Eco Sustainability’s Submission to Singapore’s Draft Guidance for the Voluntary Carbon Market

Eco Sustainability is pleased to submit our formal response to Singapore’s public consultation on Annex A – Draft Guidance on the Voluntary Carbon Market, issued by the National Climate Change Secretariat, Ministry of Trade and Industry, and Enterprise Singapore. 

To learn more, please visit this link.

For our submission, please download below.

Singapore VCM Public Consultation (Eco Sustainability).pdf

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To:

NATIONAL CLIMATE CHANGE SECRETARIAT (NCCS)

MINISTRY OF TRADE AND INDUSTRY (MTI)

ENTERPRISE SINGAPORE (EnterpriseSG)

Date: 20 Jul 2025

PUBLIC CONSULTATION FEEDBACK ON ANNEX A - DRAFT GUIDANCE ON VOLUNTARY MARKET

Dear Sir/Madam,

We are writing to submit our feedback on the draft Annex A – Guidance on the Voluntary Carbon Market, as part of the ongoing public consultation process.

Eco Sustainability Pte. Ltd. is a Singapore-based company with a presence across the ASEAN region. As project developers ourselves, we are actively engaged in originating and implementing carbon reduction projects throughout Southeast Asia, working closely with local communities, governments and verifiers on the ground.

We are submitting this response because, as a Singapore-based company active across ASEAN and involved in project development, we are closely engaged with the realities of the voluntary carbon market from the supply-side perspective. This gives us a grounded understanding of important issues such as equity, traceability and benefit-sharing - especially in the ASEAN context, where local capacity, regulatory readiness and community dynamics vary widely.

We fully support Singapore’s leadership in shaping a high-integrity, globally respected carbon market. In this submission, we have offered practical and bold recommendations to strengthen the credibility, fairness and transparency of the voluntary carbon market framework.

Thank you for the opportunity to contribute to this consultation. We welcome further engagement and are happy to elaborate on any of the points raised.

If you have any queries or require clarification of this submission, please contact TENG KY-GAN, Managing Director of Eco Sustainability at kygan.teng@ecosustainability.group .

Yours sincerely,

ECO SUSTAINABILITY

TENG KY-GAN

Managing Director

Clarification on Reporting of Corresponding Adjustments (CA) – Section 2.2.4 (with reference to 2.2.3 and Footnote 8)

While Section 2.2.3 and Footnote 8 helpfully clarify that Corresponding Adjustments (CA) are not required for voluntary use, Section 2.2.4 reintroduces ambiguity by suggesting companies should “use their judgement” in deciding whether to purchase CA-backed credits. In practice, many credits originate from countries without CA infrastructure - meaning CA is not even possible. The current phrasing may inadvertently imply a discretionary choice, when in fact buyers are constrained by host country policy.

We recommend the guidance more clearly affirm that non-CA credits remain valid and legitimate for voluntary offsetting where host country authorization is not applicable, and that integrity can still be ensured through proper registry management and retirement protocols. Additionally, a standardised disclosure format (e.g. registry, project ID, CA status, vintage) aligned to ISSB or GHG Protocol guidance would improve transparency and consistency.

Ethical Oversight of Project Developers – Sections 2.1.3, 3.3.1

The guidance rightly addresses the technical quality of carbon credits but remains silent on a deeper issue: who controls the projects, who profits and whether carbon finance is reinforcing global inequality under the guise of climate action.

Singapore-based buyers must be held to a higher standard - not just in what credits they buy, but whose pockets they’re filling. Without ethical guardrails, Singapore risks enabling a system where powerful financial players extract climate value from poorer countries, while local communities see little benefit.

We recommend the following additions:

• Mandatory disclosure of project ownership and financing: Companies should be required to declare the full origin of the project, including developer identity, country of registration and ultimate financiers or beneficiaries. This avoids scenarios where carbon revenue quietly flows back to powerful, profit-maximising interests with no local accountability.

• Red-flag screening for climate hypocrisy: Buyers should exercise caution - or be restricted - from purchasing credits originating from countries that impose carbon border taxes (such as CBAM) while underdelivering on their international climate finance obligations. These same countries often have a long history of extracting environmental and social value from lower-income nations without meaningful restitution. Allowing them to dominate project development risks turning the voluntary carbon market into a tool for outsourcing responsibility while monopolising profit.

• Redefine quality to include economic justice: If Singapore wants to lead with integrity, its guidance should define high-quality credits as those that not only reduce emissions, but ensure fair value distribution, local co-benefits and transparency over where the money flows. Otherwise, the carbon market becomes just another way for the rich to outsource responsibility and pocket the rewards.

Address Profit Arbitrage in Carbon Credit Transactions – Related to Sections 3.3.1, 3.4.1

The current guidance rightly emphasises credit quality and disclosure - but misses a critical blind spot: the profit-driven arbitrage model emerging around carbon credits, where traders and companies buy low from vulnerable communities and sell high into premium markets, capturing margins while adding no climate value.

If carbon credits are being used as financial instruments, then companies profiting from resale - including Singapore-based brokers, exchanges, or fund vehicles - should be held to greater disclosure and accountability standards.

We recommend:

• Require resale disclosure: Companies should disclose when credits are purchased for resale or speculation, not for retirement. Singapore’s guidance should distinguish between climate use and financial commodification.

• Disclose profit margins from arbitrage: If a company profits from price spreads on carbon credits, it should be required to disclose the source project, resale price, and whether any value was added (e.g. bundling, rating, or risk-sharing). Climate mitigation should not become just another spread trade.

• Introduce fair share principles: Singapore could lead in encouraging “fair pricing” principles - for instance, ensuring a minimum % of credit value flows back to project hosts or communities, especially when credits are flipped for high-margin sales.

Without such safeguards, the carbon market risks replicating extractive dynamics - where the climate benefit is born in the Global South, but the financial gain is captured in trading desks far removed from impact.

Introduce a Buyer Integrity Rating – Related to Sections 2.1.3, 3.3.1

The current draft guidance evaluates carbon credit quality at the project level, but does not adequately assess the integrity and credibility of the buyers themselves. 

A company’s ability to buy carbon credits should be assessed in the context of its broader climate behaviour. Otherwise, the system rewards large emitters who buy offsets while delaying real change - and penalises more responsible companies who disclose more and use credits sparingly.

We propose the introduction of a “Buyer Integrity Rating” framework that considers:

• Absolute and per-unit emissions (not just reductions claimed).

• Consistency between claims and behaviour, e.g. whether the company is still expanding fossil fuel operations while buying offsets.

• Reliance ratio on offsets vs actual abatement.

• Previous record of transparency, greenwashing, or regulatory penalties.

Singapore can lead by recognising that carbon market credibility is not just about what is being bought - it is also about who is buying and whether they’ve earned the right to make those claims.

A high-integrity project loses its moral and environmental value when it is used to clean up the image of a buyer with no genuine commitment to decarbonisation.