An input-output subsystem is used to discuss the CO 2 emissions of China's tertiary industry by subdividing consumption activities of the tertiary sectors into five components. The results show that total CO 2 emissions induced by the tertiary industry accounted for 17.4% of China's total CO 2 emissions in 2007; of which direct emissions accounted for 3%, and pull effects of tertiary sectors on other sectors accounted for 20.2%. The pull effects of tertiary sectors on non-tertiary sectors must also be considered in order to establish a low-carbon development path for China's tertiary industry. Though China's tertiary sectors are relatively 'low-carbon' compared with non-tertiary sectors, to reduce the impact of tertiary sectoral behaviours on non-tertiary sectors, and design a reasonable sectoral structure for China's tertiary industry, are the key challenges for designing a real 'low-carbon' development path for China.Keywords: tertiary industry; input-output subsystem; CO 2 emissions; pull effect.Reference to this paper should be made as follows: Yi, W., Guo, J. and Zou, L. (2016) Jie Guo, PhD, is an associate researcher in China Academy of Transportation Sciences (CATS). His research concerns tackling climate change, energy conservation, low-carbon transportation and other fields, and he leads a research team on Chinese transportation energy conservation and emission reductions management projects.Le-le Zou, PhD, is an Associate Professor in the Institute of Policy and Management, Chinese Academy of Sciences. Her expertise is in modelling and analysing policy issues with combinative methods of cross-discipline. Her recent researches focus on energy policy and energy economics, CO 2 reduction and climate policy, comprehensive analysis of low carbon development issues in China, complex system analysis and modelling. She has chaired over ten national and international research projects, published three books and over 20 papers in peer-reviewed journals.