- The European Commission has opened a four-week consultation following the publication of a draft implementing regulation for CBAM on 13 May 2026.
- The draft rules explain how the payment of third-country carbon prices can reduce CBAM
Carbon Offsets
EU ETS: European Commission Announces Additional Flexibilities, Including Updated Benchmarks
The package of measures recognises the need to promote energy security and combat rising costs.
By Michael D. Green and James Bee
Key Points:
- The Commission has outlined areas of ETS reform, including updated benchmarks for free allocations and a new €30 billion ETS Investment Booster.
- A medium-term ETS review is expected by July 2026 with the intention to “modernise” the system.
On 11 May 2026, the European Commission (Commission) presented updated EU Emissions Trading System (EU ETS) benchmarks for…
Singapore Signs Further Implementation Agreements and Announces Nature-Based Carbon Credit Projects
Singapore continues to expand its list of approved host countries, carbon crediting programs, and methodologies that meet the established criteria.
By Paul A. Davies, Michael D. Green, Farhana Sharmeen, James Bee, Kevin Mak, and Qingyi Pan
On September 16, 2025, Singapore signed an implementation agreement on carbon credits in cooperation with Vietnam, expanding the total number of executed implementation agreements to nine. The Ministry of Trade and Industry (MTI) announced: “Singapore is committed to channelling…
China Expands Its National Carbon Emission Trading Scheme to More Industries
The scheme’s expansion to include the steel, cement, and aluminum smelting industries increases the program’s coverage to 60% of China’s total greenhouse gas emissions.
By Paul A. Davies, JP Brisson, Michael Green, and Qingyi Pan
On March 26, 2025, China’s Ministry of Ecology and Environment (the MEE) published the “Work Plan for the National Carbon Emissions Trading Market Covering the Steel, Cement, and Aluminum Smelting Industries” (the Work Plan).1 The Work Plan expands the scope of…
Denmark to Allow Stacking of Voluntary Carbon Credits and Nationally Determined Contribution
Denmark’s unprecedented carbon removals fund has facilitated the coexistence of corporate and national carbon claims in carbon accounting.
By Jean-Philippe Brisson, Paul A. Davies, Lars Kjølbye, John-Patrick Sweny, and Qingyi Pan
In the past few years, stakeholders in the carbon market have debated how to integrate the voluntary carbon market (VCM) and the emerging international carbon market governed by the Paris Agreement — Denmark’s recent move to allow stacking of voluntary carbon credits and nationally determined…
China Releases Carbon Allowance Trading Regulations
The regulations aim to provide a legal framework for China’s carbon allowance trading market by strengthening requirements and designating responsibilities.
By Hui Xu, Paul A. Davies, Jean-Philippe Brisson, and Qingyi Pan
On January 25, 2024, Chinese Premier Li Qiang signed a decree of the State Council, introducing the Regulations on the Administration of Carbon Allowance Trading (the Regulations). Effective from May 1, 2024, the Regulations provide a legal framework for the operation of China’s emissions trading scheme…
Singapore Publishes Eligibility List Under the International Carbon Credit Framework
The Eligibility List sets out the approved host countries, carbon crediting programmes, and methodologies that meet the established Eligibility Criteria in Singapore.
By Paul A. Davies, Jean-Philippe Brisson, Farhana Sharmeen, Don Stokes, Michael D. Green, Qingyi Pan, James Bee, and Kevin Mak
On 19 December 2023, the Ministry of Sustainability and the Environment (MSE) and the National Environment Agency (NEA) in Singapore published the Eligibility List under Singapore’s International Carbon Credit (ICC) Framework, which took effect from 1 January 2024 and was published on Singapore’s Carbon Markets Cooperation website.
The Eligibility List followed the signing of an inaugural Article 6 implementation agreement with Papua New Guinea on carbon credits cooperation.
Under Article 6 of the Paris Agreement, countries may enter into an implementation agreement to cooperate to achieve their nationally determined contributions (NDCs) by trading Paris Agreement compliant carbon credits. Parties to the implementation agreement must also effect certain corresponding adjustment mechanisms to ensure that any emission reductions or removals are struck from the host country’s NDC accounts to prevent double-counting.
UK Government Announces New Import Carbon Pricing Mechanism
Goods imported into the UK from countries with a lower or no carbon price will face a levy by 2027.
By Paul A. Davies, Michael D. Green, and James Bee
On 18 December 2023, the UK government announced a proposal for a new carbon border adjustment mechanism (UK CBAM). The announcement follows extensive consultation earlier this year on possible measures to mitigate carbon leakage risks and aims to support the UK’s decarbonisation efforts.
The UK has made a number of decarbonisation commitments including reaching net zero by 2050. These commitments to decarbonise can be undermined by “carbon leakage”, in which production of goods and associated emissions move from a jurisdiction with more ambitious climate policies (which add costs to carbon-intensive processes) to another jurisdiction with less ambitious policies, resulting in an overall negative impact on the carbon intensity of the processes/goods themselves. The UK CBAM (or other form of carbon tax) seeks to address this issue by aiming to put a fair price on the carbon emitted during the production of certain carbon-intensive goods entering the UK.
China Plans to Relaunch Its Carbon Credits Program
The draft New Measure aims to enhance the environmental integrity of China’s carbon market by introducing new requirements for project registration and credit issuance.
By Paul A. Davies, Jean-Philippe Brisson, Michael Dreibelbis, and Qingyi Pan

China is preparing to relaunch its carbon credits program, the Chinese Certified Emission Reduction (CCER) Scheme, after suspending the program for over six years. On July 7, 2023, the Ministry of Ecology and Environment (MEE) and the State Administration for Market Regulation (SAMR) of the People’s Republic of China jointly released the draft Measure for the Administration of Voluntary Emission Reduction Trading (the New Measure).
The public consultation for the draft New Measure ended on August 6, 2023, and on September 15, 2023, the MEE ministry conference reviewed and passed the New Measure in principle. The formal release is expected to happen in October 2023, upon which the New Measure would replace the previous set of rules and become the governing law of the CCER Scheme.
Together with the national emission trading scheme (the China ETS) launched two years ago, the CCER Scheme represents China’s continuous efforts towards adopting market-based mechanisms for achieving its climate pledges (peaking emissions before 2030 and reaching carbon neutrality before 2060).[i]
European Parliament and European Council Reach Provisional Agreement on Carbon Border Adjustment Mechanism
By Paul A. Davies, Michael D. Green, and James Bee
The CBAM would seek to mitigate carbon leakage through the imposition of a levy on carbon-intensive imports into the EU, while free allowances under EU ETS would be phased out.

On 13 December 2022, negotiators from the European Parliament and European Council reached a provisional and conditional agreement on the terms of the EU’s carbon border adjustment mechanism (CBAM).
The CBAM was initially proposed by the European Commission in July 2021 as part of its “Fit for 55” package of policies. The measure seeks to address and mitigate the risk of “carbon leakage” from the EU, which refers to the risk that the EU’s greenhouse gas reduction efforts will be offset by increasing emissions outside of its border through the relocation of production to non-EU countries with less ambitious emissions reduction policies.
The CBAM would impose a levy on in-scope goods that are imported into the EU. Importers of such goods would be required to pay an amount equal to the cost of the emissions allowances under the EU Emissions Trading System (ETS) that would have been necessary to pay to produce that good in the EU.