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Comments on the process of determining whether to pursue linkage of Washington’s carbon market with California and Quebec’s linked market
The Stockholm Environment Institute argues that full linkage between Washington's carbon market and the California-Quebec (WCI) market currently poses risks to Washington's environmental goals due to misaligned time horizons and differing levels of ambition. Specifically, the authors highlight a large bank of unused allowances in California that could reduce in-state emission reductions and auction revenues in Washington. They recommend that full linkage be contingent on California extending its program beyond 2030 and tightening its 2030 cap. As an interim measure, the authors propose 'restricted linkage'—such as a limit on the import of WCI allowances (e.g., 2-3% of compliance obligations)—to provide cost containment while maintaining environmental integrity and revenue streams for overburdened communities.
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Document type: Statement
CMW input for South Pole consultation on corporate claims for Funding Climate Action
Carbon Market Watch (CMW) responds to a South Pole consultation on a new corporate claim, "Funding Climate Action - with Verified Climate Contributions." CMW supports moving away from "carbon neutral" claims but criticizes the continued use of a "tonne-for-tonne" approach, which it argues incentivizes low-quality, cheap credits. CMW proposes a "dollar for tonne" model and demands full financial transparency regarding the flow of funds from buyers to projects. The response also outlines six fundamental criteria for firms, including the requirement to demonstrate that emissions are truly "unabatable" and to account for all scope 1, 2, and 3 emissions before utilizing carbon credits.
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Document type: Statement
UK military GHG emissions and the Greening Government Commitments
The paper argues that the MOD is on track to meet its 2025 GGC targets primarily because they are 'weak and undemanding' and benefit from the general decarbonisation of the UK national electricity grid. It highlights that GGCs only cover estate emissions, excluding two-thirds of the MOD's total emissions from military 'capability' such as warships and aircraft. The author recommends significantly higher targets for 2030, including a 90% reduction in overall estate emissions and the inclusion of Service Family Accommodation (SFA) in future targets.
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Document type: Research paper
Una Guía Para Informar Sobre las Soluciones
The document argues that climate coverage must expand beyond problem-focused reporting to include solutions to empower audiences and policymakers. It defines solutions journalism as rigorous, evidence-based reporting that investigates the effectiveness and limitations of responses to the climate crisis. The guide emphasizes equity and justice, noting that marginalized communities—including indigenous peoples, who manage lands containing "approximately the 80% of the biodiversity that remains in the world"—are often the most impacted yet least responsible for the crisis. It categorizes potential story leads into five areas: policy and government (e.g., carbon pricing and subsidies), economy and business (e.g., scrutinizing "greenwash" and "net zero" claims), technologies and practices (distinguishing between mitigation and adaptation), civil society (evaluating the "theory of change" behind activism), and culture (the role of arts and celebrities). The guide concludes that while not all reporting should be solutions-oriented, integrating this mindset is essential to providing a complete picture of the climate emergency.
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Document type: Guide
Climate Solutions Reporting Guide
The guide argues that climate coverage must move beyond focusing solely on the problem to show that the crisis is solvable, emphasizing evidence-based solutions journalism. It outlines a framework for reporting on government policies, business practices, technological mitigation and adaptation, civil society actions, and cultural influences. The document warns reporters to prioritize the political and economic battles over 'techno-fixes' and to highlight the urgency for marginalized communities who suffer disproportionately from climate impacts.
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Document type: Guide
CMW inputs to A6.4SB structured consultation on methodological requirements_06.04.23
Carbon Market Watch argues that Article 6.4 methodologies must shift from incremental benefits to transformational activities to avoid eroding climate ambition. The organization advocates for the use of dynamic baseline contraction factors (BCFs) that trend toward zero by 2050, the implementation of 'negative lists' to exclude non-additional or fossil-fuel-linked projects, and the rejection of short-term sequestration activities as offsets due to non-permanence risks.
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Document type: Statement
Net-zero integrity Nestlé’s methane blindspot
The report finds that Nestlé's net-zero plan fails to meet any of the nine relevant UN Integrity Matters recommendations. It highlights a critical 'methane blindspot,' where the company avoids setting specific methane targets despite dairy and livestock being its largest emission sources. The analysis argues that Nestlé uses 'creative accounting' via business-as-usual scenarios to mask minimal absolute emission reductions and relies on unverified regenerative agriculture and insetting to meet goals. Furthermore, the report identifies greenwashing in the carbon-neutral claims of flagship brands like Nespresso and KitKat, which rely heavily on unreliable offsets.
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Document type: Report
Greenwashing and how to avoid it
The document defines greenwashing in the financial sector as false or misleading representations of environmental impact and warns that it can misallocate capital and undermine the Paris Agreement. It outlines five categories of evolving regulation—disclosure, labelling, ratings, taxonomies, and net zero integrity—and classifies enforcement actions into brand, product, financing, and reporting greenwashing. To mitigate risk, the guide proposes 'five pillars' of guarding against greenwashing: screening claims, ensuring transparency, aligning internal actions with public image, monitoring regulatory changes, and adhering to fiduciary duties.
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Document type: Guide
ASSESSING THE CARBON NEUTRALITY CLAIMS OF PRODUCTS IN BELGIAN SUPERMARKETS
The report finds that all 15 assessed products in Belgian supermarkets make misleading carbon neutrality claims because they rely on carbon credits that do not provide climate benefits equivalent to the emissions generated. The analysis highlights systemic issues with carbon offsets, including a lack of additionality in renewable energy projects and a lack of permanence in forest-based sinks. Furthermore, the report notes a lack of transparency in company-level climate strategies and a conflict of interest within the third-party certification industry.
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Document type: Report
PUBLIC CONSULTATION INPUT
Carbon Market Watch urges Verra to move away from the 'tonne-for-tonne' offsetting model, particularly for AFOLU projects, due to permanence risks and the potential for corporate greenwashing. The submission recommends adopting a 'contribution model' where finance supports climate action without claiming neutrality. It also calls for greater financial transparency regarding intermediaries, a more accessible and independent grievance mechanism for indigenous peoples and local communities, and the banning of methodologies that support fossil fuel infrastructure.
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Document type: Statement
ANNUAL GENERAL MEETINGS 2023: Voting recommendations for climate-conscious investors
The briefing provides a framework for climate-conscious investors to use their voting rights at 2023 AGMs to hold companies accountable for their climate strategies. It recommends voting against the re-election of directors, executive remuneration, and financial statements if companies fail to disclose comprehensive 1.5°C-aligned strategies or continue fossil fuel expansion. The document specifically analyzes the inadequacies of 'Say on Climate' resolutions and provides case studies on companies like TotalEnergies, BP, and BNP Paribas, while offering a set of priority written questions for the energy, utility, and financial sectors.
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Document type: Briefing
CMW inputs on the grievance process in Article 6.4
Carbon Market Watch (CMW) argues that the Article 6.4 Supervisory Body must establish a robust, independent grievance mechanism before registering any carbon crediting projects to protect indigenous peoples and local communities. Drawing on a review by Perspectives Climate Research, CMW finds that most voluntary carbon market (VCM) standards—including Verra, American Carbon Registry, and Climate Action Reserve—have inadequate mechanisms, while the Global Carbon Council lacks one entirely. Only the Gold Standard and the Green Climate Fund's Independent Redress Mechanism are identified as high-quality models. CMW recommends that the Article 6.4 mechanism be fully independent, transparent, and accessible, featuring a public grievance repository and the power to overturn Supervisory Body decisions.
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Document type: Statement
CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments
Carbon Market Watch (CMW) urges the Article 6.4 Supervisory Body to avoid shortcuts in developing recommendations for removal activities, emphasizing that temporary carbon storage should not be equated with permanent emission reductions. CMW argues that current forestry and land-use credits lack permanence, and that buffer pools are insufficient to manage reversal risks. The organization specifically opposes the inclusion of tonne-year accounting, claiming it creates a false equivalence between temporary storage and permanent removals, and criticizes the proposed definition of removals for including 'products' and 'processes' rather than focusing solely on outcomes.
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Document type: Statement
Assessing the robustness of Carbon Market Grievance Mechanisms and recommendations for the establishment of an Article 6.4 Grievance Mechanism
The report evaluates grievance mechanisms across various carbon market standards and funds, using UN Guiding Principles on Business and Human Rights as a benchmark. It finds that most voluntary carbon market (VCM) standards have opaque or insufficient mechanisms, while the Green Climate Fund (GCF) and Gold Standard provide more robust models. The authors recommend that the Article 6.4 mechanism prioritize accessibility, transparency through public repositories, independence, and the ability to provide binding remedies, including the power to overturn Supervisory Body decisions.
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Document type: Report
Australia’s Senate Inquiry recognises “massive climate harm” of coal mine methane but fails to tackle it
The document critiques the findings of the Australian Senate Inquiry into the Safeguard Mechanism, noting that while the committee acknowledged the "massive climate harm" of coal mine methane, its final recommendations failed to provide a sufficient plan to tackle the issue. Ember proposes three specific improvements: implementing Level 5 Oil and Gas Methane Partnership 2.0 measurement standards, setting production-adjusted emissions intensity baselines (3 kg/tonne for coking coal and 1 kg/tonne for thermal coal), and limiting the use of offsets (ACCUs and SMCs) to prioritize onsite mitigation.
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Document type: Policy brief
Policy Update: Australia’s Senate Inquiry recognises the “massive climate harm” of Coal Mine Methane but fails to outline steps to tackle it
The document analyzes the Australian government's proposed reforms to the safeguard mechanism and the subsequent Senate Committee inquiry. While the Committee acknowledged the "massive climate harm" of coal mine methane, Ember argues the final recommendations missed a key opportunity to mandate rigorous measurement, reporting, and verification (MRV) standards or a separate emissions intensity baseline for methane. The brief highlights that current reporting may underestimate methane emissions by 63% and warns that unlimited access to carbon offsets (ACCUs) weakens incentives for onsite mitigation. It recommends implementing Level 5 Oil and Gas Methane Partnership 2.0 standards and setting specific methane baselines for coking and thermal coal mines.
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Document type: Policy brief
Consultation on the Future of Competition Policy in Canada
The document advocates for reforming the Competition Act to address greenwashing, which it describes as a market distortion that prevents consumers from making informed choices and hinders firms investing in environmental quality. The authors propose several amendments, including updating the Act's purpose clause to include environmental and climate considerations, establishing clear substantiation standards for environmental claims, and requiring public disclosure of the data used to support such claims. They also suggest introducing enhanced penalties for environmental harm, expanding private rights of action for consumers, and allocating penalties to the Environmental Damages Fund. The statement highlights that while other jurisdictions like the EU, France, and California have implemented mandatory disclosures or bans on generic claims, Canada lacks dedicated statutes for regulating environmental claims to the general public.
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Document type: Statement
Feeding Us Greenwash
The report identifies widespread greenwashing in the food sector, particularly among major meat and dairy producers. It highlights the use of misleading labels like 'carbon neutral' and 'net zero', the reliance on carbon offsetting over absolute emissions reductions, and the use of idyllic imagery to mask intensive farming practices. Polling in the UK and Germany shows that while consumers are concerned about greenwashing, they are still influenced by these claims in their purchasing decisions. The document calls for stricter government regulation of green claims and a systemic transformation of the food system to reduce greenhouse gas emissions.
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Document type: Report
BLOCKED AVENUES FOR REDRESS: SHEDDING LIGHT ON CARBON MARKET GRIEVANCE MECHANISMS
A review of voluntary carbon market standards found that most have inadequate or non-existent grievance mechanisms, leaving local and indigenous communities vulnerable. Only Gold Standard and the Green Climate Fund's Independent Redress Mechanism were rated as having good mechanisms. The report details failures in accessibility, transparency, and independence for standards like Verra, CAR, and ACR, and notes that the Global Carbon Council lacks a mechanism entirely. It provides a framework of good practices and specific recommendations for these standards and the Paris Agreement's Article 6.4 Supervisory Body.
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Document type: Policy brief
TPT Consultation Survey
ClientEarth argues that the TPT framework must move from permissive language to mandatory, science-aligned standards to correct a market failure where corporate net zero commitments lack credible transition plans. Key recommendations include requiring alignment with 1.5°C pathways, mandatory disclosure of all Scope 1-3 emissions, and a prohibition on counting carbon credits toward reduction targets. The document also advocates for stronger links between transition plans and financial statements, more rigorous reporting on corporate lobbying, and the integration of 'just transition' and nature-positive objectives.
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Document type: Statement