Are Nature-Based Removals Being Sidelined?

The draft standard under Article 6.4 (A6.4) of the Paris Agreement, addressing how to manage non-permanence and reversal risks for carbon sinks, has sparked industry concerns. Both IETA and UNEP officials warn that under the current text, nature-based carbon removals such as forests and soils may face significant barriers to inclusion in the mechanism, potentially undermining global forest carbon investment and confidence.

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Key Controversy

🌿The draft proposes two technical pathways, strengthening risk mitigation, replacement, and remediation mechanisms. Industry stakeholders fear these measures far exceed voluntary market practices in both stringency and cost.

IETA’s Position

🏛️The current design is “overly stringent,” imposing high buffer and replacement obligations on land/forest projects, which could exclude nearly all nature-based removals from A6.4.

🏛️IETA calls for a redesign and a renewed public consultation.

UNEP’s View

Gabriel Labbate, Head of UNEP’s Climate Mitigation Unit, warns that under the current draft, forest-based approaches would be “almost impossible” to implement under A6.4, weakening the global ability to leverage forest carbon sinks to combat climate change.

Emerging Factors Seen

💡“Rules feedback” between A6.4 and the voluntary market.

💡Financial tools forced to innovate — insurance + buffer pools + replacement procurement models could accelerate.

💡Dynamic buffer rates and performance segmentation to better align risk and cost.

💡Digital MRV with reversal response SLAs.

💡Integration with corporate climate disclosure to enhance market transparency.

Suggested Middle Ground Approaches

🌲Establish a transitional window for nature-based removals, piloting dynamic buffers and layered insurance.

🌲Differentiated access: lower buffers for lower-risk projects.

🌲Clearly define reversal responsibility-sharing mechanisms.

🌲Complementarity with A6.2 through bilateral pilot projects.

Timeline & Next Steps

📅15 July 2025: Draft released for public comment.

📅4 August 2025: Deadline for submissions.

🚀Possible further review before COP30.

Conclusion

Regardless of the final outcome, adjustments to A6.4 are more than a methodological choice — they will shape whether billions of dollars in capital can flow smoothly into forest and land carbon markets. The true challenge is balancing “uncompromising credibility” with “scaling up at pace.”