Brazil Doubles 2031-2035 ITMO Ceiling as Argentina and Chile Advance Article 6 Frameworks

These are ceilings on what may be authorized, not transfers that have happened.
Brazil's new ITMO caps expand future scope but put no volume on the market today.
Mark

Brazil doubled a number. Why is that the headline?

Mimi

Because the 2031-2035 ceiling went from the July proposal to 100 million tonnes of CO2 equivalent. That signals more willingness to let mitigation outcomes be transferred abroad.

Luke

But it's a ceiling, not a sale. Nothing has been transferred or traded, and nothing is on the market today.

Mark

And July's version was more cautious?

Mimi

Yes, it was designed to make sure Brazil met its own NDC first. The committee changed that approach.

Luke

The reporting doesn't say why they doubled it, though. We know the change, not the reasoning.

Mark

What about Argentina?

Mimi

Its NDC says it wants to join Article 6 markets and keep sovereign control over the rules. It names no partners and no timeline.

Luke

And it lists activities like nuclear and no-till farming without saying any are Article 6 eligible. Don't read that as a project pipeline.

Mark

Chile seems furthest along.

Mimi

It has recognized three standards and moved 11 activities forward, plus approved programs under its Swiss and Japanese agreements.

Luke

Still, recognition isn't authorization, and a Letter of Interest isn't permission to transfer. Every step is preliminary.

  • Brazil's committee reversed its own cautious July plan, doubling the 2031-2035 ceiling to 100 million tonnes and widening room for future exports.
  • Argentina's third NDC promises participation in Article 6 mechanisms but leaves partners, timelines and eligible activities blank.
  • Chile has fast-tracked 11 proposed projects, from battery storage to forestry, into a stage that could yield preliminary government support.
  • Brazil's emissions trading tools and deforestation roadmap are in place, but allowance trading has not started and the definitive eligibility list is still pending.
  • Across all three countries, no international transfer has been authorized yet, and the next decisions will determine whether this momentum becomes actual trade.

Across the southern half of the Americas, three of the continent's largest economies are laying the administrative groundwork for a future in which their emissions reductions might cross borders as tradable units. Brazil has widened the ceiling on how much of that mitigation it may authorize for transfer, Argentina has declared its intention to join the Paris framework's carbon mechanisms without yet naming a partner or a calendar, and Chile has begun vetting specific projects and standards. Yet every step so far is a doorway rather than a passage: ceilings, declarations and preliminary endorsements that set the terms of a market which has not yet begun to trade.

Brazil's Interministerial Committee on Climate Change has set the maximum volume of mitigation outcomes the country will authorize for international transfer under Article 6.2 of the Paris Agreement. The ceiling is 50 million tonnes of CO2 equivalent for 2026-2030 and 100 million for 2031-2035. The later figure is double what the government had proposed in July, a more cautious plan that put Brazil's own climate commitments first. These are limits on what may be authorized, not transfers already made, so no volume is available to buyers today.

The same committee approved a Ministry of Finance resolution creating seven instruments for Brazil's emissions trading system, including a compensation program, a national allocation plan and a revenue plan for decarbonization. The resolution sets up the tools but does not begin allowance trading. Brazil has still not published its definitive list of eligible activities, though it has named carbon removals such as forest restoration and methane capture from landfills as priorities.

Argentina's third NDC, submitted to the UNFCCC on November 6, declares an intention to use carbon market mechanisms under Article 6, while insisting that markets must not hinder economic growth and that domestic rules remain Argentina's to set. The document names no partner countries, no timeline and no eligible cooperation pathways. Its listed mitigation activities, from renewables to no-till farming, are not labeled eligible for transfer. The country's 2022 emissions stood at 401 MtCO2e, against a commitment to stay at or below 375 in 2030 and 2035.

Chile moved on the same day. Its Ministry of Environment recognized three certification programs, Verra's Verified Carbon Standard, Gold Standard and ART TREES, and gave favorable preliminary reviews to 11 proposed activities: seven battery storage projects, one biogas initiative and three forestry projects. These now enter prior consideration, which could produce a Letter of Interest, a signal of support rather than permission to transfer. Separately, Chile's national committee approved programs under its agreements with Switzerland and Japan and updated its list of priority activities.

The next markers are clear. Brazil owes its final eligibility list, Argentina has no framework timeline, and Chile's 11 projects now move toward possible Letters of Interest.

Brazil's Interministerial Committee on Climate Change, known as the CIM, has set the maximum volume of internationally transferred mitigation outcomes the country will authorize under Article 6.2 of the Paris Agreement. The cap is 50 million tonnes of CO2 equivalent for 2026-2030 and 100 million tonnes for 2031-2035. The second figure is double what had been proposed for those years, which means the committee changed the plan the government presented in July.

That July proposal was the more cautious one. It was built so that Brazil would put meeting its own Nationally Determined Contribution first. The committee has now widened the room for future exports of mitigation outcomes. These are ceilings on what may be authorized. They are not transfers that have happened, and they are not credits that have been traded, so none of this volume is available in the market today.

Brazil has not yet published its definitive list of eligible activities. The government has pointed to two priorities: carbon removals, including forest restoration, and emissions reductions from methane generated by landfills and other organic waste. The source says the larger 2031-2035 ceiling could matter to developers of removal, restoration and methane capture projects.

The same committee approved a Ministry of Finance resolution creating seven instruments to support Brazil's emissions trading system. One is the Brazilian Emissions Compensation Program, which will set criteria for recognizing carbon credits as Verified Emissions Reduction or Removal Certificates, along with a central registry. Another is a National Allocation Plan, which will define the emissions cap, the allocation of Brazilian Emissions Allowances and price stabilization mechanisms. An Annual Resource Allocation Plan will direct system revenues toward decarbonization initiatives. The resolution defines the tools for implementation; it does not start allowance trading. The committee also approved a national roadmap to halt and reverse deforestation and forest degradation by 2030.

Argentina took a different step. Its third NDC, submitted to the UNFCCC on Friday, November 6, declares an intention to take part in bilateral, regional and multilateral carbon market mechanisms under Article 6. The document describes carbon markets as an additional and relevant source of financing, as long as they do not interfere with economic growth, and asserts the country's sovereign right to set its own domestic rules. Those rules would be developed within the National Climate Change Cabinet, with the aim of preventing double counting, protecting socio-environmental integrity and ensuring projects serve national mitigation and adaptation goals. It also recognizes voluntary carbon markets as a complement for drawing private investment.

What the NDC leaves out is substantial. It names no partner countries, sets no timeline for the regulatory framework and does not say which kinds of cooperation Argentina will prioritize. It lists mitigation activities such as renewable power, biofuel blending, hydropower, nuclear, efficiency, sustainable transport, afforestation, avoided deforestation of native forests and no-till farming, but it does not label them eligible for Article 6 or explain how they would yield internationally transferable outcomes. Argentina committed to keep net emissions at or below 375 MtCO2e in both 2030 and 2035. Its latest inventory put 2022 emissions at 401 MtCO2e.

Chile's Ministry of Environment, in an announcement also published November 6, recognized three certification programs for its Article 6.2 framework: Verra's Verified Carbon Standard, Gold Standard for the Global Goals and Architecture for REDD+ Transactions (ART TREES). Recognition does not automatically authorize projects registered under them or the transfer of their reductions; national requirements still apply. The ministry gave favorable preliminary assessments to 11 proposed activities: seven battery storage projects, one biogas capture initiative and three forestry and land use projects. They move to the prior consideration stage, which can lead to a Letter of Interest, a sign of preliminary government support that does not permit international transfers.

Chile's National Article 6 Committee separately approved three programs of activities under its agreement with Switzerland, covering biomass boiler replacement, electromobility and energy storage. It backed eight projects under the cooperation agreement with Japan, which are moving from Kyoto Protocol mechanisms to the Paris framework, and approved an updated list of priority mitigation activities replacing the version introduced a year earlier.

The next markers are clear. Brazil still owes its final list of eligible activities, Argentina has set no timeline for its framework, and Chile's 11 activities now head toward possible Letters of Interest.

Argentina says carbon markets could be an additional source of financing, provided they do not interfere with economic growth.
— Argentina's third NDC, paraphrased
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