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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
International aviation: Will the EU restart the clock?
The report examines four scenarios for extending the EU ETS aviation scope beyond intra-EEA flights, potentially increasing revenues up to 1,160 billion € by 2040. It argues that including non-CO2 effects and private jets would significantly boost funding for sustainable aviation fuels (SAF), rail infrastructure (TEN-T), and international climate finance (NCQG).
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Document type: Report
A G20 pathway towards oil and gas phase-out
The policy brief examines the barriers to phasing out oil and gas within G20 nations, noting that while renewable capacity has grown, fossil fuel subsidies and deep industrial integration persist. It advocates for measurable phase-out targets, subsidy reform, and increased concessional financing for the Global South to ensure a just energy transition.
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Document type: Policy brief
Guidance on Border Carbon Adjustment
This report presents guidelines for designing Border Carbon Adjustment (BCA) mechanisms, based on global stakeholder dialogues. It offers specific recommendations on measuring embodied GHG emissions, determining sectoral coverage, managing revenues, and crediting foreign carbon prices. The guidance emphasizes 'parallel treatment' between domestic and foreign producers and suggests mechanisms to support small and medium-sized enterprises (SMEs) and developing countries in their low-carbon transition, while cautioning against blanket country exemptions to maintain the effectiveness of leakage prevention.
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Document type: Report
Hoja de ruta para negociar los protocolos de la Convención Marco de las Naciones Unidas sobre Cooperación Internacional en Cuestiones de Tributación
The document outlines a strategic framework for negotiating protocols under the UN Framework Convention on International Tax Cooperation (UN FCITC). It identifies two 'early protocols'—cross-border services and tax dispute resolution—and several 'possible protocols' including the digital economy, illicit financial flows, high-net-worth individuals, and environmental challenges. The report argues that the UN FCITC can provide a more inclusive and effective alternative to OECD-led frameworks, particularly for developing countries, by establishing global standards for taxing the digital economy, combating tax evasion, and coordinating climate-related fiscal policies.
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Document type: Report
A Roadmap for Negotiating the Protocols to the United Nations Framework Convention on Tax
The report outlines a strategic framework for negotiating protocols under the UN Framework Convention on International Tax Cooperation (UN FCITC). It identifies two 'early protocols'—taxation of cross-border services and the resolution of tax disputes—and several 'potential protocols' covering the digital economy, illicit financial flows, high-net-worth individuals, environmental taxation, information exchange, mutual assistance, and harmful tax practices. The document argues that the UN FCITC can provide a more inclusive and effective alternative to OECD-led initiatives, which often disadvantage developing nations. Key recommendations include establishing a global digital services tax, creating a global asset register for beneficial ownership, implementing a global minimum tax on the super-rich, and developing a coordinated multilateral environmental tax architecture to support net-zero goals.
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Document type: Report
Feuille de route pour la négociation des protocoles à la Convention-cadre des Nations Unies sur la coopération internationale en matière fiscale
The report outlines a strategic framework for negotiating protocols under the UN Framework Convention on International Tax Cooperation, focusing on enhancing tax revenue and fairness for developing countries. It details two preliminary protocols—cross-border services and tax dispute resolution—and several potential protocols covering the digital economy, illicit financial flows, high-net-worth individuals, environmental taxation, information exchange, mutual administrative assistance, and harmful tax practices. The document argues for a shift away from OECD-led standards, which it claims often disadvantage developing nations, toward a more inclusive UN-led multilateral architecture.
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Document type: Report
Global Solidarity Levies: A Call for Country Participation
The document argues that current development and climate finance is insufficient to meet the Sustainable Development Goals (SDGs) and the Paris Agreement, noting a $4 trillion annual investment gap for SDG implementation in developing countries. It promotes the work of the Global Solidarity Levy Task Force (GSLTF), which has proposed 16 levy options targeting undertaxed sectors responsible for carbon emissions, including aviation, fossil fuels, and financial transactions. The GSLTF estimates that these levies could potentially generate over $500 billion in annual revenue, with specific examples such as a 0.1% levy on trading stocks and bonds potentially raising $418 billion. The brief calls for developing countries to engage in the design and assessment of these levies to ensure equitable access to funds, as the recovery of these taxes generally occurs through individual national tax systems, leaving the allocation of grants to developing countries to the discretion of developed nations.
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Document type: Policy brief
Carbon Competitiveness: South Africa at the Net Zero–Trade Nexus
South Africa faces significant trade risks as its carbon-intensive export model clashes with global net zero targets and Carbon Border Adjustment Mechanisms (CBAMs). Approximately 78% of its exports are sold to countries with net zero targets, and hundreds of thousands of jobs are exposed to CBAMs in the EU and UK. High embodied CO2 emissions in the basic metals and automotive sectors, combined with a carbon-intensive electricity grid, threaten competitiveness. However, the document notes South Africa's potential to pivot using its critical minerals and renewable energy resources, provided that international financial commitments like the Just Energy Transition Partnership (JETP) are fulfilled.
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Document type: Briefing
Décarbonisation du secteur minier
The report argues that while Canada has a competitive advantage due to its clean electricity grids, the mining sector's emissions are rising as mines deepen and ore grades decline. It identifies three primary barriers to decarbonization: a lack of market demand for 'green' minerals, fragmented traceability infrastructure, and technological gaps in open-pit mining. The author proposes a policy toolkit including emission-intensity criteria for funding, support for R&D in emerging technologies like direct lithium extraction, and the maintenance of carbon pricing systems to incentivize the transition.
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Document type: Report
Enhancing Sustainable Finance Governance: The Role of the Sustainable Finance Committee in Policy Harmonisation and Cross-Institutional Coherence
The document outlines the operationalization of Indonesia's Sustainable Finance Committee (SFC) under Law No. 4/2023. It proposes a three-tier governance structure involving the Ministry of Finance, Bank Indonesia, and the Financial Services Authority (OJK) to bridge institutional silos and align national climate targets with financial market mechanisms. The paper emphasizes the need for a formal Government Regulation to ensure the SFC's authority, the creation of a centralized data platform for ESG transparency, and the use of sectoral coalitions to co-create bankable financial solutions for priority sectors like energy and transport.
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Document type: Research paper
Fit for 2040
The document argues that the EU ETS1 is fit for purpose until 2035, after which a supply-demand mismatch for allowances may emerge. It strongly warns that integrating international carbon credits (Article 6) or carbon removals into the ETS would undermine the carbon price incentive, risk emissions mitigation avoidance, and divert investment away from domestic decarbonisation. For the upcoming ETS2, the brief recommends allowing the market to function for several years before making adjustments due to high price uncertainty. It also cautions against merging ETS1 and ETS2 due to differences in market actor price sensitivity and suggests maintaining national targets beyond 2030 to support the ETS.
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Document type: Policy brief
OVERCOMING ALL BARRIERS TO INDUSTRIAL ELECTRIFICATION
The report argues that direct electrification is the most efficient way to decarbonize industrial process heat, outperforming alternatives like green hydrogen, bioenergy, and carbon capture. It identifies three primary barriers: economics (high electricity costs relative to fossil fuels), grid readiness (slow interconnection and outdated planning), and technology maturity (lack of awareness and scale for high-temperature solutions). To overcome these, the authors recommend a combination of financial incentives (such as a Clean Heat Production Tax Credit), grid reforms (including surplus interconnection and real-time pricing), and foundational RD&D and workforce training.
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Document type: Report
Global Solidarity Levies: A Call for Country Participation
The document outlines the work of the Global Solidarity Levy Task Force (GSLTF) in developing 16 tax options targeting undertaxed, high-emission sectors to bridge the trillion-dollar financing gap for Sustainable Development Goals (SDGs) and the Paris Agreement. It highlights the potential for these levies to generate over $500 billion in annual revenue and calls for developing countries to engage in the design and assessment of these mechanisms to ensure equitable access to funds. The brief details the GSLTF's efforts to build political momentum through international forums and its submission to the Baku to Belém Roadmap to support the New Collective Quantified Goal on Climate Finance.
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Document type: Policy brief
Le Canada doit aller au-delà des États-Unis pour éviter de prendre du retard
The document warns that Canada faces significant economic risks if it follows the United States' lead in rolling back climate policies, as the rest of the world continues to transition toward clean energy. It highlights the rapid growth of electric vehicles globally, the expansion of carbon markets in China and India, and the implementation of carbon tariffs in the EU and UK. To maintain competitiveness and diversify exports, the author urges the Canadian federal government to strengthen industrial carbon pricing, finalize methane regulations for oil and gas, complete clean electricity investment tax credits, and publish a domestic climate taxonomy.
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Document type: Statement
Canada needs to look beyond the U.S. global energy transition
The author contends that while the U.S. has retreated from climate policy, global momentum toward a low-carbon economy continues, posing a risk to Canada's oil-dependent economy if it does not keep pace. The text highlights the rapid growth of electric vehicles in China, the expansion of carbon markets in China and India, and the implementation of carbon tariffs in the EU and UK. It recommends that the Canadian federal government prioritize industrial carbon pricing, methane regulations, and a national climate taxonomy to ensure competitiveness in non-U.S. markets.
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Document type: Statement
Modernisation Fund - First evaluation of the monitoring rules
Carbon Market Watch criticizes the EU Modernisation Fund for continuing to finance fossil gas, waste incineration, and biomass projects, noting that at least EUR 4.2 billion (27% of spending) has gone to investments not aligned with the fund's aims. The organization calls for more ambitious emissions avoidance benchmarks and a shift in funding toward grid improvements, renewables, building renovation, and public transport electrification to support lower-income member states ahead of the 2027 ETS2 implementation.
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Document type: Statement
Who’s winning the green investment race in Southeast Asia?
The document analyzes the competitive landscape of green investment in Southeast Asia, highlighting China as the leading public investor in clean energy between 2013 and 2023. It details the specific technological strengths of investor nations—such as Japan's lead in geothermal and solar and China's dominance in wind and hydropower—while examining the strategic frameworks used, including China's Belt and Road Initiative and Japan's Asia Zero Emissions Community. The report also notes significant financing gaps in the region, where annual renewable investments of USD 8 billion fell far short of the USD 27 billion required to meet 2025 targets.
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Document type: Briefing
Watering down already weak IMO compromise will sink shipping’s climate ambition
The IMO's new Net-Zero Framework is criticized as a 'defeat for the climate' because it replaces a universal carbon levy with a hybrid fuel standard and weak carbon pricing. The author contends that the scheme will only reduce emissions by about 10% by 2030—half of the IMO's own base target—and will generate insufficient revenue ($11-12 billion annually) to support the transition to zero-emission fuels, which requires $12-24 billion per year.
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Document type: Statement
Improving Green Competitiveness for Inclusive Transformation
The document argues that traditional nationalistic industrial models must shift toward collaborative frameworks to avoid excluding developing nations from green value chains. It suggests strategies such as disaggregating energy-intensive production to regions with abundant renewables, moving from 'technology transfer' to 'sharing of know-how', and utilizing industrial clusters to reduce costs and aggregate demand. The paper emphasizes the role of Multilateral Development Banks (MDBs) in providing concessional capital and the potential for 'climate-smart' public-private partnerships, including philanthropic funding, to bridge financial gaps. It highlights the importance of regional trade frameworks and the need to recycle revenues from carbon border measures back into developing economies to catalyze green industrialisation.
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Document type: Briefing