Brazil’s Ministry of Finance and China’s Ministry of Ecology and Environment have initiated strategic bilateral discussions to establish a sovereign carbon trading framework ahead of COP31. The primary objective of these negotiations, centered in Wuhan, involves exploring the potential transfer of Brazilian Internationally Transferred Mitigation Outcomes (ITMOs) under Article 6.2 of the Paris Agreement to Chinese counterpart entities. This initiative builds on existing bilateral engagements through the China-Brazil High-Level Coordination and Cooperation Committee, positioning two major emerging carbon markets to create a formal cross-border mechanism for climate finance and market interoperability.

The central challenge addressed in these negotiations concerns the structural integration of cross-border carbon transfers within rigid national mitigation targets and regulatory systems. Brazil is currently operationalizing the Brazilian Emissions Trading System while establishing strict national export limits, including a proposed 50 million tonne carbon dioxide equivalent cap for international transfers between 2031 and 2035. Conversely, China is expanding its national emissions trading scheme to encompass key industrial sectors like steel, cement, and primary aluminum, creating high demand for compliance-aligned assets. Navigating these overlapping regulatory architectures requires establishing robust corresponding adjustments to eliminate double-counting risks while protecting Brazil’s ability to achieve its own Nationally Determined Contribution.

To address these accounting and market integration hurdles, both nations are establishing rigorous baseline requirements and operational criteria for high-integrity credits. Brazil’s proposed regulatory framework mandates that all exported mitigation outcomes receive explicit authorization from its national designated authority and adhere strictly to standardized monitoring, reporting, and verification methodologies. Furthermore, through the Open Coalition for Regulated Carbon Markets, Brazil, China, and European partners are coordinating to align technical standards across emissions accounting, project eligibility criteria, and offset protocols, ensuring that carbon removal and reduction activities meet high integrity thresholds prior to cross-border transfer.

The successful implementation of this bilateral framework by COP31 would establish a formal channel for international climate finance into Brazilian decarbonization efforts while supplying China’s expanding compliance market with verified mitigation assets. By setting clear operational guidelines for Article 6.2 transfers between large emerging economies, the agreement provides a scalable model for cross-border carbon accounting. Crucially for biochar producers, this framework creates a regulated pathway for durable carbon dioxide removal projects to generate exportable, high-integrity ITMOs with secured corresponding adjustments.


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