Carbon Removal, Reduction, and Avoidance Credits Explained

Key Takeaways

• Concrete and steel contribute 13% of global CO2 emissions. These materials represent substantial scope 3 emissions for companies that are building new infrastructure, including data centers.
• Low-emission alternatives and production technologies are nascent and not yet widely deployed.
• Environmental attribute certificates (EACs) are an innovative solution that can stimulate manufacturing of sustainable commodity materials and overcome market barriers to direct physical procurement.
• Relae (formerly Carbon Direct) and Microsoft developed criteria to guide Microsoft’s high-quality EAC procurement, accelerate decarbonization, and catalyze market expansion for decarbonized materials across supply chains. 
• These criteria cover seven key areas: qualifying conditions, social harms and benefits, environmental harms and benefits, additionality and baselines, catalytic impact, verifiability, and leakage.

A Vision for Low-Carbon Concrete and Steel

Concrete and steel are essential for modern construction, but are carbon-intensive. Combined, they account for approximately 13% of global carbon dioxide (CO2) emissions. ​As the demand for data centers and infrastructure development continues to grow, so do the embodied emissions from concrete and steel. There is an urgent need to decarbonize these sectors so that construction of new facilities remains consistent with climate commitments.​

However, the markets for low-carbon concrete and steel are still in their infancy. Market barriers such as low production volumes, contracting complexity, geographic concentration of supplies, and long-distance transportation limit buyers’ ability to directly procure low-carbon building materials. As buyers and sellers overcome these barriers, the market for low-carbon building materials will mature, giving producers the confidence to invest in new manufacturing facilities and giving buyers access to decarbonized materials directly in their supply chain.

Environmental attribute certificates (EACs) represent the sustainability attributes of a material commodity, unbundled and transacted separately from the physical commodity. EACs are transacted at a price that reflects the additional cost of sustainably producing the material. While barriers to direct procurement of low-carbon materials persist, EACs can serve as a powerful tool to signal demand for low-carbon concrete and steel, catalyze market expansion, and accelerate decarbonization.

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Microsoft’s Approach to Emissions from Building Materials ​

To address embodied emissions and help achieve its ambitious 2030 carbon-negative goal, Microsoft aims to deeply reduce its scope 3 emissions, including from building materials, by more than half compared to a 2020 baseline. In 2023, scope 3 emissions made up over 96% of Microsoft’s total greenhouse gas footprint. To meet its 2030 target, Microsoft is focusing on addressing supply-chain emissions related to data center construction and the embodied carbon of the commodity materials used to build them. Microsoft is already working to decarbonize its building material supply chain using the following three tactics:

• Reduce the need for concrete and steel through innovative building design or the use of lower-carbon alternatives, such as sustainably sourced mass timber.
• Directly engage with suppliers to procure low-carbon alternatives to conventional concrete and steel.‍
• Invest in and help pilot new low-carbon production pathways.

EACs represent a fourth approach to decarbonization that can both reduce emissions and catalyze industry growth. Taken together with Microsoft’s design, procurement, and investment tactics, these actions underpin a comprehensive strategy for long-term decarbonization of the built environment.

High-Quality EACs Support Decarbonization

EACs offer a virtual, market-driven solution to decarbonize the built environment by allowing companies to support low-carbon material production when physical supply chain barriers impede direct procurement. ​EACs for concrete and steel function similarly to other market-based decarbonization mechanisms such as sustainable aviation fuel (SAF) certificates in the aviation sector and renewable energy certificates (RECs) in the energy sector.

These mechanisms work by decoupling the environmental benefits of low-carbon production from the physical materials themselves. EACs allow companies to claim the environmental benefits of physical low-carbon concrete or steel production, even if they do not directly or physically source those materials. EACs provide a verified claim that a purchaser has procured a product with lower emissions, enabling companies to meet climate targets and demonstrate their commitment to sustainability.

Due to their virtual nature, which limits physical oversight of the supply chain, EACs also exacerbate risks such as double counting, greenwashing, fraud, social harms, and environmental harms. Therefore, adhering to transparent, rigorous criteria is foundational to mitigating these risks.

New Criteria to Guide Procurement of High-Quality EACs

To support the integrity and effectiveness of EACs in these sectors, Relae and Microsoft have co-developed Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors. These robust criteria serve as a public resource for companies seeking credible and impactful EAC procurement pathways for low-carbon concrete and steel.

The criteria address seven key areas:

1. Qualifying conditions: EACs must complement, not displace, direct procurement and represent significant emissions reductions. ​
2. Social harms and benefits: EACs must not further social harms and should promote community engagement and social benefits such as meaningful workforce development opportunities and community climate resilience.
3. Environmental harms and benefits: EACs must not perpetuate environmental harm, but instead should mitigate risks and, ideally, provide additional environmental benefits.
4. Additionality and baselines: Projects funded by EACs must drive real, meaningful emissions reductions ​in terms of financial, regulatory, and common practice additionality.
5. Catalytic impact: Prioritize transformative technologies with sector-wide decarbonization potential. ​
6. Verifiability: Set a high bar for documentation, transparency, and independent auditing. ​
7. Leakage: Address risks of emissions displacement to support net-positive outcomes. ​

These criteria provide a robust framework for companies and stakeholders to evaluate and implement commodity EACs effectively, supporting impactful change. ​They balance rigor with flexibility and acknowledge the nascent state of the markets for low-carbon concrete and steel. Sectoral decarbonization will advance over time, shifting the thresholds for what is considered significant, additional, and catalytic in EAC transactions. This science-driven framework can adapt to advancements in policy, industry practices, and technological readiness, ensuring EACs remain a relevant and impactful tool for years to come. ​

Sector-Specific Insights

In addition to providing overarching criteria and guidance on procuring EACs for the built environment, Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors also provides insights into the unique challenges and opportunities of decarbonizing concrete and steel.

Decarbonizing Concrete

EACs can support innovative decarbonization strategies for concrete, such as producing alternatives to clinker and cement, adopting supplementary cementitious materials (SCMs), and reducing emissions from cement kilns through electrification or integrating carbon capture and storage (CCS). ​Performance-based standards and evolving building codes may also unlock new opportunities for low-carbon concrete. ​

The Global Cement and Concrete Association (GCCA) publishes a rating system, Low Carbon Concrete (or Cement) Ratings, which defines eight separate low-carbon grades (AA through G). These grades correspond to the depth of decarbonization and are based on a sliding scale related to the material’s compressive strength. When developing these criteria, Microsoft considered grades AA through D to be eligible for consideration in its EAC procurements.

Decarbonizing Steel

EACs can support transformative technologies for decarbonizing steel, like direct reduced iron (DRI) with electric arc furnaces (EAF) powered by green or blue hydrogen. This support can enable the steel sector to move beyond incremental improvements and focus on capital-intensive solutions that have the potential to reshape the industry. ​

ResponsibleSteel, an independent standards and certification organization with membership that is broadly representative of the steel industry, publishes decarbonization progress levels, with four separate grades (PL1–PL4). These grades correspond to the depth of decarbonization and are based on a sliding scale related to the fraction of recycled scrap use in the steel manufacturing process. When developing these criteria, Microsoft included levels PL2 through PL4 for consideration in its EAC procurements.

A Blueprint for EAC Market Development ​

Relae and Microsoft crafted Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors as a public resource that can help shape the future of the commodity EAC market. ​

These criteria are designed to:

• Communicate intent: Communicate Microsoft's intent to support the decarbonization and scaling of physical commodity supply chains where they have been previously limited.‍
• Guide decision-making: Serve as a public guide for Microsoft's decision-making process, explaining the rationale behind pursuing or declining specific EAC pathways.‍
• Set high-integrity standards: Maintain high integrity for EACs at an early stage, ensuring they are used to enable future physical procurement by supporting market development.‍
• Stimulate partnership opportunities: Encourage potential partnerships and purchasing pipelines by clearly describing criteria for high-quality EACs.‍
• Publicly share detailed thinking: Build on previous work and publicly share detailed thinking, aiming to stimulate market development and guide procurement decisions.

Practical Recommendations for Implementing EACs

Whether you are a supplier, buyer, policymaker, or sustainability advocate, these new criteria offer actionable insights to help you navigate the complexities of EACs in the built environment. ​From setting significance thresholds to ensuring verifiability to avoiding double counting, the criteria provide clear guidance to maximize the impact of EAC-supported projects.

Beyond the technical aspects of EACs, these criteria aim to address their broader social and environmental implications. The criteria focus on the importance of community engagement, transparency, and equitable distribution of benefits in EAC project planning, ensuring that decarbonization efforts contribute to a more sustainable and just economy. ​The criteria are backed by extensive research, stakeholder consultations, and industry expertise.

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Frequently Asked Questions

What is an environmental attribute certificate (EAC), and how does it differ from buying low-carbon concrete or steel directly? 

An environmental attribute certificate represents the sustainability attributes of a commodity material such as concrete or steel, unbundled from the physical material and transacted separately from it. Direct procurement means a buyer purchases low-carbon concrete or steel and takes physical delivery of it for a specific project. An EAC purchase instead allows a buyer to fund and claim the environmental benefit of sustainably produced materials that are sold as typical commodities, and apply that benefit against conventional commodities in their own supply chain. EACs are priced to reflect the additional cost of producing the material sustainably, which sends a demand signal to producers. This makes EACs useful where market barriers—limited production volumes, geographic concentration of supply, or long-distance transportation—prevent buyers from sourcing low-carbon materials directly.

How do EACs for concrete and steel compare to renewable energy certificates (RECs) or sustainable aviation fuel (SAF) certificates?

Environmental attribute certificates for concrete and steel share a structure with renewable energy certificates and sustainable aviation fuel certificates: each decouples the environmental benefit of low-carbon production from the physical product, letting a buyer fund and claim that benefit without taking physical delivery. There are two key differences. First, conventional RECs represent electricity with a zero-emissions footprint, while every tonne of concrete or steel behind an EAC still carries embodied emissions — the certificate demonstrates reduction against a baseline, not a zero-emission product. Second, REC and SAF markets are established, while EACs for concrete and steel are nascent. Both differences are why rigorous criteria matter: quantifying the reduction credibly is harder, and the virtual structure carries risks of double counting, greenwashing, and fraud.

Will EACs let companies claim emissions reductions without actually reducing their built environment climate footprint?

An EAC purchase does not change the materials in a buyer's own buildings; it funds lower-emission production elsewhere in the market. Credible EAC frameworks therefore require that certificates complement rather than displace direct procurement, that they represent significant reductions against a defensible baseline, and that the funded project would not have proceeded without EAC revenue. The criteria published by Relae and Microsoft enable buyers to address these requirements directly in their procurement processes - addressing the climate and reputational risks of low-quality certificates. Used this way, EACs become an additional tool to address emissions from the built environment, supplementing design changes, direct procurement, and investment in new production pathways.

Who should use these criteria?

Criteria for High-Quality Environmental Attribute Certificates in the Concrete and Steel Sectors, co-developed by Relae and Microsoft, is a public resource intended for four audiences. Buyers pursuing scope 3 reductions can use it to evaluate whether a given certificate represents a credible, additional emissions reduction. Suppliers and project developers can use it to understand what purchasers of high-quality certificates look for before bringing a project to market. Policymakers and standards bodies can draw on it while shaping rules for an emerging market. Sustainability practitioners and advocates can use it as a reference point for assessing claims made about low-carbon concrete and steel. The criteria are designed to evolve as these sectors decarbonize, and users may adapt them to meet their own levels of capability and ambition. 

Key Takeaways

• Improved forest management (IFM) increases measurable long-term carbon storage in living trees and durable wood products.
• At the same time, it can provide strong social and ecological co-benefits.
• IFM projects like the ones developed by Weyerhaeuser and the Indigenous community of Petcacab in collaboration with Relae (formerly Carbon Direct) show how IFM practices can align climate goals with social and environmental benefits.

Forests Are Climate Solutions If We Manage Them Wisely

Forests remove carbon dioxide from the atmosphere, but they need to be thoughtfully managed to keep doing so. As buyers look to scale carbon removal, improved forest management (IFM) is gaining traction in the voluntary carbon market (VCM).

IFM focuses on enhancing how existing forests are managed to increase carbon storage over time. It’s a nature-based solution that supports climate outcomes, community livelihoods, and environmental benefits when done well.

This piece explains how IFM works, what makes a project high-quality, and how real-world IFM projects like those developed by Weyerhaeuser and Petcacab in collaboration with Relae (formerly Carbon Direct) are delivering credible results for buyers and local communities alike.

What Is Improved Forest Management?

Improved forest management is a catch-all phrase that describes management techniques that decrease emissions from forests or increase carbon removal and storage. Some management techniques, like transitioning a working forest to a conserved status, decrease emissions from forest harvest and primarily create credits for avoided emissions. Other management techniques, like harvesting forests less frequently, can lead to greater carbon removal and storage over time and create credits for additional carbon removal. 

Examples of IFM Practices Include:

• Extending harvest rotations to allow more carbon accumulation
• Reducing the impact of logging on soil and surrounding trees
• Managing fire and pest risks to enhance forest health
• Transitioning some of a forest to conservation status

These strategies help forest carbon stocks grow beyond business-as-usual baselines. In carbon markets, IFM can generate carbon removal or avoided emissions credits, depending on the project's design and carbon accounting methodology.

What Makes a High-Quality IFM Carbon Removal Credit?

Buyers today face increased scrutiny around carbon credit quality. In this context, IFM projects must go beyond basic registry standards to demonstrate climate integrity and social and environmental benefits. 

Relae developed the Criteria for High-Quality Carbon Dioxide Removal, an annual report published in collaboration with Microsoft to establish science-backed quality standards. This includes six core principles that define high-quality carbon removal, all of which apply to IFM projects: 

• Social harms, benefits, and environmental justice - The extent to which the project prevents new social harms to people and communities, reduces existing harms, and provides meaningful benefits distribution. Since IFM projects take place in communities around the world, benefits will naturally vary from project to project.  
• Environmental harms and benefits - The extent to which the project minimizes and mitigates environmental harms, as well as provides environmental benefits. Because IFM projects enhance management practices, environmental co-benefits of high-quality IFM projects are usually substantial.
• Additionality and baselines – Evidence that the project’s carbon removal would not have occurred without carbon finance. Many IFM projects fail to present compelling additionality data and narratives. High-quality projects will be able to identify the actions the project took to increase carbon storage that would not have happened without carbon finance. 
• Measurement, monitoring, reporting, and verification (MMRV) – The ability to accurately quantify carbon removal in a repeatable and verifiable way, and to develop a plan for long-term monitoring of the project. IFM projects must have robust forest inventory, growth modeling, and occasional remeasurement to verify the additional carbon storage. 
• Durability – The likelihood that removed carbon remains stored over time, with mechanisms in place to mitigate reversal risk. Enhanced management of fire, pests, and disease in IFM projects can enhance forest carbon durability. 
• Leakage – Evaluation of whether project activities cause increased emissions elsewhere. If an IFM project substantially reduces timber supply, market demand can drive increased harvesting in other forests, undermining some of the project’s climate benefits. High-quality IFM projects minimize this risk by limiting harvest reductions, and account for any remaining leakage by issuing fewer credits.

Relae uses these criteria as part of our diligence framework when advising buyers evaluating projects and co-developing our own projects.

IFM Projects Delivering Real Impact

Weyerhaeuser: Applying Science at Scale

Weyerhaeuser, one of the largest forest owners in North America, is applying improved forest management practices across over 200,000 acres of working forests.

The IFM projects led by Weyerhaeuser are located in rural areas in the US, with low wildfire risk. These IFM projects sequester carbon by extending harvest rotations and forgoing harvest in established streamside management zones. 

Relae supported Weyerhaeuser with hands-on scientific collaboration to confirm that every IFM project met the Criteria for High-Quality Carbon Dioxide Removal. 

Why it matters to buyers:

• High-quality climate impact at large scale
• Transition of working forests from traditional management techniques to maximize climate impact
• Responsible forestry practices aligned with SFI® standards
• Rigorous carbon accounting and high-quality project baseline established using historical harvest records

The IFM projects led by Weyerhaeuser are some of the largest in the US today and a model for scaling science-backed forest carbon solutions.

Petcacab: Indigenous-Led Conservation in the Yucatán Peninsula

Located in the communal lands of Petcacab, Mexico, this IFM project is led by Indigenous Mayan ejidatarios—community members who have legal rights to manage the land.

Historically, forests in the ejido have been degraded through unsustainable harvesting and extensive damage from hurricanes. Through carbon finance, they are developing new forest management plans and sustainable forestry models, with revenue reinvested in health, education, and job creation.

“The rainforest for me represents my home, my work, my present, my future. We have a very daring challenge: to transform how we manage our forest, shifting from harvesting and selling timber to conserving it through the sale of carbon credits that support the development of our community.”
— Celso Chan Rivas, Carbon Project General Manager

What makes Petcacab stand out:

• Equitable benefit-sharing and strong Indigenous governance
• Critical habitat protection for endangered species
• Increased additional carbon storage through forest management and reduced land use conversion 
• Transparent reporting and verified outcomes

Petcacab is recognized by Relae as a high-quality community IFM project in Mexico, with clear social, environmental, and climate outcomes.

Investing in Forests That Deliver More Than Carbon

Improved forest management is more than a carbon strategy, it’s an investment in ecosystems, communities, and long-term impact. For buyers seeking high-integrity carbon removal with social and environmental co-benefits, IFM projects offer a compelling opportunity.

IFM projects like the ones developed by Weyerhaeuser and Petcacab in collaboration with Relae show what’s possible when forests are managed with science and care. They also reflect what the voluntary carbon market needs more of: quality, transparency, and impact beyond the metric ton.

Key Takeaways

• Relae (formerly Carbon Direct) has conducted over 900 comprehensive, rigorous reviews of carbon removal (CDR) projects around the world. But fewer than 10% meet our standard for high-quality. In today’s market, scientifically-credible CDR supply is scarce.
• To identify high-quality projects, buyers and investors previously had to commission numerous deep diligences, which often made it a lengthy and complex process, not well-suited to most market participants. 
• The Diligence Collection changes that paradigm by giving you direct access to existing comprehensive analysis on a curated set of high-quality CDR projects. The hard work of identifying high-quality projects is already done, allowing you to move faster, spend less, and procure with more confidence.

Relae Sets the Bar for High-Quality CDR

Since 2020, every year Relae has released an updated version of the Criteria for High-Quality Carbon Dioxide Removal in collaboration with Microsoft. The Criteria set the standard for scientific rigor across nine CDR pathways and across six technical dimensions. Using this standard, the Relae team has conducted diligence on over 900 CDR projects across 63 countries. Our diligence has been used for over 50% of all tonnes contracted through announced CDR offtake agreements worldwide, including diligence for the majority  of tonnes from Microsoft’s announced offtakes. This gives Relae a uniquely deep understanding of the CDR market; and importantly, it has highlighted that high-quality projects in the voluntary carbon market are scarce. 

Quality Is the Central Challenge in CDR Procurement 

Only 10% of the projects that Relae has assessed meet our high-quality criteria. This means that without rigorous, scientific assessment, buyers and investors run real risk of exposing themselves to delivery shortfalls, financial loss, and reputational damage. 

This presents a series of challenges to buyers and investors interested in procuring or investing in CDR. Conducting diligence on CDR projects is time-intensive, complex, and requires deep expertise. Building the internal capacity to rigorously evaluate a wide variety of CDR projects isn’t practical for most actors. But conducting the in-depth diligence required to procure or invest confidently requires real commitment, especially when a significant proportion of the projects diligenced may not be high-quality. Finding the needle in the CDR haystack isn’t easy.

The Case for Curated CDR 

The Diligence Collection directly addresses these challenges by providing self-serve access to diligence on a curated set of high-quality CDR projects vetted by Relae. Every project has already been evaluated against the Criteria for High-Quality Carbon Dioxide Removal, the science-based benchmark jointly established by Relae in collaboration with Microsoft. The Collection includes projects reviewed on behalf of Microsoft and other major buyers, and more broadly reflects our diligence work across the market.

With the Diligence Collection, you're not starting from scratch. Instead, you're starting from a shortlist of some of the highest-quality CDR opportunities available, with robust scientific diligence to back them up. The bottleneck that's slowed procurement for so many organizations is no longer a concern.

The Collection offers two levels of diligence, matched to the level of scrutiny your commitment warrants:

1. Desk review: An executive-level assessment using available project documentation, enough to make an informed shortlisting decision or purchase.
2. Deep diligence: A comprehensive technical evaluation covering project design, operational risk, technology assessment, policy landscape, and community impacts, reflecting the same methodology that's informed the procurement programs of Microsoft and other major buyers.

Both tiers include the option to commission an updated evaluation as your needs evolve.

What Rigorous CDR Diligence Involves 

The depth of Relae’s diligence sets the Diligence Collection apart. Our desk review process involves conducting detailed assessments to evaluate projects against 6 quality principles: social harms, benefits, and environmental justice; environmental harms and benefits; additionality and baselines; measurement, monitoring, reporting, and verification; durability; and leakage. The result is a comprehensive report that assesses projects against these criteria, highlighting the project's overall quality, strengths, and weaknesses in a clear, succinct way that supports decision-making. 

Many of our reports dig even deeper. Our deep diligences assess both a project’s quality and its delivery risk. To evaluate delivery risk, we assess projects across 5 elements: technologic, economic, commercial, operational, and political. Deep diligence is conducted over 3-4 months, which includes weekly back-and-forth with the supplier and a site visit to understand all of the nuances of the project and validate developer claims on the ground. The resulting report not only documents a project's strengths and weaknesses, but also outlines risk mitigation measures and recommends improvements over time. 

Broader Access, Stronger Market 

Forward offtake demand in the CDR market has historically concentrated among a handful of large buyers, and as our 2026 State of the Voluntary Carbon Market report notes, diversifying that pool is essential to enabling the next generation of CDR supply. The Diligence Collection is built to support exactly that. By making the scientific rigor behind the world's largest CDR transactions available through a self-service platform, it opens credible procurement to organizations at any stage of purchasing. More buyers accessing high-quality, de-risked projects means more capital flowing to suppliers, more projects able to scale, and a more resilient market that doesn't depend on a small number of actors to function.

High-quality CDR supply is scarce, and the best projects are in high demand. The Diligence Collection gives you the foundation to act efficiently and with confidence, without starting from zero.

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Frequently Asked Questions

Who Can Access the Relae Diligence Collection?

The Diligence Collection is available to approved subscribers, including CDR buyers and investors seeking to more efficiently evaluate carbon removal projects. To preserve the independence and integrity of the Collection and protect proprietary diligence insights, access is not available to project developers or rating agencies.

How Is the Relae Diligence Collection Different From a Rating Agency or Market Intelligence Platform?

Most rating platforms optimize for quantity; we optimize for quality. Our process includes pathway-specific risk assessments and, in many cases, site visits from our in-house scientists, engineers, and technical experts—the same multidisciplinary team and judgment behind our own portfolio decisions and the procurement programs we support directly. The Collection also includes projects diligenced before they've received external ratings, giving you visibility into promising opportunities at the pre-commercialization stage.

Does Inclusion in the Relae Diligence Collection Mean Relae Endorses a Project?

Inclusion means a project was evaluated through our scientific diligence process and, at the time of review, met our Criteria for High-Quality Carbon Dioxide Removal. It reflects a positive diligence outcome based on the information available during the review and the project's stage of development at that time. As projects and market conditions evolve, we recommend considering whether updated diligence or additional evaluation is appropriate for your specific procurement or investment objectives.

Can I Request Diligence on a Project That Isn't Already in the Collection?

Yes. You can commission us to diligence a specific project based on your procurement or investment priorities. Whether it's later added to the Diligence Collection depends on a few factors beyond just meeting our quality bar, including consent from you as the commissioning buyer and approval from the project developer.

Key Takeaways

• Carbon credits are one of several instruments for decarbonizing cement, alongside environmental attribute certificates (EACs) and direct procurement of lower-carbon products. Each serves a different purpose, and buyers and developers should understand how they interact before engaging. 
• Article 6.4 of the Paris Agreement is becoming a reference point for public and private carbon credit procurement, so the quality of its methodologies now holds significant weight. 
• Proposed methodology A6.4-PMM010 - Partial substitution of fossil fuels by MSW in cement manufacture largely aligns with Relae and Microsoft’s Criteria for High-Quality EACs in the Concrete and Steel Sectors. However, Relae identified opportunities to strengthen provisions addressing interactions between carbon credits and environmental product declaration (EDP), where credited reductions are deducted from the product's EPD, with the aim of reducing the risk of the same mitigation being claimed more than once.

Article 6.4 Joins the Cement Decarbonization Toolkit 

Article 6.4 of the Paris Agreement is expanding the financing options for decarbonizing cement and concrete. Environmental attribute certificates (EACs) let buyers pay for lower-carbon production without taking physical delivery of the product, while carbon credit methodologies reward manufacturers for storing captured CO₂ in their products. 

Relae is actively shaping this market: conducting technical diligence for buyers of cement EACs, providing project assurance and go-to-market support for industrial decarbonization projects, and leading market development through the publication of the Criteria for High-Quality EACs in the Concrete and Steel Sectors, in collaboration with Microsoft. 

To build on these efforts, Relae (as Carbon Direct) recently participated in the public consultation for a proposed carbon credit methodology under the Paris Agreement Crediting Mechanism (PACM). Methodology A6.4-PMM010 would credit emissions reductions from replacing fossil fuels with municipal solid waste (MSW) in the production of cement clinker. The approach was proposed by the Inter-American Cement Federation (FICEM), which in 2026 partnered with the UN Industrial Development Organization to work to decarbonize the sector across Latin America. 

The PACM, established under Article 6.4 of the Paris Agreement, could underpin national climate strategies and voluntary offsetting demand for years to come. One potential avenue of influence is the SBTi Corporate Net Zero Standard V2.0, which has introduced formal recognition of market-based instruments. As both public and private entities weigh their carbon credit procurement options, this is a critical juncture for getting the methodologies right. 

Two Key Options for Decarbonizing Cement: Carbon Credits and EACs

Concrete and steel are indispensable to modern construction and together account for approximately 13% of global CO₂ emissions. With demand for infrastructure continuing to rise, including via data centers, decarbonizing these sectors is essential for new construction to remain consistent with climate commitments. 

Carbon credits are one route to financing that work. A credit is issued for each tonne of emissions reduced below a baseline, meaning the emissions that would have occurred without the intervention. For a cement plant, credits might be issued for switching to low-carbon fuels or installing new equipment that reduces emissions. Companies buy credits to offset emissions outside their own value chains, and in doing so channel finance to projects that would not otherwise proceed. 

EACs are a second route, and one that Relae is helping to shape. An EAC assigns a measured environmental characteristic to a unit of product (e.g., tonnes of CO₂ per tonne of cement), usually established through an attributional life cycle assessment. The buyer pays for the lower-carbon attribute of a product and reports it against its own value chain emissions, which makes EACs a tool for scope 3 decarbonization rather than for offsetting. 

While methodology A6.4-PMM010 is for carbon credits, we use the Relae EAC criteria as our reference point, as both instruments depend on the same foundations. An intervention must be traceable to a specific facility, the carbon impact must be quantifiable with a defensible method, and the project must be assessed for its social and environmental harms and benefits. The criteria set out in depth how Relae tests those foundations for an EAC claim, and the same tests apply with little adjustment to a crediting methodology.

Regardless of the preferred market instrument, replacing fossil fuels in cement production should be read as a partial solution. Kiln fuel combustion accounts for roughly 35% of the CO₂ emitted in clinker production, while the remaining 65% arises from process emissions inherent to calcination: when the heated limestone breaks down into lime and releases CO₂ as a byproduct. As such, Relae considers this as part of a multi-step decarbonization strategy that should ultimately address calcination emissions through carbon capture, novel binders, or substitution of the clinker itself. 

Why the PACM Matters for Carbon Credit Buyers

While there is a lack of supply today, PACM credits have the potential to underpin carbon credit demand. Corporate buyers looking to make recognized offsetting claims have reason to favor units issued under a government-endorsed UNFCCC mechanism. The European Climate Law references Article 6.4 quality standards, and the EU is expected to tie the eligibility of procured international credits to its methodologies. The German federal government has used UN-recognized credits to offset its business travel emissions since 2014, and UK government agencies have also sought PACM credits to fulfill their offsetting needs. 

A strength of the PACM is its centralized structure. The 12-person Supervisory Body (SB) makes all final approvals, following methodology recommendations from the Methodological Expert Panel (MEP). All methodologies draw on the same Article 6.4 standards and tools. For example, A6.4-PMM010 relies heavily on the Standard on Baselines and the Tool on Emissions from Solid Waste Disposal Sites. Together, these can be used to calculate the counterfactual emissions from waste diverted from landfill, and dictate how to monitor waste conditions over the crediting period.

The potential for the PACM to scale is conditional. As the market matures, voluntary buyers can choose from a widening range of high-quality carbon credits. Moreover, the European Commission has shown, via its criticism of CORSIA, that the EU will make robust efforts to prohibit procurement from projects it considers flawed. As such, the PACM will only succeed if it provides compelling methodologies to accompany solid governance. That is the standard against which Relae reviewed the fossil fuel substitution methodology.

Relae’s Response to the Cement Methodology A6.4-PMM010 

Alignment With Our High-Quality Criteria

We found methodology A6.4-PMM010 for carbon credits to largely align with our high-quality criteria. Certain gaps in the methodology are addressed by the Article 6.4 standards and tools it references, and the combination provides additional safeguards intended to support robust integrity. 

In both the methodology and our criteria, additionality must be shown on regulatory, financial, and common practice grounds. Crediting is limited to the capacity installed at validation, so carbon finance improves existing production rather than funding new clinker capacity, which aligns with our catalytic impact criterion. The methodology also credits both displaced fossil fuel and avoided landfill methane, a dual benefit that strengthens the case for these projects, especially where landfill sites are poorly managed (e.g., do not flare methane). 

We proposed only two major refinements: updating the landfill methane baseline at each verification, and closing the double-counting gap with environmental product declarations (EPDs). 

Landfill Methane Baseline

Under Article 6.4, an independent verifier checks a project’s reported results for each monitoring period before new credits are issued. Relae proposed that the landfill methane baseline be re-established at each of these verifications: from site measurements where available, and by re-selecting the default value to match current conditions where they are not. 

The baseline rests on two factors that can shift as a waste disposal site is capped, compacted, or drained: the oxidation factor (the share of methane absorbed by landfill cover before release), and the methane correction factor (how much of the waste decomposes without oxygen). 

The Article 6.4 Tool on Emissions from Solid Waste Disposal Sites offers measured and default routes for setting these values, but the methodology does not specify which applies. A project developer could apply default values from the tool and leave them static for the whole crediting period. Re-selecting those values at each verification, rather than locking them in at the outset, keeps the baseline tied to how the site is actually performing throughout its crediting period.

Double-Counting Concerns

The Article 6.4 Activity Standard rightly requires that issued credits do not overlap with other emissions mitigation crediting schemes. However, the A6.4-PMM010 does not explicitly say how that applies to EPDs, which report a cement product's carbon intensity. Relae proposed closing that gap directly: the EPD should report the new, lower carbon intensity achieved after the intervention without subtracting the avoided emissions again. The methodology should also require an annual declaration confirming that the credit and the EPD aren’t claiming the same reduction twice. 

An EPD reports a cement product’s carbon intensity, so a lower-carbon cement can earn value in two places at once: through the carbon credit, and through the EPD itself, which is exactly where the double-counting risk sits. EPD standards already keep the avoided emissions out of a product’s carbon intensity, reporting them separately from the product’s life-cycle stages, but A6.4-PMM010 never references that separation. 

Explicitly addressing this distinction in the methodology, and pairing it with Relae’s proposed annual declaration, could strengthen transparency and reduce the risk of overlapping claims associated with the same emissions reductions, where the same emissions reduction can’t be claimed once through the credit and again through the product’s own carbon footprint.

How Relae Can Help

A6.4-PMM010 is a well-designed methodology, but market-based mechanisms for enabling cement decarbonization are evolving faster than practical guidance on how to use them credibly. Relae works with buyers and cement producers navigating this landscape. For buyers, we conduct technical due diligence, advise on procurement strategy, and guide robust claims. For producers and project developers, we assess which market-based mechanism suits a given plant and provide the analytical, market intelligence, and go-to-market support needed to monetize the chosen mechanisms credibly.

Frequently Asked Questions 

What is the difference between a carbon credit and an Environmental Attribute Certificate (EAC)?

A carbon credit represents one tonne of emissions reduced below a baseline, and a buyer uses it to offset emissions outside their value chain. An EAC attaches a measured carbon attribute to a unit of product, such as cement, which the buyer reports against its own scope 3 emissions rather than for offsetting.

What is the relationship between Article 6.4 of the Paris Agreement and the Paris Agreement Crediting Mechanism (PACM)?

Article 6.4 of the Paris Agreement establishes the PACM, which refers to the registry itself along with the methodologies, standards, and tools that govern the credits listed on it. Article 6.4 is the treaty provision, and PACM is the mechanism built under it, so people often use the two terms interchangeably.

How do PACM credits differ from other credits available on the voluntary carbon market (VCM)?

PACM methodologies and standards are developed through a transparent UNFCCC process, which sets them apart from most VCM credits. This does not make PACM credits inherently higher quality, but some buyers, especially governments, prefer to tie procurement to PACM standards. Another key difference is that 7% of PACM credits are deducted at issuance–5% are transferred to the UN Adaptation Fund, and 2% are cancelled for overall mitigation.

Key Takeaways

• SAF and e-SAF mandates are reshaping the aviation fuel market. The EU and UK impose steep non-compliance penalties, turning regulatory requirements into a strategic lever for those who act early.
• Non-compliance is costly. Penalties run roughly 3 times the cost of compliance in the EU and from about 2 to 13 times in the UK, making long-term planning essential to mitigate risk.
• e-SAF producers have a unique opportunity. Mandates and penalties are shifting the economics of aviation fuel, making e-SAF more attractive despite historically high production costs.

How SAF Compliance Stacks Up

Airlines and fuel suppliers operating in Europe and the UK face growing economic uncertainty due to stringent mandates requiring the adoption of sustainable aviation fuels (SAF) with carve-outs for SAF produced from renewable hydrogen, also known as Power-to-Liquids (PtL) or e-SAF.¹ These mandates, aimed at reducing aviation emissions, carry steep penalties (up to 13 times the cost of compliance) for fuel suppliers who fail to meet required quotas. While this creates cost uncertainty for airlines and passengers, it opens a strategic opportunity for e-SAF producers. These producers are challenged by high production costs relative to other SAF on the market and a limited set of buyers that can afford the premium on a voluntary basis.

This piece explores the cost implications for aviation being shaped by these EU and UK SAF mandates and outlines how airlines and suppliers can respond strategically to minimize risk and maximize opportunities. By understanding these dynamics, industry stakeholders can turn regulatory compliance into a source of competitive advantage. 

Understanding SAF Mandates in the EU and UK

The EU Commission’s ReFuelEU Aviation regulation, part of the European Green Deal, sets binding targets for aviation sustainability. Beginning in 2025, ReFuelEU mandated that aviation fuel suppliers offer a minimum percentage of SAF and e-SAF at EU airports. By 2030, suppliers must blend at least 6% SAF, including 1.2% e-SAF. To discourage tankering practices (carrying excess fuel for return trips, increasing emissions), ReFuelEU Aviation requires airline operators to refuel at least 90% of their annual aviation fuel needs at a given EU airport before departure. 

In parallel, the UK Department for Transport (DfT) mandates a higher SAF blend of 10% by 2030 and places greater emphasis on reducing reliance on hydrogenated esters and fatty acids (HEFA) SAF fuels, which face eventual limitations on feedstock supply. HEFA’s allowable share will decline annually from 100% in 2025 to 42% in 2040. The UK also includes a sub-mandate specifically for PtL SAF.

The Real Cost of Falling Behind on SAF Mandates

The financial impact of these mandates is significant. Each year, the European Union Aviation Safety Agency (EASA) publishes regulatory reference prices for SAF, e-SAF, and conventional jet fuel (CJF) that anchor non-compliance penalties in the EU, most recently the 2025 Aviation Fuels Reference Prices for ReFuelEU Aviation. Using these reference prices for current-year costs and projected production costs or prices for SAF, e-SAF, and CJF from 2030–2050, the following analysis compares EU and UK compliance versus non-compliance penalties, converting all figures to US$/gallon.²

The price gap between SAF and fossil jet fuels remains wide. In 2025, SAF is approximately three times the price of CJF, while e-SAF is nearly twelve times more expensive. Projections indicate this price gap narrows by 2030, but far more for SAF than for e-SAF. The projected price of SAF in 2030 is US$5.46/gallon, more than double the estimated US$2.41/gallon for CJF. The price difference is even greater for e-SAF: with no traded e-SAF market yet, projected 2030 prices span US$5.70/gallon to US$33.00/gallon, with a central estimate around US$18/gallon, or roughly seven times the price of CJF.

Estimated Jet Fuel Prices 2025-2050 (US$/Gallon)

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Source: European Union Aviation Safety Agency. 2025 Aviation Fuels Reference Prices for ReFuelEU Aviation. (link); UK Department for Transport. SAF Mandate: Final-stage Cost Benefit Analysis. (link); EUROCONTROL. Aviation Outlook 2050: Main Report. (link)

The mandates carry strict penalties for non-compliance. Penalties for non-compliance in the EU are set at a minimum of two times the price difference between SAF and CJF per gallon of unmet obligation. Additionally, fuel suppliers must supply any unmet fuel obligations in subsequent reporting periods, which pushes the cost of non-compliance in the EU to three times the cost of compliance.

In the UK, penalties work differently: fuel suppliers must pay a fixed buy-out price per megajoule (MJ) of unmet obligation, which translates to US$24.64/gallon of unmet SAF obligation and US$26.08/gallon of unmet e-SAF obligation.³ Because the buy-out is fixed while compliance costs vary, UK penalties range from about 2 times the cost of compliance for e-SAF to 13 times for SAF in later years. The intent is clear: regulators are serious about pushing aviation towards sustainable fuels.

Cost-Comparison of Compliance vs Non-Compliance (US$/Gallon)

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Note: The cost of compliance under both mandates is calculated as the price premium of SAF/e-SAF over CJF per ton, using region-specific SAF prices: the EU SAF price reflects HEFA-based supply (ReFuelEU imposes no HEFA cap), while the UK SAF price is a weighted average of HEFA and higher-cost advanced pathways based on the UK's declining HEFA cap. The e-SAF (PtL) price is the same in both regions. 

Cost-Comparison of Complicance vs Non-Compliance (US$/Gallon)

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e-SAF Has a Policy-Driven Market Opportunity 

These price differentials present risk and opportunity. Airlines and fuel suppliers that fall short of compliance will face steep penalties. Those who comply strategically, can mitigate those risks and benefit from financial incentives that help offset higher fuel costs.

Incentive structures support SAF and e-SAF production. For example, the EU’s Emissions Trading System (ETS) has allocated allowances to offset SAF costs, especially for renewable fuels of non-biological origin (or e-SAF). Similarly, the UK offers tradable certificates and has now legislated a Revenue Certainty Mechanism (Sustainable Aviation Fuel Act 2026) that will guarantee SAF producers a set strike price through contracts-for-difference-style agreements, funded by a levy on fuel suppliers, with the first allocation round expected in 2027. The UK’s ETS also provides an indirect incentive as SAF use by airlines lowers compliance costs through reducing required allowances. 

Strategic Recommendations for Airlines and Suppliers

To navigate this shifting landscape, airlines and fuel suppliers must think strategically about procurement and compliance, potentially including:

• Proactive procurement: Airlines and fuel suppliers should prioritize securing long-term contracts with SAF and e-SAF producers. Early engagement can help ensure access to limited supply and stable pricing.
• Leverage incentive programs: Actively participate in available incentive schemes, such as the EU ETS and UK tradable certificates, to minimize compliance costs.
• Invest in e-SAF production: Consider strategic investments or partnerships in e-SAF production to align sustainability goals with regulatory requirements and financial incentives.
• Plan for volatility: Develop robust risk mitigation plans, using flexible procurement strategies and financial instruments to buffer against supply chain disruptions and price swings.

Turning Mandates into Market Momentum

As 2030 approaches, the pressure on airlines and fuel suppliers to comply with SAF mandates will intensify. Those who proactively respond to and embrace the mandates can transform regulatory requirements into strategic opportunities. Rather than viewing mandates as burdens, forward-looking stakeholders can use them to drive sustainable innovation and long-term resilience.

The EU and UK mandates for SAF and e-SAF represent an emerging shift in aviation fuel markets. Stakeholders that act now, by engaging with incentives and investing in sustainable fuel solutions, will emerge as industry leaders. Now is the time for airlines, fuel suppliers, and e-SAF producers to act decisively, transforming regulatory compliance from a costly obligation into a clear competitive advantage.

Frequently Asked Questions 

What happens if an airline or fuel supplier misses its SAF mandate quota?
Fuel suppliers—the obligated parties—pay a penalty on every unmet tonne: in the EU, twice the price gap between SAF and jet fuel, plus supplying the shortfall in a later period; in the UK, a fixed buy-out price (£0.137/MJ for SAF, £0.145/MJ for e-SAF). Combined, non-compliance runs roughly 3 times the cost of complying in the EU and from about 2 to 13 times in the UK.

What is e-SAF, and how is it different from other SAF?
e-SAF, also called Power-to-Liquid (PtL) fuel, is made from renewable or low-carbon electricity, hydrogen, and captured CO₂ rather than biomass feedstocks. It costs more to produce than conventional SAF today, but both the EU (from 2030) and UK (from 2028) mandates carve out a specific, growing sub-quota for it.

What is the UK's Revenue Certainty Mechanism?
It is a UK government scheme, modeled on the Contracts for Difference structure used in the power sector, that guarantees SAF producers a set strike price for up to 10 years, funded by a levy on aviation fuel suppliers. It became law through the Sustainable Aviation Fuel Act 2026, and the first contract allocation round is expected in 2027.

Is the EU considering changes to its SAF mandate timeline?
The EU has scheduled a formal review of ReFuelEU Aviation for 2027, following calls from airline groups to delay the 2030 e-SAF sub-target. No delay has been adopted, and the European Commission has said it remains "fully committed" to both the SAF and e-SAF mandates and that the 2027 review will evaluate the regulation rather than revise it.

Can corporate buyers still claim SAF benefits from fuel used to meet these mandates?
No, mandated volumes are claimed in the compliance market, so to avoid additionality concerns, voluntary corporate scope 3 claims (typically made through SAF certificates and book-and-claim) must come from supply beyond what the mandates require. As mandate demand grows, the pool available to voluntary buyers tightens, which is why early procurement locks in both supply and price.

Key Takeaways

• Near-term role for carbon removals: The revised Science-Based Targets Initiative (SBTi) Corporate Net Zero Standard (CNZS) v2.0 proposes requiring or recognizing interim carbon dioxide removal (CDR) targets before companies reach net zero. This shift aims to scale up the CDR industry in line with climate science and ensure companies address residual emissions earlier rather than deferring action until their net-zero target year.‍
• Revised target frameworks and increased accountability: The draft standard introduces key changes, including separate targets for scope 1 and 2 emissions, enhanced scope 3 target-setting guidelines, and the recognition of market-based mechanisms for indirect mitigation of scope 3 emissions. It also requires companies to publicly disclose transition plans and assess implementation progress against targets.‍
• Potential for stronger action on removals: While the proposed updates are a step forward, the final standard should make near-term CDR targets mandatory rather than optional and should expand to include those for projected scope 3 residual emissions, not just scope 1. Without these stronger mandates, demand for early-stage CDR investments may remain limited, potentially slowing progress toward net-zero goals.‍
• Companies should prepare now: Businesses should start integrating CDR into their climate strategies now so they are equipped to navigate procurement of high-quality removal credits in the voluntary carbon market. Preparing ahead of the final CNZS v2.0 release will help companies align with science-based decarbonization pathways and demonstrate climate leadership.

What the Latest SBTi Update Means for Corporate Climate Action

On 18 March, 2025, the Science Based Targets Initiative (SBTi) released its draft Corporate Net Zero Standard (CNZS) v2.0, significantly updating its framework for corporate net-zero target setting for the first time since 2021. The draft proposes new approaches for companies to support carbon dioxide removal (CDR) in the transition to net-zero emissions, a move that could help scale the nascent CDR industry.

This release is part of a broader revision, with key proposed updates including:

• Requiring public disclosure of transition plans after companies set targets.
• Separating targets for scope 1 and 2 emissions.
• Enhancing the scope 3 target-setting framework using an impact-based prioritization process.
• Recognizing indirect mitigation (e.g., book-and-claim commodity certificates) for hard-to-trace scope 3 emissions.
• Defining a role for emissions removals in the transition to net zero.
• Providing options to recognize company leadership in beyond value chain mitigation (BVCM).
• Assessing corporate progress against targets to bolster accountability.

While formal recognition of removals in the transition to net zero is a positive step, stronger incentives will be needed in the final CNZS to ensure companies take meaningful early action on CDR. The draft standard is open for the first of two public consultations until 1 June, 2025, with a finalized version expected to launch in 2026.

What Remains the Same From the Current Standard?

SBTi’s framework remains focused on three core requirements for companies:

• Reducing emissions year-on-year to reach an approved science-based target (SBT) by 2050 or earlier.
• Investing in beyond value chain mitigation (BVCM) in the transition to net zero to support near-term global decarbonization efforts.
• Neutralizing remaining emissions from the net-zero year (achieved after at least 90% emissions reductions) and onwards with high-quality, permanent carbon removal.

Carbon credits representing emissions reductions and removals remain ineligible for meeting reduction targets within a company’s value chain (SBTs).

What’s New in CNZS v2.0 for Carbon Removals?

Until now, the SBTi encouraged companies to invest in CDR through mechanisms such as BVCM, but has not proposed requiring removal before their target net-zero year. As a result, organizations had little clarity or incentive to invest in CDR ahead of their net-zero target date, dampening near-term demand for carbon removal and delaying the industry's growth.

The new draft changes this by proposing three options for the V2.0 Standard that address the impact of residual emissions during the transition to net zero:

• Option 1 (requirement): Companies are required to set near- and long-term removal targets, including interim CDR milestones,¹ to address projected residual emissions.
• Option 2 (optional with recognition): Companies can set and receive recognition for removal targets to address projected residual emissions.
• Option 3 (flexibility of mechanism): Companies have the flexibility to address expected residual emissions either entirely through additional emissions reductions within their value chain, entirely through removals, or via a combination of both.

Notably, all three approaches apply only to residual scope 1 emissions.

On top of these approaches, SBTi has suggested two options for the minimum durability threshold of CDR purchases in their draft standard. Removals will either need to follow a ‘like for like’ approach,² where CDR storage must match the atmospheric lifetime of residual emissions, or a gradual transition approach, where carbon storage durability increases over time.

Why Mandating CDR Matters

Mandating near-term CDR reinforces the need for immediate climate action, ensuring that carbon removals complement emissions reductions rather than being deferred until the net-zero target year. The urgency of early CDR investment is clear:

• Limiting global warming to well below 2°C above pre-industrial levels requires removing billions of tonnes (gigatonnes) of carbon dioxide annually by mid-century.
• The CDR industry is in its early stages and requires sustained investment today to scale in time.
• If companies wait until their net-zero year to purchase CDR, the supply of high-quality removal credits is unlikely to be sufficient.

As part of the proposed removal targets in Option 1 (above), the CNZS v2.0 would require companies to gradually increase CDR purchases over time, ramping up to 100% of a company’s projected residual scope 1 emissions in the net-zero target year (<10% of baseline year emissions).³

What More Can Be Done?

The potential introduction of required removal targets would be a significant and welcomed step, reinforcing the importance of near-term CDR investment to support industry maturation and climate goals. However, mandatory near-term CDR targets represent only one of three potential pathways for the V2.0 standard. Moreover, neutralization of residual emissions on the path to net zero is only proposed for scope 1 emissions. While the SBTi provides clear rationale for this,⁴ SBTi should not let the complexity of projecting scope 3 emissions be a barrier to climate change mitigation. Scope 3 emissions represent the majority of emissions from SBTi-aligned companies. Furthermore, companies with high scope 3 emissions typically have a higher ability to pay compared to their industrial counterparts with high scope 1 emissions.

If interim removal targets are made optional, and scope 3 emissions remain excluded, the demand signal for near-term CDR will be limited. The public consultation (and advice of Expert Working Groups that SBTi is convening) will be essential in determining which proposed guidance matures into the final standard; consultation feedback can be provided here prior to June 1, 2025.

How Businesses Can Prepare for CNZS v2.0

Companies aligning with SBTi’s evolving guidance should begin to integrate CDR into their climate strategy now. This means:

• Understanding their residual emissions forecast and planning early investments.
• Developing a company-specific climate strategy to incorporate CDR into their sustainability roadmaps in tandem with plans to reduce value-chain emissions.
• Engaging early in the voluntary carbon market to implement these strategies and develop procurement processes to support high-quality removal projects.
• Ensuring credibility by selecting removal projects aligned with scientific best practices.

Conclusion: A Step in the Right Direction, But More Certainty Is Needed

The CNZS v2.0 draft represents a critical turning point for corporate climate action with options to formalize the role of early CDR investment through interim removal targets for signatories. However, SBTi must take a stronger stance in the final version of the revised standard by choosing to adopt requirements for near-term neutralization (rather than leaving this optional), including projected residual scope 3 emissions in near-term CDR targets, aligning durability requirements with climate science, and defining removal quality standards to ensure these efforts drive meaningful climate impact. Organizations seeking to align with this guidance should prepare by developing a comprehensive climate strategy that accounts for science-based decarbonization pathways and recognizes the role of early-stage investment in CDR solutions.