The Commission’s “Have your say” consultation on the 2040 target indicates that the EU is likely to apply additional qualitative filters to international credits beyond the standards currently being developed under Article 6.4. The questionnaire raises issues across environmental integrity, regulatory design, governance, and financing, suggesting a preference for a limited and carefully curated volume of eligible units. Emerging signals point toward an EU-defined eligibility framework that may prioritise permanence, reversal risk management, and “credible and transformative” mitigation activities, potentially favouring durable removals and systemic decarbonisation projects over conventional offset types. The consultation also hints at interest in more centralised procurement structures, potentially via cooperative approaches under Article 6.2, which could align credit use with broader EU geopolitical and industrial partnerships.
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