Carbon Market Watch welcomes the opportunity to provide feedback on Verra’s proposal. We echo Verra’s recognition that there is a need to differentiate between credits which do or do not meet all the requirements set (or to be set) under the Paris Agreement’s article 6 rules. However, we express concern that Verra’s proposed “labelling” approach will not be sufficient to ensure environmental integrity. We note that transparently providing the information is not sufficient given the technical nature of the issue. Many buyers of carbon credits have a very limited understanding of the technical specificities of the offsets they purchase. It is likely that only a few buyers, most likely those with the most resources who can invest in order to research the quality of the offsets they purchase, will be able to clearly understand the implications of Verra’s proposed labels. As the largest voluntary market standard by issuance volume, Verra has a responsibility to not offer products that could mislead buyers. Our recommendation is that Verra does not offer the possibility for buyers to acquire carbon offsets for “neutrality” claims if these offsets have not been subject to corresponding adjustments. […]

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