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In the context of a rapidly evolving Clean Development Mechanism (CDM) market and increasing debate about the design of a future global climate regime, it is essential to understand which types of projects are undertaken along industrial value chains, and also the influence of company characteristics (e.g. size, raw material base, product type, ownership and location) on firms' CDM participation and choice of project type. The Indian pulp and paper industry was examined for its energy intensity and its diversity in terms of both mitigation opportunities and company characteristics. Large firms were found to be more likely than small firms to participate in CDM. Although CDM projects in large and small firms generate similar amounts of certified emission reductions (CERs), the type of technology implemented in those projects varies strongly with company size due to differing levels of capabilities and capital. Mill size and raw material base also affect participation and choice of project type. A structured approach is suggested for analysing how to engage different subsectors of an industry in mitigation efforts based on transnational sectoral approaches, domestic sectoral approaches, and programmatic CDM. Preliminary policy recommendations are offered for the Indian pulp and paper industry, as well as insights that are transferable to other countries. A one-size-fits-all sectoral approach is difficult to implement and a strategy for differentiated treatment based on company characteristics is required to reflect local development priorities. [ABSTRACT FROM AUTHOR]