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CDM Watch and partner organizations are calling on EU Environment Ministers to ensure that HFC-23 and adipic acid (N2O AA) offset credits are banned from national registries for non-traded sectors by April 2013. While these credits are banned from the EU Emissions Trading System (EU ETS) as of 30 April 2013, the authors argue that the Effort Sharing Decision (ESD) could be exploited to allow their use toward national targets, undermining domestic emissions reductions and the Montreal Protocol.

Key insights

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  • EU Member States agreed on 21 January 2011 to a European Commission proposal banning HFC-23 and N2O from adipic acid (N2O AA) abatement project credits from the EU Emissions Trading System (EU ETS) starting 30 April 2013.
  • Industrial gas credits are criticized for undermining the Montreal Protocol and EU international climate goals, providing limited sustainable development benefits, and failing to represent real emissions reductions.
  • There is a risk that EU Member States may use the wording of the Effort Sharing Decision (ESD) to continue using banned HFC-23 and N2O AA credits for national targets in non-traded sectors, where offsets can account for up to two-thirds of required reductions from 2013-2020.
  • Denmark and the United Kingdom have committed to not using HFC-23 and N2O AA credits for compliance after 2012, aligning their national rules with those of the EU ETS.

Cite the original document

APA
Filzmoser, E., Walravens, F., & Elsworth, R. (2011). Open letter to EU Environment Ministers. Carbon Market Watch. https://carbonmarketwatch.org/publications/open-letters-regarding-the-use-of-banned-offsets-by-eu-member-states/
Chicago
Filzmoser, Eva, Fionnuala Walravens, and Rob Elsworth. Open letter to EU Environment Ministers. Carbon Market Watch, 2011. https://carbonmarketwatch.org/publications/open-letters-regarding-the-use-of-banned-offsets-by-eu-member-states/.
Wikipedia
{{cite press release |last1=Filzmoser |first1=Eva |last2=Walravens |first2=Fionnuala |last3=Elsworth |first3=Rob |title=Open letter to EU Environment Ministers |publisher=Carbon Market Watch |date=10 March 2011 |url=https://carbonmarketwatch.org/publications/open-letters-regarding-the-use-of-banned-offsets-by-eu-member-states/ |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{filzmoser2011open, author = {Filzmoser, Eva and Walravens, Fionnuala and Elsworth, Rob}, title = {{Open letter to EU Environment Ministers}}, publisher = {Carbon Market Watch}, year = {2011}, month = mar, url = {https://carbonmarketwatch.org/publications/open-letters-regarding-the-use-of-banned-offsets-by-eu-member-states/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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