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The document highlights the impact of human-induced changes to the global nitrogen cycle, specifically the use of manufactured nitrogen-based fertilisers. It notes that reactive nitrogen levels have tripled in Europe and doubled globally over the last century, leading to ecosystem eutrophication, biodiversity loss, and the exacerbation of climate change.

The submission argues that environmental attribute certificates, specifically REDD+ carbon credits and energy certificates like RECs and GOs, are unsuitable for corporate decarbonisation targets. It highlights systemic issues in the voluntary carbon market, including over-crediting and flawed methodologies in REDD+ projects, and asserts that energy certificates are financial instruments that do not represent physical electricity delivery. The document advocates for a strict separation of these certificates from gross emission reduction targets, citing the EU Corporate Sustainability Reporting Directive (CSRD) as a regulatory precedent.