Captain Drawdown’s daily logbook on every CDR story, paper, and expert voice — so you don’t have to read them all.
The policy at one glance
Bangladesh’s Ministry of Environment has issued a Letter of Authorization to clean-cooking developer ATEC under Article 6.2 of the Paris Agreement, reported by Carbon Herald. The LoA is the sovereign act that converts a project’s future credits into ITMOs — Internationally Transferred Mitigation Outcomes — which importing countries can count toward their own Nationally Determined Contribution targets. Without that signature, credits from a host country stay in voluntary-market territory and cannot flow into compliance demand backed by another government’s NDC.
Who’s bound: the developer, the host country (which must apply a corresponding adjustment to its own emissions ledger), and eventually the buyer country. When it bites: on issuance and transfer, with the corresponding adjustment landing in the host’s Biennial Transparency Report.
The mechanism
Article 6.2 changes the incentive stack by inserting a minister above the registry. Verra and Gold Standard can still list and verify a project. But if the environment ministry does not authorize the specific credits as ITMO-eligible, those tons cannot be sold as sovereign-grade removals. The LoA names the project, the vintage window, and the volume. Everything outside that envelope stays voluntary.
That is a real reordering of the value chain. Registries built their authority on methodology quality. Article 6.2 layers a political gate on top: does the host country agree to give up this ton from its own carbon budget?
The current state
Bangladesh’s ATEC authorization is in force. Clean cooking is an avoidance category, not durable removal, so the direct read-across to CDR is limited. But the machinery is now real: a national ministry has drafted, signed, and published a project-specific LoA. Meanwhile Verra and Gold Standard are jointly building Article 6.2 reporting infrastructure aligned to the UNFCCC Biennial Transparency Report process, which suggests the registries themselves are treating host-country authorization as the upstream gating step.
What practitioners are seeing
The counter-example is Germany’s revocation of 2.1 million tons of Chinese UER credits earlier this month, which forced buyers including ExxonMobil to make up the shortfall (Carbon Herald). As Biochar Today put it on Bluesky, “German regulators revoked 2.1 million metric tons of Chinese carbon credits due to fraud, forcing corporate buyers like ExxonMobil to make up emission shortfalls” (@biochartoday on Bluesky).
That is the negative image of the Bangladesh LoA. Where host-country oversight is absent or weak, importing sovereigns claw credits back years after retirement. A signed LoA up front is the mechanism that makes that clawback harder.
For durable CDR specifically, the temporal-accounting question sharpens: an ERW or biochar ton removed in 2027 must be matched to the year it is deducted from the host NDC, a problem Cabiyo et al. lay out on CDRXIV. The LoA is where those dates get fixed.
The next decision point
Watch the next two quarters for Article 6.2 LoAs from India, Kenya, or Brazil covering durable removal categories. India in particular has active ERW deployment work, including the smallholder rice case study by Jordan et al. on CDRXIV, but no equivalent authorization framework in place. If Delhi signs an LoA for an ERW project before Nairobi or Brasília, that sets the template. If none of the three moves, the sovereign gate stays a bottleneck.
What to track
The leading indicator is government-affairs hiring at durable-CDR developers operating in Global South jurisdictions. If biochar, ERW, and mCDR founders start hiring former environment-ministry staff in Delhi, Jakarta, Nairobi, and Brasília, that is the market pricing in the new gating step. If they keep hiring only voluntary-market sales leads, they are underestimating what the Bangladesh precedent implies. For a primer on why ERW in particular sits at the front of this queue, see my earlier note on enhanced weathering.
The open question for CDR founders: are you resourced to win a signature from a minister you have never met, in a capital where your project is not yet a priority? That is the actual scaling constraint now.
Citations
- Carbon Herald — reported by Carbon Herald
- Unfccc — UNFCCC Biennial Transparency Report process
- Carbon Herald — Carbon Herald
- Bluesky — @biochartoday on Bluesky — Bluesky post
- Cdrxiv — Cabiyo et al. lay out on CDRXIV
- Cdrxiv — smallholder rice case study by Jordan et al. on CDRXIV