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Roadmap towards Nature Credits
ClientEarth critiques the European Commission's 'Roadmap towards Nature Credits', warning that a market for biodiversity credits could undermine EU environmental law if not strictly separated from regulatory obligations and offsetting. The organization argues that the biodiversity financing gap—estimated at 19 billion euros per year in the EU—should first be addressed by scaling up public funds and redirecting the 48 billion euros in annual harmful subsidies. ClientEarth recommends that any future credit system be strictly outcome-based, exclude 'business-as-usual' practices, and prohibit the use of credits for ecological compensation (offsetting) to avoid 'net loss' of biodiversity. It further highlights the scientific complexity of measuring biodiversity compared to carbon, cautioning against reductionist proxy metrics that could lead to greenwashing.
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Document type: Statement
Companies role in scaling up DURABLE CARBON DIOXIDE REMOVALS
The report finds that while durable CDR (storage >1,000 years) is essential for neutralizing fossil emissions, corporate uptake is low and concentrated among a few companies, notably Microsoft. Many companies instead rely on non-durable CDR, which the authors argue is unsuitable for neutralizing long-cycle emissions. The report highlights risks of double counting between companies and governments and a systemic lack of transparency regarding the environmental and social impacts of CDR projects. It recommends that voluntary initiatives like SBTi require companies to set separate monetary and removal targets based on ability to pay, rather than merging them into net-zero goals.
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Document type: Report
The Production Gap 2025 Report
The Production Gap Report 2025 finds that governments are collectively planning more fossil fuel production than in 2023, with 2030 projected levels exceeding 1.5°C-consistent pathways by over 120%. While some countries are developing net-zero aligned scenarios, most continue to expand production and provide substantial financial support for fossil fuels, undermining Paris Agreement commitments.
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Document type: Report
NET ZERO STOCKTAKE 2025
The Net Zero Stocktake 2025 finds that while net zero target-setting continues to rise among companies and subnational governments, national-level coverage has dipped due to the US formally abandoning its target. Target integrity remains low, with only a small fraction of entities meeting minimum procedural and substantive requirements. The report also highlights a concerning corporate reliance on nature-based removals and offsets, which often lack transparency and durability.
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Document type: Report
Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals
The policy brief by Carbon Market Watch and Oeko-Institut criticizes the draft CRCF methodologies for permanent carbon removals, citing critical failures in additionality, biomass accounting, and long-term monitoring. It argues that the current framework risks certifying low-quality units that do not represent actual emission reductions, potentially undermining EU climate action.
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Document type: Policy brief
The Carbon Crediting Data Framework
The Carbon Crediting Data Framework (CCDF) is a four-part toolkit (executive report, implementation spreadsheet, technical documentation, and JSON schema) created by RMI's Carbon Markets Initiative to address data fragmentation in the voluntary carbon market (VCM). The framework synthesizes requirements from over 160 sources to provide a common language for 570 individual data fields across 22 categories and 48 sub-categories. It organizes data into four tiers based on the project lifecycle: Pre-Registration (Tier 0), Validation (Tier 1), Verification (Tier 2), and Innovation & Ambition (Tier 3). The CCDF specifically integrates socio-environmental (SE) data as core benefits rather than optional add-ons, drawing on standards from international finance institutions and the UN. Early implementation by Centigrade demonstrates that the framework can reduce due diligence time and transaction costs, which can otherwise exceed $100,000 per project. RMI is also using the CCDF to support the Carbon Data Open Protocol (CDOP) in developing a unified VCM data schema.
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Document type: Executive summary
CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity
A coalition of NGOs, including Carbon Market Watch, warns that the European Commission's draft delegated act for permanent carbon removals—covering DACCS, BioCCS, and biochar—fails to meet the legal requirements of the CRCF regulation. The group argues the methodologies are of low quality, fail to address indirect land use change, assume automatic additionality, and lack sufficient MRV and liability rules for biochar. They call on the European Parliament and Council to object to the draft and urge the Commission to prevent the integration of these units into the EU ETS until quality is ensured.
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Document type: Statement
Expert feedback on CRCF methodologies Part II
The document outlines the structure of the EU's Carbon Removals and Carbon Farming (CRCF) certification framework and its associated methodologies for permanent removals, carbon farming, and carbon storage in products. It highlights the 'QU.A.L.ITY' criteria used for certification and expresses concern that the EU Carbon Removals Expert Group (CREG) is dominated by industry lobbyists, prompting Carbon Market Watch to commission independent expert reviews of the draft methodologies published in April 2025.
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Document type: Report
What does proposed EU 2040 target mean for climate action?
The European Commission's proposed net 90% emissions reduction target for 2040 is criticized by Carbon Market Watch for being inadequate and lacking accountability. The analysis highlights risks associated with the potential use of international carbon credits, the absence of separate targets for gross emissions and removals, and the proposed integration of permanent removals into the EU ETS, which may create loopholes for polluters.
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Document type: Research paper
The geography of clean energy investments in the U.S.
The document analyzes how federal clean energy incentives have driven over $321 billion in investments across the U.S. between Q2 2022 and Q1 2025, highlighting that these investments are heavily concentrated in Southern and Western states and Republican-held congressional districts. It argues that rolling back these incentives would disproportionately harm these regions and jeopardize significant outstanding investments in states like Louisiana and North Dakota, as well as major projects in emerging hubs like Southern Arizona and the Southeast.
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Document type: Briefing
Feedback to call for evidence - ETS1 review
Carbon Market Watch argues that the EU ETS1 fails to drive industrial decarbonisation due to the continued allocation of free emission allowances, which it claims undermines the carbon price signal for sectors like steel, cement, and chemicals. The submission calls for the complete phase-out of free allocations and indirect cost compensation, suggesting that any remaining benefits be tied to decarbonisation milestones. It further advocates for expanding the ETS scope to cover all departing flights from 2027, including non-CO2 effects and flights to third countries, and extending maritime coverage to 100% of extra-EEA routes and all small ships by 2027. Regarding market stability, the document suggests maintaining existing Market Stability Reserve (MSR) and Linear Reduction Factor (LRF) rules until 2035 to preserve investment signals. Finally, it strongly opposes the integration of carbon removals into the EU ETS to avoid mitigation deterrence and the risk of using removals as a substitute for actual emission reductions.
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Document type: Statement
Corporate Climate Responsibility Monitor 2025
The Corporate Climate Responsibility Monitor 2025 finds that none of the 20 assessed companies demonstrate a climate strategy of 'reasonable' or 'high' integrity. The report highlights that 2030 emission reduction targets are increasingly 'unfit for purpose' due to structural obstacles, including incomplete emissions disclosures and sector-specific accounting malpractices. In the tech sector, soaring energy demand from AI and a reliance on outdated market-based accounting for electricity undermine target credibility. The automotive sector shows inadequate progress in phasing out internal combustion engines, while the fashion sector lacks commitments to reduce overproduction. The agrifood sector is criticised for relying on undefined land-based carbon removals to obscure a lack of structural emission reductions. The report argues for the adoption of transition-specific alignment targets to complement general GHG targets.
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Document type: Report
Corporate Climate Responsibility Monitor 2025
The report finds that the five largest incumbent light-duty vehicle manufacturers are making inadequate progress in transitioning to electric mobility. Most assessed companies have 2030 emission reduction targets that are critically insufficient and long-term net-zero pledges that lack concrete substantiation. While some companies have committed to procuring near-zero emission steel and aluminium, other critical transitions, such as reducing battery production emissions and improving electric vehicle efficiency, are largely neglected. The analysis highlights a significant gap between corporate pledges and the 1.5°C-compatible pathways required for the passenger transport sector.
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Document type: Report
How effective are Article 6 carbon market rules?
The report evaluates the Article 6 carbon market rules finalized at COP29. It finds that Article 6.2 provides a weak, decentralized framework with significant loopholes in additionality, permanence, and accountability. Article 6.4 is rated more robust due to its centralized Supervisory Body and structured transparency, though it still lacks sufficient safeguards for land rights and permanence. The author argues that the current framework is not robust enough to ensure high-quality carbon credits and warns developed countries against using these markets to meet their NDCs.
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Document type: Report
Private Equity, Public Harm
The report estimates that air pollution from a subset of private equity-backed fossil fuel infrastructure in the U.S. causes between $11.3 billion and $15.1 billion in annual health costs. Using the EPA's COBRA tool, the analysis finds these facilities are responsible for approximately 1,000 premature deaths and 1,500 emergency room visits each year. The document argues that private equity firms must disclose their fossil fuel exposure and health impacts, cease investments in fossil fuel expansion by 2030, and integrate environmental justice into their operations.
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Document type: Report
Harnessing Carbon Removal Opportunities in Desalination
The report examines how coastal desalination plants can integrate carbon removal technologies, such as Direct Ocean Capture (DOC), Electrochemical Ocean Alkalinity Enhancement (eOAE), and Direct Air Capture (DAC), by leveraging existing seawater pumping infrastructure and brine outflows. It identifies significant synergies, including reduced energy costs when using concentrated brines and potential energy savings of up to 30% through shared infrastructure. While theoretical carbon removal capacities are high—with eOAE potentially reaching 200 MtCO2/y under ideal conditions—the report highlights critical constraints such as high low-carbon energy requirements (up to 2.8 MWh/tCO2), the need for large-scale acid or chlorine byproduct offtake, and the necessity for rigorous environmental safety testing regarding pH and salinity changes in marine ecosystems.
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Document type: Report
The EU ETS and the 2040 Climate Target
The report finds that current EU ETS cap trajectories are more ambitious than required by most climate neutrality scenarios, potentially leading to severe allowance shortages and price spikes after 2035. It evaluates several reform options to balance supply and demand, including adjusting the linear reduction factor (LRF), reforming the Market Stability Reserve (MSR), and integrating carbon dioxide removals (CDRs). The authors warn against the inclusion of Article 6 international credits due to risks to environmental integrity and the potential for market collapse. Recommended solutions include a combination of MSR replenishment and technological CDRs or a phased reduction of the LRF post-2035.
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Document type: Report
Private Equity, Public Harm
The report 'Private Equity, Public Harm' estimates that private equity-backed fossil fuel infrastructure in the U.S. generates annual health costs between $11.3 billion and $15.1 billion, causing approximately 1,000 premature deaths and 1,500 emergency room visits yearly. Using the EPA's COBRA tool, the analysis identifies significant impacts from pollutants such as SO₂, NOₓ, VOCs, and PM2.5, noting that several individual private equity firms are responsible for over $1 billion in annual health impacts. The document calls for mandatory disclosures of fossil fuel exposure and emissions, a complete transition to a fossil-free portfolio by 2030, and the integration of environmental justice mechanisms to protect impacted communities.
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Document type: Report
Corporate Climate Responsibility Monitor 2025 methodology
The Corporate Climate Responsibility Monitor (CCRM) methodology v5.0 provides a stepwise framework for assessing corporate climate claims across four key areas: emissions tracking, target setting, sectoral transitions, and responsibility for ongoing emissions and removals. The 2025 update introduces revised weightings for scoring, a new progress assessment for five-year emission trends, a full methodological revision of sectoral transition evaluations, and updated scientific insights regarding durable carbon dioxide removal.
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Document type: Guide
Corporate Climate Responsibility Monitor 2025
The report finds that while some fashion companies have improved their GHG emission reduction targets, these commitments often lack credibility due to a failure to implement systemic transitions. Key issues include a reliance on 'false solutions' like biomass and fossil gas instead of electrification, limited transparency regarding supply chain energy, and a persistent adherence to fast fashion business models that prioritise volume over value. While H&M Group is noted for its transparency in disclosing supply chain energy balances, the sector generally lacks the prescriptive guidance and regulatory interventions needed to curb overproduction and scale low-GHG fibres.
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Document type: Report