis illustrating the general benefits of lower-emission fuels based on estimated fuel carbon intensity (CI) from various third-party sources (such as Argonne National Labs’ GREET model) as compared against its conventional fuel alternate on a life cycle basis. Calculation is an estimate that represents a range of potential outcomes that are based on certain assumptions. Estimates are based on the potential implementation of projects or opportunities that are at various stages of maturity. Individual projects or opportunities may advance to a final investment decision by the company based on a number of factors, including availability of supportive policy and permitting, technology and infrastructure for cost-effective abatement, and alignment with our partners and other stakeholders. Actual avoided and abated emissions may differ.
  22. EPA’s greenhouse gas equivalencies calculator: Carbon dioxide or CO2 equivalent converted to a U.S. home’s electricity use for one year: https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator#results.