There are two reasons why CO2 emissions linked to FIE exports matter. First, up to 50% of the economic benefits generated by FIEs' exports return to the home countries (Ahmad and Ribarsky, 2014). Ma et al. (2015), for example, found that in 2007 foreign content accounted for 52.9% of the value-added generated by exports of FIEs' based in China, whereas foreign content accounted for only 24.9% of the value-added generated by COE exports.2 Therefore, CO2 emission responsibilities embodied in each unit of national income from exports may differ significantly from the picture based on traditional emission intensity per unit of exports. Thus from a national-income-based perspective, it is both important and relevant to (i) compare the extent to which China is responsible for CO2 emissions embodied in the exports of FIEs as compared to when they are produced by COEs, and (ii) suggest some potential implications for China and for global emissions policies.