Russian Joint Implementation credits under the Kyoto Protocol, 2009–2012
- SEI estimated that the credits undermined the EU emissions trading target by about 400 million tonnes of CO2. Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- In 2011 about 37 billion cubic metres of associated petroleum gas were flared in Russia, according to satellite-based data cited by SEI. Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- Company or project Project design document (TNK-BP companies): Baseline assumed that all utilised APG would otherwise have been flared; TNK-BP decided against a full design document in 2007 because of considerable transaction costs. Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- Researchers Stockholm Environment Institute: The baseline assumption is contradictory and it is not plausible that the project is additional. Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
Russia approved 108 Joint Implementation projects through tenders run by the state bank Sberbank, and 98 registered projects received about 266 million emission reduction units, according to Sberbank figures cited by the Stockholm Environment Institute. A 2015 SEI study found significant environmental integrity concerns for more than 80% of Russian and Ukrainian units.
98 registered projects, per Sberbank data cited by SEI. ERU prices fell from more than EUR 12 in 2010 to less than EUR 0.10 in early 2013.
Status Latest source is the August 2015 SEI study; Russian JI issuance belongs to the first Kyoto commitment period, and no court ruling or prosecution is on record.
- Russian project owners — Earned ERUs sold to foreign buyers; total revenue is not on record Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- Sberbank — Charged issuance fees as operator; about EUR 0.05 per tonne taken abroad according to Kommersant; total not on record Kommersant
- EU ETS operators — Used more than 560 million ERUs from all host countries for compliance by April 2015 Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- ERU holders — Prices fell from more than EUR 12 in 2010 to less than EUR 0.10 in early 2013 Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- Global atmosphere — SEI estimate: use of JI may have enabled global emissions about 600 million tCO2e higher than with domestic reductions Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
- EU ETS emission reduction target — SEI estimate: undermined by about 400 million tCO2 Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)
What happened
Joint Implementation (JI) is the mechanism under Article 6 of the Kyoto Protocol through which projects in a host country earn Emission Reduction Units (ERUs) that buyers can use for compliance. Russian JI procedures adopted in 2007 never became operational and were replaced in 2009. The Ministry for Economic Development and Trade acted as Designated Focal Point (DFP), and the state-owned Sberbank, the "operator of carbon units", handled project approval, registration and ERU issuance; Sberbank took on the operator role in October 2009. The first Russian Letters of Approval were issued in 2010. Russia did not join the second Kyoto commitment period and therefore cannot host JI projects in it.
Projects were approved through tenders held by Sberbank rather than case by case. Sberbank rated each project; an expert council nominated by Sberbank and approved by the DFP made recommendations, and the DFP approved the project lists. Cumulative reductions approved in each tender were initially capped at 30 million tCO2e and total Russian ERU approvals at 300 million; both limits were later removed. The third tender ran from 12 August to 5 September 2011: Sberbank received 70 applications totalling 106.58 million tCO2e, against sector limits of 30 million tonnes each for energy and industrial processes and 10 million tonnes for waste. The two earlier tenders had approved 33 projects. To receive ERUs, the project owner and the buyer needed Sberbank's approval of their Emission Reduction Purchase Agreement, and Sberbank charged issuance fees.
According to Sberbank, as cited by SEI, the government approved 108 projects with total projected reductions of around 309 million tCO2e; 98 were registered and received 266 million ERUs. SEI described Russia as the second-largest JI host, with 31% of all ERUs issued (another passage of the same paper gives 30% of ERUs in the first commitment period). All Russian projects except two, accounting for 99.8% of ERUs issued, were registered under Track 1, the host-country-controlled track without international review. In 2012, the last year of the first commitment period, Russia approved 72 projects (67% of its approved projects) and issued 210 million ERUs (79% of the issued volume). SEI's Table 19, based on UNEP Risoe data, lists 97 registered projects and 265,053 thousand ERUs, of which associated petroleum gas (APG) utilisation accounted for 22 projects and 116,840 thousand ERUs and HFC and SF6 projects for 3 projects and 53,347 thousand. Thirty-nine Russian projects (41%) were credited retroactively for more than four years and delivered 165 million ERUs, 62% of Russian ERUs.
Project RU1000353 covered APG utilisation at ten oil fields in Khanty-Mansi Autonomous Okrug, operated by four companies owned by TNK-BP. According to the project design document as summarised by SEI, the APG decision was made in 2003, construction ran from 2004 to 2012, the Letter of Approval came in May 2012 and the first issuance was on 30 August 2012; all ERUs were issued retroactively, more than 77 million. The 22 Russian APG JI projects generated 117 million ERUs, 14% of all ERUs in the first commitment period. SEI concluded that "it is not plausible that the project is additional". After 2007 Russian law required 95% APG utilisation and set penalties for flaring more than 5%; SEI reported that operators perceived the risk of penalties as limited.
The 2015 SEI working paper reviewed a random sample of 60 projects and the six largest project types, applied to the 642 projects registered as of March 2014. In the sample, additionality claims were not plausible for 73% of ERUs issued and questionable for another 12%. SEI estimated that Russia's expected surplus of about 5.7 billion Assigned Amount Units (34% of its assigned amount) let it issue ERUs from projects with limited environmental integrity. Buyers used more than 560 million ERUs from all host countries in the EU Emissions Trading System by April 2015. Commission Regulation (EU) No 550/2011 barred credits from HFC-23 destruction and adipic-acid N2O projects from the EU system from 1 January 2013.
- 2007Initial Russian JI procedures adopted; they never became operational
- 2009Revised procedures replace the 2007 ones; Sberbank becomes operator of carbon units (October)
- 2010First Russian Letters of Approval issued
- 2011Commission Regulation (EU) No 550/2011 adopted (7 June); third Sberbank tender open 12 August–5 September, 70 applications
- 2012Russia approves 72 projects and issues 210 million ERUs; first issuance for RU1000353 on 30 August
- 2013ERU prices below EUR 0.10 in early 2013; Russia stays outside the second Kyoto commitment period
- 2015SEI Working Paper 2015-07 published (August)
What was said
“about three-quarters of JI offsets are unlikely to represent additional emissions reductions”
“significant environmental integrity concerns for more than 80% of ERUs from Russia and Ukraine”
“Like Ukraine, Russia could afford to issue large numbers of ERUs from projects with very limited environmental integrity because of its large expected AAU surplus”
“a subjective judgment of the authors based on the limited information publicly available”
“makes it impossible to check whether substantial changes were made e.g. to the monitoring plans”
“it is not plausible that the project is additional”
“considerable transaction costs”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
Earlier contracts had no legal force because the units are state property; adapting them was Sberbank's problem.
KommersantDisagreed that the earlier contracts lacked legal force and warned that a 'special path' could harm the market.
KommersantThe new decree gave buyers an option to cancel ERU purchase contracts, which they said undermined earlier deals.
KommersantBaseline assumed that all utilised APG would otherwise have been flared; TNK-BP decided against a full design document in 2007 because of considerable transaction costs.
Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)The baseline assumption is contradictory and it is not plausible that the project is additional.
Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)Russia generated 30% of all ERUs in the first commitment period.
Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)98 registered projects and more than 266 million ERUs, 31% of all ERUs issued.
Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)97 registered projects and 265,053 thousand ERUs.
Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin)How it looked
Shown
- Sberbank head German Gref promised in 2011 to place about EUR 600 million of potential Kyoto money from Russian projects quickly, plus EUR 1.4–1.9 billion in 2012; Kommersant described these as forecasts.Kommersant, 6 October 2011 · Kommersant
- Having entered the Kyoto Protocol, Russia should get some investment out of it.President Dmitry Medvedev, June 2011, as quoted by Kommersant · Kommersant
- Success of third-tender applications would depend on the quality of documents, not on the tender quota.Sberbank (Vsevolod Gavrilov, head of energy-saving and environmental projects), September 2011 · PRIME (citing RIA Novosti)
Recorded
- Sberbank figures cited by SEI: 108 approved projects (around 309 million tCO2e projected), 98 registered, 266 million ERUs.
- Track 1 (no international review) covered all registered projects except two, 99.8% of ERUs issued.
- In SEI's sample, additionality claims were not plausible for 73% of ERUs issued and questionable for another 12%.
- Bureau Veritas Certification determined and/or verified 56% of all JI projects, which generated 78% of ERUs; in the sample, 77% of the projects it determined made implausible additionality claims (SEI).
- ERU prices fell from more than EUR 12 in 2010 to less than EUR 0.10 in early 2013 and stayed well below EUR 0.50.
- More than 560 million ERUs from all host countries had been used in the EU ETS by April 2015; 132.8 million international credits (66.4 million CERs, 66.4 million ERUs) were exchanged in phase three by 30 April 2014.
- Before Sberbank's entry, ERU contracts were priced at USD 2–3 per tonne, according to Oleg Pluzhnikov of the Ministry of Economic Development.
Who gained
Reached nature or the ground
Gained elsewhere
Responses on record
- Sberbank (September 2011): Third-tender applications would be reviewed under a new, simplified procedure; success would depend on the quality of documents, not on the tender quota (Vsevolod Gavrilov). · PRIME (citing RIA Novosti)
- Ministry of Economic Development (January 2011): Unit prices should be close to European secondary-market prices with some discount; earlier contracts transferring ERUs to foreign companies had no legal force because the units are state property (Oleg Pluzhnikov). · Kommersant
- VTB (2011): Lobbied to end Sberbank's exclusive operator status and described this as normal competition (Andrey Kostin). · Kommersant
In court and with insurers
Lawsuits and rulings
Insurers
What nature saw
Nature's report opens this page. Below: further outcomes measured on the ground.
What we don't know
Nature
- Disputed Whether the APG utilisation at ten TNK-BP fields (RU1000353) was additional
Court
- None on record No court case on record.
Accounts
Record
- None on record None on record: total revenue earned by Russian project owners or total fees collected by Sberbank.
- Not disclosed Not disclosed: a breakdown of which EU ETS operators surrendered Russian ERUs; the European Commission states that phase-three use per compliance year cannot be traced.
- Insufficient Insufficient: the Russian registry website kept only the latest versions of documents, some verification and monitoring reports were unavailable and many documents were only in Russian; holding and transaction data could not be queried as Decision 13/CMP.1 requires (SEI).
- None on record None on record: Letters of Endorsement; Russia did not issue them, which SEI says makes timeline-based additionality checks harder.
- Disputed Figures differ: SEI gives Russia's share of ERUs as 30% (p. 24) and 31% (p. 80), and issued units as 265 million (UNEP Risoe table) and 266 million (Sberbank and UNFCCC data).
- None on record None on record: a response from the Russian government to the SEI findings.
- None on record None on record: a company response from TNK-BP to the SEI assessment of RU1000353.
- Insufficient Insufficient: the design document for RU1000353 gives limited information, and bundling ten fields makes additionality assessment of each field impossible (SEI).
- None on record None on record: a court ruling or prosecution concerning Russian JI.
Did the harm stop?
Russia did not join the second Kyoto commitment period and cannot host JI projects in it (SEI).
Who paid?
None on record.
Sources
Government and regulators
- Commission Regulation (EU) No 550/2011European Union · 2011-06-07
- Number of international credits exchanged totals 132.8 millionEuropean Commission · 2014-05-02
Press and investigations
- VTB will challenge the monopoly on air (translated title)Kommersant · 2011-10-06
- Sberbank will review applications from the third 'Kyoto' tender under a simplified procedure (translated title)PRIME (citing RIA Novosti) · 2011-09-21
- Russian industry paid to increase emissions under UN carbon credits schemeCarbon Brief · 2015-08-24
Researchers
- Has Joint Implementation reduced GHG emissions? Lessons learned for the design of carbon market mechanisms (Working Paper 2015-07)Stockholm Environment Institute (Kollmuss, Schneider, Zhezherin) · 2015-08
Connected cases
- HFC-23 and SF6 Joint Implementation projects at KCKK Polymer and HaloPolymer Perm Russia · 2008–2015
- Stockholm Environment Institute (SEI) (Research institution) — here: Authors of the 2015 Joint Implementation study; there: Authors of the Nature Climate Change paper and working paper
- Vitol (Company) — here: Swiss trader named in contracts with two Russian plants; there: Swiss trader named in contracts for ERUs from the two plants
- Bureau Veritas Certification (Company) — here: Auditor of 56% of JI projects; there: Verifier who confirmed the revised documentation
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Regulation 550/2011 banning HFC-23 credits from 2013
- UN Framework Convention on Climate Change (International organisation) — here: Kyoto Protocol Joint Implementation framework; there: Kyoto Protocol Joint Implementation framework
- Kerch Strait storm, November 2007: Volgoneft 139 fuel-oil spill and sulphur-ship sinkings Russia · 2007–2018
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Post-disaster needs assessment with UNEP
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Government claimants; military clean-up reported
- Khimki forest and the M11 Moscow–St Petersburg toll motorway (km 15–58) Russia · 2007–2025
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Letter to an MEP on EIB and EBRD financing conditions
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Land-transfer order; Medvedev and Ivanov statements
- Russia's national carbon-unit system under Federal Law 296-FZ Russia · 2021–2026
- Ministry of Economic Development of the Russian Federation (Government) — here: Designated Focal Point for Joint Implementation; there: Approves international-cooperation projects; reports registry figures
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Adopted Decree No. 234 of 2026
- Sakhalin carbon-neutrality experiment under Federal Law 34-FZ Russia · 2022–2028
- Ministry of Economic Development of the Russian Federation (Government) — here: Designated Focal Point for Joint Implementation; there: Ministry responsible for the experiment's rules
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Set the payment rate; federal law 34-FZ
- 62% of UK paraquat exports since 2015 went to poorer countries, analysis finds United Kingdom · 2015–2024
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Institution whose paraquat approval the EU court annulled
- AdBlue cartel (Daimler, BMW, VW) Germany · 2009–2014
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Competition authority that issued the decision
- Arctic Sunrise seizure at the Prirazlomnaya platform: ITLOS bond, PCA arbitration, 2019 settlement and ECtHR judgment Russia · 2012–2023
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Respondent; did not appear before ITLOS or the PCA tribunal; settled in 2019
- Baikal Natural Territory: expertise exemptions and clear-cutting rules Russia · 2020–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Sets the list of objects under Article 25.1(3); Deputy Prime Minister statements
- Baikal omul industrial fishing ban (from 2017) Russia · 2016–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Funded releases, hatchery and research vessel
- Baikalsk Pulp and Paper Mill: closure and waste clean-up Russia · 1966–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Decree No. 1; funded wages and clean-up; named contractors
- Bottom trawling in European marine protected areas European Union · 2017–2026
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Proposed the non-binding phase-out target
- Bou Craa phosphate mine and Morocco green hydrogen in Western Sahara Western Sahara (controlled in large part by Morocco) · 1975–2026
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Negotiated the EU-Morocco arrangements
- Cosmos 1408 anti-satellite test (Russia) Russia · 2021
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Conducted the test
- End-of-life vehicle recycling cartel (EU carmakers, ACEA) European Union · 2002–2017
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Regulator
- ESPO oil pipeline rerouted away from the Baikal shore (2006) Russia · 2005–2008
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: President ordered the reroute; Prime Minister approved the route
- EU banned-pesticide exports European Union · 2018–2026
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Made the 2020 pledge; reported to have withdrawn it in 2026
- EU bans three neonicotinoid pesticides outdoors in 2018; Turkey follows in part European Union · 2018
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: adopted the outdoor ban
- EU Carbon Border Adjustment Mechanism burden on Turkish exporters Turkey · 2026
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Regulator of CBAM
- EU Deforestation Regulation delays and trade pressure European Union · 2022
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Proposer of simplification review
- EU taxonomy hydropower exemption and California large hydro exclusion European Union / United States · 2002–2021
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Author of the taxonomy rule
- Germany agreed €2.6bn and €1.75bn coal exit payments to RWE and LEAG Germany · 2019–2023
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: approved the RWE payment
- Hardwood logging in the Russian Far East and exports to China Russia · 2001–2023
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Officials' statements 2020 and 2023
- Lliuya v RWE Peru · 2025
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Approved the German compensation payment to RWE (13 December 2023)
- Norilsk diesel spill Russia · 2020–2023
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Declared federal emergency; federal budget received the award
- Nornickel Sulphur Programme: SO2 targets, spending and measured emissions at Norilsk and Kola Russia · 2015–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Resolution No. 353 of 12 March 2022; emissions-quota experiment postponed
- Russia's 1 January 2022 ban on exports of unprocessed softwood and valuable hardwood logs Russia · 2020–2025
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Issued the instruction, duties and quotas
- Russia's forest-fire control zones and federal fire-service funding Russia · 2015–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Reserve-fund Order No. 2740-r (2026); Decree No. 382 issued by the President
- Russian forest-climate projects: RUSAL fire-protection units and Sakhalin larch planting Russia · 2019–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Federal Law 492-FZ and reserve-account rules
- Sakhalin-2 and Sakhalin-1 in 2022: transfer decrees, the ecological-audit deduction clause and write-downs Russia · 2022–2026
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Decree No. 416 and the orders on the stake sale
- Sakhalin-2: 2006 approval revocation, Gazprom stake purchase, 2009 damage-claim settlement and lender exits Russia · 2005–2009
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: President Putin present at the December 2006 protocol
- Siberian wildfire season of 2019: Krasnoyarsk, Irkutsk and Yakutia Russia · 2019
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Prime Minister ordered arson checks (1 August 2019)
- Sochi 2014 Winter Olympics: environmental pledges and the Mzymta valley Russia · 2007–2018
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Host government; Putin and Kozak statements
- Soviet whaling catches and the reports to the IWC, 1948–1979 Russia · 1948–1994
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Supplied original catch data to the IWC Scientific Committee in 1994
- Spain: environmental liability financial guarantee (EU Directive Art. 14) Spain · 2004
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Evaluated the directive and reported on mandatory financial security
- US withdrawal from 66 international bodies and Paris/UNFCCC United States · 2025–2027
- UN Framework Convention on Climate Change (International organisation) — here: Kyoto Protocol Joint Implementation framework; there: Treaty secretariat the US is leaving
- Used cooking oil and POME biofuel certification: fraud allegations (ISCC, EU/UK) European Union · 2016–2025
- European Commission (Public authority) — here: Regulation 550/2011; EU ETS credit data; there: Regulator; anti-dumping duties; recognition of ISCC
- Usinsk pipeline spill (Komi, 1994) and the World Bank and EBRD emergency loans Russia · 1994–2004
- Government of Russia (Government) — here: Approved projects through the Designated Focal Point; there: Borrower of both loans; on-lent them to Komineft