For steel, we note that the SAT criteria for amber activities align with the green criteria for production facilities operational prior to 2022 (with a sunset date of 2030). If a loan matures before 2030, should the borrower label the activity as green (aligned with CBI) or amber (aligned with SAT)?
If a loan matures before 2030, reference can be made to the grandfathering rules in “#3 Grandfathering rules and provisions in the SAT” in the “Guidance for Leveraging the Singapore-Asia Taxonomy in Green and Transition Financing” published by SSFA as of July 2025. [Updated in Dec 2025]
For steel, we understand that the SAT criteria are aligned with the CBI criteria. The CBI distinguishes between criteria for new and existing steel plants based on a 2022 cutoff, but the SAT does not seem to take the same approach. Could SAT provide clarification on this?
Yes, the methodologies for SAT are based on CBI, and it is also mentioned to have a reduction in impact percentage between 2022 and 2030 by decarbonisation efforts. [Updated in Dec 2025]
For the manufacture of cement, it is noticed that the use of recycled aggregates was not taken into consideration. Why is it so? The Green Cement label under the Singapore Green Label Scheme takes this into account.
The Cement Criteria and the Green Cement label under the Singapore Green Label Scheme are not equivalent. The Singapore Green Label Scheme applies to individual products; it allows certified products to earn points toward a project’s Green Mark rating. Products with higher ratings under the SGBP Scheme contribute more points to the Green Mark certification […]
For cement, why are single or combined decarbonisation measures considered eligible only for amber labelling, rather than green? Would emission intensity be a factor in the assessment? For example, if a facility integrates renewable energy measures but still has an overall emission intensity below the threshold in Table 11, would the project be eligible for green labelling?
Regarding TSC 4.2 Manufacture of Cement, single or combined decarbonisation measures are currently eligible for amber labelling because they represent initial steps towards reducing emissions, but may not yet achieve the significant impact required for green labelling. Emission intensity is indeed a critical factor in the assessment process. If a facility integrates renewable energy measures […]
For hydrogen, when considering multiple production facilities owned by the borrower, is the emission intensity threshold applied on a facility-by-facility basis or as an average across all facilities?
Green criteria for the manufacturing of hydrogen assess and pertain only to the cradle-to site emissions at the individual facility level. [Updated in Dec 2025]
For basic chemicals, how is emission intensity determined for production facilities that produce a mix of various chemical products? Can this be assessed at the facility level rather than on a product-by-product basis?
For facilities producing a mix of basic chemical products, emission intensity should ideally be determined at the product level to ensure that carbon performance is benchmarked meaningfully against sectoral thresholds. Product-level assessment enables better comparability and scalability of outcomes across the industry. However, recognizing the complexity of integrated production systems in the basic chemicals sector, […]
Under TSC 4.7 Manufacture of Batteries, it states that the batteries need to result in “substantial GHG emission reductions”. How does one track and evidence the way the batteries are used, the source of energy (grid or otherwise), and end-of-life/circularity in order to estimate said “substantial GHG emission reductions” (which happens in the future)?
To effectively track and evidence the use of batteries, the source of energy (whether from the grid or otherwise), and end-of-life circularity, we recommend a comprehensive approach that encompasses the entire battery value chain. This includes: Embedded Emissions: Assessing the GHG emissions associated with the production and operation of the batteries, including raw material extraction, […]
Under TSC 4.7, Manufacture of Batteries, it states that batteries must achieve “substantial GHG emission reductions”.
Additional question: What is the definition of “substantial”? — The definition of “substantial” under TSC 4.7 Manufacture of Batteries refers to a significant and measurable reduction in greenhouse gas emissions compared to a baseline scenario. While a precise numerical threshold may vary depending on the specific application and context, it generally implies a positive impact […]
The eligibility criteria for battery recycling are not clearly stated. Does it mean that all the recycling types are acceptable, including pyrometallurgical recycling? Some corporates/ banks have been unsure about using the term “green” for some recycling methods. We believe adding clarifications would help avoid potential misinterpretations.
Financial institutions can do their own assessment and interpretation, including whether the jurisdiction in which the company is mandated has any lithium recovery targets. [Updated Dec 2025]
Under TSC 4.11, it says “household appliances falling into the highest TWO classes of energy efficiency in accordance with local market standards”. But in TSC 4.12, it says “goods that meet the HIGHEST performance level for a given good in energy rating system introduced by the NEA or internationally available equivalent”. Due to the similar nature of the goods in question, should it be the highest two or just the highest?
TSC 4.11 pertains to commercial building applications, which also use household equipment (only minimum equipment, such as an electric kettle, oven, refrigerator, etc.), and may have the option to choose from the top two ratings. TSC 4.12 is specifically for the household/ residential sector, which needs to be aligned with NEA consumer durable energy rating, […]
