The Government of Guyana is concerned by the contents of a restricted European Commission concept note on CORSIA unit eligibility that has not been subject to public consultation. The paper proposes a material narrowing of carbon market eligibility rules after those markets have already been established and are operational under the CORSIA framework agreed through the United Nations International Civil Aviation Organization (ICAO). It proposes de facto retrospective effects on existing supply, including for ART-TREES HFLD jurisdictional carbon credits.
Even at an early stage, proposals of this nature set clear policy direction and market expectations, making it essential that they are informed by open and inclusive engagement from the outset.
However, in this case, the European Commission paper appears to have been developed without input from those with direct expertise in HFLD crediting, including the only host country that has operationalised such jurisdictional supply at scale.
The apparent attempt to exclude HFLD approaches on the basis that they credit the “mere existence” of carbon stocks reflects a fundamental misunderstanding of how these systems operate. In reality, HFLD crediting uses reference levels based on highly conservative definitions of additionality. They are fully consistent with the UNFCCC REDD+ framework developed over nearly two decades, as well as with the rigorous due diligence and processes of the UN International Civil Aviation Organization (ICAO), and the peer-reviewed methodologies which underpin standards such as ART-TREES. Lack of recognition of these facts raises serious questions about the completeness of the analysis and due diligence undertaken.
It should not be necessary to say that proposals of this significance cannot credibly be advanced through closed processes. Restricted, non-public papers that are not grounded in peer-reviewed science, and that are not aligned with the UNFCCC framework for REDD+, risk undermining both the integrity and the stability of international carbon markets.
Signals that exclude credits based on assertions that are not supported by the full body of peer-reviewed evidence destabilise markets, reduce available supply, and undermine confidence in long-term climate ambition. The concept note itself acknowledges that the proposed criteria could eliminate most or all of the current CORSIA supply. That should be a cause for serious concern. Airlines and host countries have made real-world decisions based on the expectation of stable and predictable rules – this paper risks undermining that confidence.
This concept note is not harmless. The markets that it seeks to restrict are operational today, so the implications – both to climate ambition and the welfare of people – are immediate and material. Jurisdictional forest crediting is one of the very few mechanisms delivering finance at scale to Indigenous Peoples and local communities, and supporting national investment in low-deforestation development.
There is also a broader issue of precedent. If major market jurisdictions begin to apply unilateral filters that are not anchored in the UNFCCC framework, not based on peer-reviewed evidence, and not developed through transparent consultation, this risks fragmenting markets and weakening the very system of international cooperation that Article 6 was designed to support. In addition, narrowing the scope of credits recognised within the UN ICAO framework sets a damaging precedent for the rules-based approach to climate and international cooperation.
If pursued, this would be a step backwards for global climate action just as real progress is starting to be made.
Guyana remains committed to high-integrity carbon markets and to continuous improvement of standards. We urge others to align with these goals by following processes which embed integrity through evidence, agreed international processes, and engagement with those creating the supply of credits. Integrity cannot be achieved through restricted, non-public papers that exclude key stakeholders, ignore peer-reviewed science, and mischaracterise established approaches.
We therefore urge that this paper be withdrawn immediately, and that a more credible, science-based, and transparent process be pursued instead – one that is aligned with the UNFCCC framework and informed by those with direct experience in delivering forest climate solutions. This needs to be done urgently, and before the European Commission releases any draft regulations.
If this is done, the Government of Guyana stands ready to contribute to a greater understanding of these solutions, with the ultimate objective of ensuring that high-integrity carbon markets can accelerate climate action in the interests of the whole world.
