Withdrawal of Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF63 (90 Fed. Reg. 44321)

The Clean Air Task Force (CATF) argues that the CFTC's withdrawal of guidance for voluntary carbon credit derivative contracts risks eroding market integrity and undermining climate progress. CATF highlights systemic quality issues in voluntary carbon markets, particularly in forest carbon credits, and contends that the withdrawal process lacked transparency and legal justification. The organization recommends that the CFTC not only reinstate the guidance but move toward issuing specific regulations for these markets.

• The voluntary carbon market has experienced stagnation and volatility due to persistent concerns regarding credit quality, with total trade reaching $2 billion in 2021 but declining by 25 percent in total transactions in 2024.
• Market value projections for 2050 vary drastically based on credit integrity: BloombergNEF estimates the market could exceed $1.1 trillion annually with high trust, but would be limited to no more than $34 billion if integrity issues remain unaddressed.
• Forest carbon credits, which comprise nearly 40% of the global voluntary carbon market, suffer from flawed protocols characterized by a lack of additionality, indirect emissions from leakage, permanence risks from wildfires and pests, and weak monitoring and verification.
• The CFTC's withdrawn guidance aimed to standardize voluntary carbon credit derivatives to promote transparency and liquidity, focusing on quality standards such as additionality, permanence, risk of reversal, and robust quantification.
• CATF asserts that the CFTC's withdrawal of the guidance was 'arbitrary and capricious' because it lacked a public notice and comment period and failed to provide a detailed justification for contradicting previous factual findings regarding the unique attributes of voluntary carbon markets.

APA

Clean Air Task Force (2025). Withdrawal of Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF63 (90 Fed. Reg. 44321). https://www.catf.us/wp-content/uploads/2025/12/cftc-withdrawal-letter-122025.pdf

Chicago

Clean Air Task Force. Withdrawal of Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF63 (90 Fed. Reg. 44321). 2025. https://www.catf.us/wp-content/uploads/2025/12/cftc-withdrawal-letter-122025.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Withdrawal of Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF63 (90 Fed. Reg. 44321) |date=11 December 2025 |url=https://www.catf.us/wp-content/uploads/2025/12/cftc-withdrawal-letter-122025.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2025withdrawal, author = {{Clean Air Task Force}}, title = {{Withdrawal of Commission Guidance Regarding the Listing of Voluntary Carbon Credit Derivative Contracts, RIN 3038–AF63 (90 Fed. Reg. 44321)}}, publisher = {Clean Air Task Force}, year = {2025}, month = dec, url = {https://www.catf.us/wp-content/uploads/2025/12/cftc-withdrawal-letter-122025.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }