Call for Evidence: Legal Framework for the Possible Use of International Carbon Credits

Carbon Balance Initiative welcomes the opportunity to respond to the European Commission’s Call for Evidence informing an Impact Assessment on the possible use of high-quality international credits under Article 6 of the Paris Agreement.

The amended European Climate Law provides for the use of such credits from 2036 to account for up to 5% of the 2040 climate target – equivalent to 5% of 1990 net emissions – implying that at 85% of the required reductions must be achieved through domestic action.

We recognise that cost-efficiency is a legitimate objective in the design of this framework. This submission argues that genuine long-run cost-efficiency and environmental integrity are complementary rather than competing: a framework that procures low-quality credits risks both undermining the EU’s climate credibility and the market development benefits that high-integrity procurement can unlock at scale. Domestic decarbonisation remains the primary lever for EU competitiveness and industrial transition; international credits should aim to complement, not substitute for, that effort.

Read the full submission here

We offer concrete recommendations on how the EU can ensure environmental integrity in its procurement and use of international credits, while promoting its technological leadership and climate diplomacy ambitions. This submission addresses four areas:

• the use case for international credits;

• the types and quality criteria for credits under Article 6;

• financing considerations;

• partnership considerations.