Comments on Draft South African Framework on Article 6

A statement submitted on 13 December 2024 by a coalition of civil society organizations, including Natural Justice and SAFCEI, providing critical comments on South Africa's Draft Article 6 Framework. The coalition argues that carbon markets are fundamentally flawed and risk enabling human rights abuses, land grabs, and the evasion of actual emission reductions.

• The coalition fundamentally rejects carbon markets as an effective climate response, arguing they legitimize emission-intensive development and may increase vulnerability to climate impacts. They assert that carbon markets should not replace the climate finance developed countries are obligated to provide to developing nations, nor should they be used to reduce mitigation ambition.
• The draft framework is criticized for lacking robust social and environmental safeguards, specifically the omission of Free, Prior and Informed Consent (FPIC). The authors warn that without explicit protections, the framework risks enabling land grabs and the displacement of indigenous peoples and local communities for mitigation projects.
• The coalition objects to the designation of the Department of Mineral Resources and Energy (DMRE) as the Designated National Authority (DNA), proposing instead that this role be moved to the Department of Forestry, Fisheries and the Environment (DFFE), which serves as the Designated Focal Point.
• The authors argue that the framework's reliance on third-party carbon standards (such as the Gold Standard and Verified Carbon Standard) compromises national autonomy and environmental integrity. They cite a study indicating that only 16% of nearly 1 billion credits issued under the CDM and VCM likely represent a full tonne of CO2 reduction.
• The 'Rainbow list' in the draft framework, which does not discriminate against types of carbon offset technologies, is viewed as dangerous. The coalition argues this creates a permissive environment for ineffective or destructive geoengineering and energy technologies that cannot deliver real mitigation.
• The coalition identifies a lack of mechanisms to ensure fair compensation for local communities hosting projects. They recommend the creation of a Community Benefit Fund funded by a share of proceeds from carbon credit sales, with compensation based on revenue rather than profits.
• The document claims that carbon removal technologies are either reversible (natural ecosystems) or resource-intensive and unproven at scale (industrial technologies). It specifically notes that land-based removals like BECCS could threaten planetary boundaries regarding freshwater and cropland.

APA

Natural Justice (n.d.). Comments on Draft South African Framework on Article 6. https://naturaljustice.org/wp-content/uploads/2025/01/Civil-Society-Comments-on-Draft-South-African-Framework-on-Article-6.pdf

Chicago

Natural Justice. Comments on Draft South African Framework on Article 6. n.d. https://naturaljustice.org/wp-content/uploads/2025/01/Civil-Society-Comments-on-Draft-South-African-Framework-on-Article-6.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=Comments on Draft South African Framework on Article 6 |url=https://naturaljustice.org/wp-content/uploads/2025/01/Civil-Society-Comments-on-Draft-South-African-Framework-on-Article-6.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljusticendcomments, author = {{Natural Justice}}, title = {{Comments on Draft South African Framework on Article 6}}, publisher = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2025/01/Civil-Society-Comments-on-Draft-South-African-Framework-on-Article-6.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }