Skip to Content

Carbon Trading: NGO Statements

Will carbon markets ever deliver for southern government, forests and people?

This statement, endorsed by 57 prominent human rights and environmental organisations from Europe, Africa, Asia,and North America, argues that carbon markets will never deliver for southern governments, forests or people.

Carbon trading does not reduce emissions, will not deliver money where it is needed on the ground and will not recognize the important role that communities play in protecting forests.

The statement, released in the second week of the Paris climate summit in December 2015, is an update of a similar statement released in 2011. While some of the figures have changed, the fundamental flaws in relying on a carbon market to deliver are just as pronounced today.

PDF iconWill carbon markets deliver?931.71 KB

Fern’s response to EU LULUCF Consultation

Fern's response to this consultation concludes that the challenge of limiting global warming to two degrees is so great that effort should be made in all sectors. By maintaining Land Use, Land Use Change and Forestry (LULUCF) separately, the EU avoids reducing its ambition and gives itself the opportunity to create real ambition to maintain carbon stocks and reduce emissions in LULUCF.

PDF iconLULUCF consultation_Fern.pdf243.17 KB

Input to the consultation on structural options to strengthen the EU Emission Trading System

This input to the European Commission consultation on options to stregthen the EU Emissions Trading Scheme (ETS) was signed onto by 21 organisations. It raised only was concern, that the consultation excludes a fundamental, seventh option: ending the ETS by 2020 and replacing it with other regulatory climate policies. This is a serious omission that leaves this consultation incomplete as an input toward a legislative proposal. After two years of decline, the prices of emission permits and carbon credits have reached historic lows. Numerous institutional as well as private actors are now leaving the carbon market, acknowledging the effectual end of a scheme that from its early days has been crippled by profound contradictions and structural failures. The EU needs to open discussions on how to close the EU ETS and the actions that should replace it.

Submission to the UK climate change committee enquiry into the EU ETS

This submission to the "EU Emissions Trading System: New Inquiry" shows that fundamental flaws in the design of the EU ETS have been exposed by (a) a series of fraud and cybercrime incidents; (b) the excessive use of carbon offsets by companies hoarding higher-value EU ETS permits received free of charge; and (c) the lack of a functioning regulatory possibility to adjust thesupply of EU ETS emission permits to a sharp economic downturn, and theresulting drop in emissions far below projected levels that were used to calculate permit allocation.

Submission to UN consultation on new market-based mechanisms to enhance the cost-effectiveness of, and promote, mitigation actions

This submission concludes that the EU ETS and the Kyoto Protocol’s carbon trading schemes have been designed to fail: they assume the contribution of carbon permits and offset credits to limiting greenhouse gas emissions to a verifiable target to be the same, when in reality they are not because calculation of offsets depends on unverifiable hypothetical baselines from which offset volumes are calculated. The call for submissions on ‘establishing new market-based mechanisms’ suggests that these ill-conceived mixed permit-credit carbon trading schemes are to be extended to additional sectors, such as the forest and land use sector (where error margins are even bigger and risk of reversal of carbon savings is significant).

Linking trading schemes that operate in jurisdictions where enforcement capacity differs significantly, will provide further ground for trading in ‘subprime’ carbon derivatives, in particular given that much of the trading activity in carbon offsets is carried out over-the-counter. 

FERN submission to a commodity futures trading commission study

FERN’s input into the Commodity Futures Trading Commission and interagency working group’s forthcoming study on the oversight of existing and prospective carbon markets. It concludes that the EU Emissions Trading Scheme and the Kyoto Protocol’s carbon trading schemes have been designed to fail and that it is difficult to see how subsequent regulation could remedy a situation where the challenge is not to remedy design flaws but where the design is the flaw.  

FERN submission to UK Parliament

FERN submission to the UK Select Committee on Environment, spelling out FERN's vision on forest, climate, rights and carbon trading

Microsoft Office document iconOPEN76.5 KB


Most recent publications

Response to the Verified Carbon Standard

By Fern

In November 2017, Fern published new research showing why forest carbon offsets should be ineligible for the United Nations (UN) ICAO. The VCS issued a public “rebuttal” to our publication.

Fern wishes to reassert why forest offsets and, more broadly offsetting itself, is not a viable solution to climate change or a way to protect communities’ rights.

Improving forest governance in Laos

In 2012, the Lao government expressed interest in negotiating a Voluntary Partnership Agreement (VPA) with the European Union to address illegal logging trade and to improve forest governance.

How UN aviation deal is cheating the climate


Today airlines are plotting a deal that would undermine our ability to tackle climate change. Tell ICAO - International Civil Aviation Organization their plan must REDUCE emissions.


Aviation sector threatens to undermine Paris Agreement

This press release explains why the aviation sector’s plan for tackling its greenhouse gas emissions would have disastrous consequences for the climate.