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The Ten-Thousand Enterprises Program is China’s keystone energy conservation and climate change program. The program has effectively created a class of energy-intensive enterprises that are regulated by the government for energy conservation purposes. Through an empirical study conducted in Changchun, this paper shows that the adoption of energy efficiency technologies and practices has been highly uneven in this class of enterprises because of two reasons. First, a de facto two-tier regulatory system has emerged within the framework of the Ten-Thousand Enterprises Program. Central state-owned enterprises are closely regulated by the State-Owned Assets Supervision and Administration Commission (SASAC) which is a central government apparatus, whereas local state-owned enterprises and privately owned enterprises are regulated by the local government, which has fewer resources and incentives to implement the program rigorously. Second, the Ten-Thousand Enterprises Program bundles together different types of enterprises. This approach places smaller enterprises at a disadvantage and limits their ability to conserve energy. [ABSTRACT FROM AUTHOR]