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The document clarifies the distinctions between Article 6.2 and 6.4 mechanisms, the role of 'corresponding adjustments' in preventing double counting, and the transition of the Kyoto Protocol's Clean Development Mechanism (CDM) into the new framework. It highlights risks such as the potential for 2.8 billion 'dud' credits from transitioning CDM projects and the lack of mandatory cancellation for ITMOs under Article 6.2.

A coalition of environmental organizations warns the European Commission that the Sustainable Carbon Cycles Communication risks undermining climate ambition if it allows carbon removals to be used as offsets for emissions. While supporting the Carbon Removal Certification Mechanism and improved climate accounting by 2028, the authors argue that removals should not be treated as tonne-for-tonne equivalents to emissions reductions. They specifically oppose the inclusion of removal offsets in the EU ETS, ESR, and LULUCF regulations, and call for a strict definition of storage permanence to distinguish real removals from short-term carbon stores.

The report establishes four core principles for verifying 'real' carbon dioxide removals: sourcing carbon from the atmosphere, ensuring permanent storage (at least 200-300 years), conducting comprehensive life cycle assessments of all associated emissions, and ensuring net-negative results. It argues against the 'false equivalency' that one tonne emitted equals one tonne removed, noting that removals may only undo up to 90% of an emission's impact and cannot reverse certain climate damages like sea-level rise. The author emphasizes that CDR should supplement, not replace, deep decarbonization to prevent 'mitigation deterrence,' where the promise of future removals slows current emission cuts.

The author contends that the proposed ETS2 for buildings and road transport risks exacerbating energy poverty and failing to drive decarbonization unless it is accompanied by complementary policies to remove renovation barriers and a reform of the current ETS to eliminate free allowances for heavy industry.

Carbon Market Watch criticises the IMO's slow progress on shipping emissions and the insufficiency of its 2030 energy efficiency targets. It highlights a growing coalition of countries and companies calling for zero emissions by 2050 and advocates for a strong market-based measure, specifically a carbon levy, to bridge the price gap between fossil and sustainable fuels and support climate justice.

Carbon Market Watch argues that while the CBAM proposal has positive elements, such as basing certificates on verified emissions and avoiding export rebates, it requires significant revisions. Key recommendations include removing the overlap between CBAM and free emission allowances, including bulk chemicals and indirect emissions from the start, providing special considerations for least developed nations and small islands, and recycling revenues toward international climate finance rather than the Next Generation EU facility.

Carbon Market Watch argues that the European Commission's EU ETS revision proposal is inadequate, specifically citing an insufficient emission reduction target and a failure to implement the polluter pays principle through the continued use of free emission allowances. The organization proposes increasing the 2030 emission reduction target to 65% or 70%, reforming the Market Stability Reserve, phasing out free allocations, and expanding the scope of the ETS to include municipal solid waste incineration and full shipping emissions.

Carbon Market Watch advocates for a dual approach to carbon market activism, combining the exposure of 'brazen greenwashing'—such as 'carbon-neutral fossil fuels'—with active participation in governance bodies like the TSVCM and VCMI to ensure human rights and accounting integrity.

Carbon Market Watch argues that the European Commission's proposal to update the EU ETS is insufficient, specifically citing an inadequate emission reduction target and the failure to implement the polluter pays principle through continued free allowances. The organization advocates for a 70% emission reduction target by 2030, a more aggressive Market Stability Reserve (MSR) intake rate of 36%, and the immediate phase-out of free emission allowances. Further recommendations include expanding the ETS to cover all international shipping voyages and waste incineration, excluding Carbon Capture and Utilization (CCU) due to potential loopholes, and deleting Article 26 of the ETS Directive to allow binding greenhouse gas limits in industrial permits.

The author contends that outdated Kyoto-era carbon credits lack environmental integrity and that reviving the Clean Development Mechanism (CDM) would not benefit the climate. The text highlights the lack of legal basis for continuing the CDM after 2020 and notes the significant uncertainty regarding the volume of existing credits, with estimates ranging from 300 million to over 4 billion CERs.

The document outlines five primary concerns regarding Article 6 of the Paris Agreement: the lack of buyer demand compared to sellers, the prevalence of unregulated private sector greenwashing, the oversupply of low-quality credits, the struggle to find high-integrity removal credits, and the risk of legacy credits from the Clean Development Mechanism (CDM) undermining new climate targets.

Carbon Market Watch contends that the EU's 'Fit for 55' package lacks the urgency required for the climate crisis. The authors argue for increasing the 2030 emissions reduction target to 65% and advancing the carbon neutrality goal to 2040. While welcoming the inclusion of shipping in the Emissions Trading System (ETS) and the proposed Carbon Border Adjustment Mechanism (CBAM), the document criticises the continued use of free allowances and the lack of exemptions for low-income countries within the CBAM framework.

Carbon Market Watch analyzed 18 "carbon neutral" fossil fuel claims, primarily involving liquefied natural gas (LNG), and found that every claim failed to meet basic criteria for environmental integrity and transparency. The report argues that fossil fuels cannot be carbon neutral because the firms involved are not aligned with 1.5°C pathways and rely on flawed "tonne-for-tonne" offsetting. Key failures include the omission of Scope 3 emissions in one-third of claims, a total lack of transparency regarding the price paid for carbon credits, and the use of impermanent nature-based sinks to offset long-term fossil carbon emissions. The report recommends that fossil fuel firms cease these claims, stop new exploration, and shift toward a "contribution" model for climate finance.

The author contends that the European Commission's proposal to exempt CCU from the EU carbon market is flawed because it defines 'permanent storage' too narrowly, ignoring the end-of-life release of carbon from products like plastics and the emissions generated during the CCU production process.

Carbon Market Watch criticises a proposal by fifteen Members of the European Parliament to incentivise CCS and CCU within the EU carbon market. The organisation distinguishes between carbon removals, which physically remove greenhouse gases from the atmosphere, and CCS/CCU, which typically only capture emissions from industrial sources. It warns that promoting CCS/CCU could lead to greenwashing, stranded assets, and delayed emissions, particularly in the power sector. The document specifically highlights the risks of BECCS and waste-to-energy CCS, citing deforestation linked to the Drax power plant. It concludes that the EU carbon market must focus on reducing emissions at the source and that public funding should only support mature, transparently assessed carbon removal technologies.

The submission by CSC to the IMO's 77th session argues for a robust carbon pricing mechanism for international shipping that avoids offsets and exemptions. It proposes a high carbon price—potentially $400/tonne or more in this decade—to bridge the gap between fossil and zero-carbon fuels and drive rapid decarbonization. The document emphasizes that revenues should be used for climate rebates to vulnerable nations, such as low-income small island developing States (SIDS), and for investing in zero-emission infrastructure. It further asserts that global IMO measures must not undermine more ambitious regional regulations, such as the EU's plan to include shipping in the EU ETS.

Carbon Market Watch argues that environmental integrity under Article 6 requires the mandatory application of corresponding adjustments to all mitigation activities to prevent double counting. The briefing strongly opposes the carry-over of pre-2020 Kyoto Protocol units, asserting they would flood the market with up to 4 billion "junk credits" and increase global emissions. Additionally, it advocates for a share of proceeds (SOP) for adaptation that combines monetary and in-kind contributions, recommending that this levy apply to both Article 6.2 and 6.4 mechanisms to ensure stable finance for developing countries.

Carbon Market Watch asserts that Article 6 of the Paris Agreement must move beyond zero-sum offsetting to achieve an overall mitigation in global emissions (OMGE). The author critiques two proposed options—relying on market forces and using conservative baselines—as insufficient. Instead, the document advocates for the automatic partial cancellation of credits, arguing that this mechanism ensures net atmospheric benefits and can increase carbon market prices and project owner profits.

Carbon Market Watch critiques the TSVCM's objective of scaling the voluntary carbon market (VCM), arguing that growth should not be the primary goal and that financial speculation through secondary markets and futures contracts does not benefit the climate. The organization emphasizes the need for a truly independent governance body, free from industry associations and conflicts of interest, and calls for more rigorous Core Carbon Principles (CCPs). Key recommendations include excluding ex-ante and retroactive crediting, requiring a minimum permanence timeframe of at least 100 years, and ensuring that credits used for offsetting include corresponding adjustments to national reporting to avoid double claiming.

Carbon Market Watch argues against the transition of CDM credits to the Paris Agreement era, warning that up to 4 billion "hot air" credits could flood the market. The organization advocates for a clean break from the Kyoto Protocol, requiring all CDM projects to be reassessed against strict quality criteria. To enable climate ambition under Article 6, the submission proposes the use of conservative baselines, an automatic partial cancellation rate of credits to ensure overall global emission reductions, and the restriction of carbon markets to the disbursement of results-based climate finance rather than zero-sum offsetting.