Subject: Urgent Suspension and Investigation of the First Article 6.4 Credit Issuance
To the Paris Agreement Crediting Mechanism Supervisory Body (PACM SB):
We, the undersigned civil society organisations, networks and other stakeholders, call on the PACM Supervisory Body to immediately suspend any further issuance, transfer or use of credits associated with PoA 10471, and undertake an independent and comprehensive assessment of the project and the process by which it was approved.
PoA 10471 is an “improved biomass cookstoves” project in Myanmar, coordinated by the South Korean Climate Change Center (now Climate Change Foundation), and was the first project to be cleared for credit issuance under Article 6.4 of the Paris Agreement, in February 2026. Originally a Clean Development Mechanism (CDM) project, this first credit issuance is a crucial test of how the Article 6.4 carbon crediting mechanism, promoted as offering the highest environmental integrity, transparency and social safeguards, is being implemented in practice.
Serious concerns have been raised about the project’s environmental integrity, monitoring, verification, and the effectiveness of safeguards and stakeholder participation, especially given Myanmar’s radically changed political circumstances following the February 2021 military coup attempt and subsequent wide-spread conflict, involving serious war crimes and human rights violations.
Since the attempted coup, the project continued operating in regions where widespread violence, displacement, and human rights abuses by the military junta and its associated armed groups occurred. The Dry Zone Greening Department and other regime authorities, still under military control today, were responsible for implementation and monitoring throughout all but one of the 17-month crediting period that has been cleared for credit issuance.
Although such financial information has not been publicly disclosed, it is therefore very likely that the Myanmar military junta—accused of widespread crimes against humanity and responsible for inflicting untold harm on civilian populations—has benefited and will continue to benefit financially from funding arrangements and the transfer of credits associated with this project, first under the CDM and now under Article 6.4. The risk is particularly high because the ministry ultimately responsible for implementing the project, the Ministry of Natural Resources and Environmental Conservation (MONREC), is a major income earner for the junta, bringing in revenue through the illegal trade of timber, minerals, gems and other resources.
The project’s monitoring documentation failed to acknowledge these changed conditions or their impact on mitigation outcomes. Verification was conducted remotely, with no site inspections due to security risks, and relied on just 22 online interviews (only two with women) despite nearly a million stoves distributed. This raises doubts about the adequacy of evidence supporting the claimed emissions reductions.
Independent analyses also estimate that the project was over-credited by a factor of 14 under the CDM, and still by a factor of seven under Article 6.4—due to questionable baseline assumptions and calculation methods. However, the analysis assumes implementation under ideal conditions, which were not present. Furthermore, assumptions about greenhouse gas reductions from improved cookstoves, based on lower use of fuel wood by households in the global South, are inherently problematic as long as the burning of wood by energy companies and households in the global North is treated as carbon-neutral.
Finally, there are serious doubts over the integrity of stakeholder participation and safeguards under conflict conditions, and the project falls well short of the principles enshrined in the UNFCCC’s Gender Action Plan (GAP). Women and girls are presented as project beneficiaries, but a lack of air quality or fuel use monitoring means that no evidence is provided for this. Despite credit generation relying entirely on their unpaid labour, women and girls also had limited participation in project monitoring and decision-making. Of 231 households surveyed during the monitoring process, 80% were conducted with male heads of households. Even more significant is the fact that women and girls were subjected to violence and displacement in project areas, perpetrated mainly by the military junta ultimately responsible for project implementation.
The Article 6.4 Supervisory Body will meet for its 23rd meeting (SBM 023) from 5–9 October in Bonn, Germany. This meeting provides an immediate opportunity for the Supervisory Body to address these concerns. SBM 023 is scheduled to consider matters relating to the activity cycle, issuance and registry, including work on post-issuance arrangements and the rules governing the mechanism.
We therefore urge the Supervisory Body to:
- Immediately suspend further issuance and use of PoA 10471 credits;
- Commission an independent, comprehensive assessment of the project’s methodology, monitoring, safeguards, and the impact of post-coup circumstances, as well as the process by which this project was approved under Article 6.4 in the first place;
- Make the assessment findings and responses public;
- Take all necessary corrective action.
Signed by:
Global Forest Coalition
Biofuelwatch
Myanmar Policy Institute
Plan 1.5
AbibiNsroma Foundation
Acción Ecológica
Action Jeunesse pour le Développement (AJED-Congo)
AIH Colombia
Agent Green
ANGRY Alliance (FS Working group)
Amis de l’Afrique Francophone- Benin (AMAF-BENIN)
Armenian Forests Environmental NGO
Asociación Indígena Ambiental (AIA)
Association des agriculteurs sans frontières
Association des jeunes pour la paix et la démocratie ASJPD asbl
ASSOCIATION JEUNES AGRICULTEURS (AJA)
Banka Earth Foundation
Barokupot Ganochetona Foundation -BGF
Bio Vision Africa (BiVA
Biomass Action Group
Biomass Action Network’s Asia Pacific Working Group
Blue Dalian
Blue Mountains Biodiversity Project
Brot für die Welt, Germany
CEDENMA
Censat Agua Viva
Center for International Humanitarian Law and Human Rights(HLHRCI)
Centro de Desarrollo Ambiental y Humano o
Centro de Estudios HEÑÓI
Centre for Environmental Justice
Centre pour la Justice Environnementale – Togo
China Environmental Paper Network
Civil Society Independent Forest Monitors
Climate Action Network Latin America (CANLA).
Climate Communications Coalition
Colectivo VientoSur
COECOceiba Amigos denla Tierra Costa Rica
COLECTIVO CASA
Comité Schone Lucht
Comrades Of Rohingya Youth
COMMUNITY ACTION FOR HEALTH AND DEVELOPMENT
Community Development initiative
Community Initiatives for Development in Pakistan-CIDP
Community Legal Education Center (CLEC)
Congo Basin Conservation Society CBCS network
CONGO FOR AGRICULTURE
Corporate Accountability and Public Participation Africa
Corporate Europe Observatory
Dívida pelo Clima – capítulo Brasil
DISABILITY PEOPLES FORUM UGANDA
Earth Thrive
EcoNexus
Ei polteta tulevaisuutta
Environmental Investigation Agency
ETC Group
F3E
FASE – Solidariedade e Educação
FECOFUN
Fern
Focus on Women
FoE Japan
Fórum Carajás
Forum Ökologie & Papier
Fossil Free Greater Manchester
Frente Nacional Ecosocialista por la Vida (FRENESVI)
Freundeskreis Peru Amazonico e.V
Fundaexpresion
Fundación Chile Sin Ecocidio
Global Campaign to Demand Climate Justice (DCJ)
Global Campaign to Demand Climate Justice – Latin America and Caribbean, DCJ-LAC
Global Justice Ecology Project
Green Advocates
Green Finance Observatory
Green Longjiang
Greater Equitable Measures (GEM) – Malaysia
Health of Mother Earth Foundation (HOMEF)
Hidrodefensa
IBON International
Independent
Instituto para el Futuro Común Amerindio IFCA
International Women’s Development Agency (IWDA)
Juventud Ecologista en Acción
Korean Federation for Environmental Movement (KFEM)
Landelijk Netwerk Bossen- en Bomenbescherming
Leefmilieu
Link-AR Borneo (Institute for Reasearch & Advocacy of Borneo)
MAÏSHA NA MAZINGIRA
MenaFem Movement
Movimentu Rosas Mean
MWANAMKE FUND
National association of professional Environmentalists (NAPE)
National Forum for Advocacy Nepal (NAFAN)
National Sudanese Women Association
NaturelCD
North American Climate, Conservation and Environment(NACCE)
Observatorio de Derechos Humanos y Naturaleza
Oilwatch International
PIDP
Pikunche koyagtun
Pivot Point
Plataforma Latinoamericana y del Caribe de Justicia Climática
Programme Intégré pour le Développement de Peuples Autochtones Pygmées PIDP/SHIRIKA LA BAMBUTI
Protect the Forest
Reaccion Climatica-Bolivia
Reacción Climática
Red Dominicana de Estudios y Empoderamiento Afrodescendiente -RedAfros-
RedAFROs
RECODEF Sénégal – ex FEMNET
Rettet den Regenwald – Schweiz
Rettet den Regenwald e.V. – Rainforest Rescue –
Rohingya Maìyafuìnor Collaborative Network
Rural Integrated Center for Community Epowerment -RICCE
Sahabat Alam Malaysia (FoE Malaysia)
Salva la Selva, España
Save Estonia’s Forests
Sinatsisa Lubombo Women and girls Empowerment organization
Stay Grounded Network
Sukaar Welfare Organization
Taiwan Environmental Protection Union
The Association for Women’s Rights in Development (AWID)
Trend Asia
War on Want
We Woman Lanka Network
WILPF UK
Windrose Fund
Women’s Earth and Climate Action Network
Women Rising Radio
WhatNext?
Youth Food Network RDC Asbl
ZAMSOF
