SEI Response to Criticism Raised about the SEI Working paper on Adipic Acid CDM Projects

This document is a formal response by the Stockholm Environment Institute (SEI) to critiques of a working paper concerning Clean Development Mechanism (CDM) projects for adipic acid. The authors, Anja Kollmuss and Michael Lazarus, defend their findings regarding the competitive advantages provided by Certified Emission Reductions (CER) revenues and the resulting risk of carbon leakage.

• SEI maintains that CDM plants in the adipic acid market retain a strong competitive advantage even when using lower primary CER (pCER) price estimates and accounting for Chinese CER taxes. For example, assuming a pCER price of 9.5 EUR and a 30% Chinese CER tax on N2O projects, CDM revenues would still exceed 500 EUR per ton of adipic acid, which is several times the plant-by-plant variation in production costs of approximately 120 EUR.
• The authors defend their estimate that carbon leakage from adipic acid projects in 2008 and 2009 was approximately 20% of total issued adipic acid CERs. They argue that the discrepancy in plant utilization rates between CDM and non-CDM plants was more pronounced in Asia than globally: in 2008, rates were 90% for CDM versus 58% for non-CDM, and in 2009, they were 85% versus 45%.
• SEI argues that anti-dumping tariffs imposed by China in November 2009 on adipic acid imports from the US, EU, and South Korea (ranging from 5% to 35.4%) did not cause the observed production discrepancies, as those differences were already evident in 2008. Furthermore, these measures may exacerbate carbon leakage by incentivizing production shifts to Chinese CDM plants or increase N2O emissions by shifting production to non-abating Chinese plants.
• The authors suggest that the current CDM methodology is flawed because it allows plants to receive credit for 100% of emissions reductions, ignoring that N2O abatement has been common practice since the 1990s. They propose adopting a more stringent baseline emissions factor similar to that used in Joint Implementation (JI) projects, which only credit reductions above 90%, to eliminate the risk of carbon leakage while maintaining project viability.

APA

Kollmuss, A., & Lazarus, M. (2010). SEI Response to Criticism Raised about the SEI Working paper on Adipic Acid CDM Projects. Stockholm Environment Institute. https://www.sei.org/mediamanager/documents/Publications/Climate/sei-responsetocriticism-adipic-acid12-9-10.pdf

Chicago

Kollmuss, Anja, and Michael Lazarus. SEI Response to Criticism Raised about the SEI Working paper on Adipic Acid CDM Projects. Stockholm Environment Institute, 2010. https://www.sei.org/mediamanager/documents/Publications/Climate/sei-responsetocriticism-adipic-acid12-9-10.pdf.

Wikipedia

{{cite press release |last1=Kollmuss |first1=Anja |last2=Lazarus |first2=Michael |title=SEI Response to Criticism Raised about the SEI Working paper on Adipic Acid CDM Projects |publisher=Stockholm Environment Institute |date=December 2010 |url=https://www.sei.org/mediamanager/documents/Publications/Climate/sei-responsetocriticism-adipic-acid12-9-10.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{kollmuss2010sei, author = {Kollmuss, Anja and Lazarus, Michael}, title = {{SEI Response to Criticism Raised about the SEI Working paper on Adipic Acid CDM Projects}}, publisher = {Stockholm Environment Institute}, year = {2010}, month = dec, url = {https://www.sei.org/mediamanager/documents/Publications/Climate/sei-responsetocriticism-adipic-acid12-9-10.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }