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EPA's Partial Repeal of the Carbon Pollution Standards is published and effective 16 November; ADM brings 800kt/yr of Puro-certified removals toward issuance

Trading-day outlook

Also on the calendar: CARB's weekly LCFS credit transfer report today (see 1b), and CFTC Commitments of Traders on 25 September for positioning in the carbon complex.

AS OF 22 September 2026, 13:55, MDT (Calgary, UTC-6). Futures marks are today's close, marked off the most liquid futures contract by open interest, Dec26. Auction clearings and regulator prints carry their own dates, which are stated on each. Currency is named on every price.

1. North America

1a. Compliance carbon

California-Quebec (CCA) — Mark: USD 31.51 (2026-09-22, Most liquid futures settlement (Dec26), CCA V26, settlement observation), −0.9% vs prior same-basis mark. Primary print USD 32.48 (2026-08-19, Auction 48, current-vintage settlement price).

What moved: The Dec26 mark is the softest leg in the compliance complex today and sits roughly 3.0% below the 19 August clearing — a modest discount, consistent with post-auction repricing rather than a data question.

Why: The amended 17 CCR 95841 Table 6-2 took effect 1 September, removing 118.3 Mt from the 2027–2030 budgets; our forward rows run deficit throughout (−27.0 Mt 2027 deepening to −84.2 Mt 2030). Those rows are budget minus emissions and carry no private bank, so read them as a supply path, not a scarcity call.

Desk view: Judgment — constructive CCA on the curve, neutral on the front; the futures discount to the last auction is too small to fight and offsets under AB 1207 sit inside the cap unmodelled.

Washington (WCA) — Mark: USD 39.50 (2026-09-22, Most liquid futures settlement (Dec26), WCA V26, settlement observation), −2.5% vs prior same-basis mark. Primary print USD 39.50 (2026-09-02, Auction #15 settlement).

What moved: Dec26 gave back 2.5% and now sits exactly on the September auction clearing — no spread to read between mark and primary today.

Why: Two hard dates: Ecology's Cap-and-Invest Updates and Linkage rulemaking, which sets allowance budgets for 2027–2050 and adjusts 2023–2026 (Ecology rulemaking page), is at adoption (desk estimate 23 September, effective 24 October); and APCR Auction #8 falls 30 September (Ecology publication 26-14-072). The first-ever ECR sale was held 16 September (Ecology publication 26-14-068); the desk holds no settlement print for it. The CA-Québec-WA linkage agreement was signed by all three jurisdictions in June 2026 — standing context, and the reason the rule matters more than the auction.

Desk view: Judgment — neutral-to-firm. Our post-2026 rows are the desk's own extension of the pre-2027 decline, not statute; adoption replaces them, and that is the repricer.

RGGI (RGA) — Mark: USD 38.57 (2026-09-22, Most liquid futures settlement (Dec26), RGGI V26, settlement observation), −2.4% vs prior same-basis mark. Primary print USD 37.65 (2026-09-09, Auction 73 clearing price).

What moved: EPA signed the Partial Repeal of the Carbon Pollution Standards on 14 September; it published 17 September and is effective on November 16, 2026 , repealing most provisions of the 2024 Carbon Pollution Standards for fossil fuel-fired EGUs. A separate supplemental proposal to rescind the GHG findings and repeal the remaining s.111 standards is out for comment — proposed, not law. This closes a desk catalyst whose expected date had passed.

Why: Federal standards were never the binding constraint inside RGGI, but their removal takes away the complement that would have pressed coal and steam units independently of the cap. The load-bearing number remains the market monitor's 55M short tons of allowances in circulation at end-Q2 2026, projected to 45M at the CP6 deadline (Potomac special Supply & Demand report, 21 August 2026). The 2026 CCR was triggered and fully depleted at Auction 71 (11 March 2026, cleared USD 24.99) — a spent lever. Virginia rejoined on 1 July 2026; its 11.48M H2 budget allowances plus a 1,148,000 CCR tranche are offered beginning with Auction 73, spread across the 9 September and 2 December sales.

Desk view: Judgment — mildly bearish front, constructive 2027+. Rows go deficit from 2027 (−9.8 Mt deepening to −32.9 Mt), but drawdown pace of that surplus, not any single compliance year, is the trade.

Alberta TIER — Mark: CAD 95.00 (2026-05-15, headline TIER price for 2026, stated verbatim in s.1.2.1.1 of the Canada-Alberta Implementation Agreement). No citable futures mark: no reference contract can be determined.

What moved: Nothing new in the last 24 hours.

Why: Standing schedule: CAD 100 for 2027–2029, CAD 115 in 2030, to CAD 140 by 2040, with a credit price floor ladder starting CAD 60 in 2030 and Alberta to enact the floor regulation by 31 December 2026.

Desk view: Judgment — the enactment date is economically live now, not in 2030: clause 1.2.3.4 grandfathers pre-enactment credits below the floor, so the cut-off is the carry.

1b. Low-carbon fuels (LCFS / CFR)

Mark: CA LCFS credit USD 79.85 (CARB weekly volume-weighted average credit transfer price, week of 2026-09-07, range USD 65.00–85.00, report posted 2026-09-16). BC LCFS CAD 135.80 (2026-07, monthly average credit transfer price). No citable CFR credit mark — ECCC's credit-retirement data is unpublished.

What moved: No new development overnight; the next weekly CARB transfer report is on our calendar for today.

Why: Structure is tightening — 2026Q1 showed credits 6.93M MT against deficits 9.77M MT, net −2.84M MT, bank 36.86M MT (quarter ended 31 March 2026, published 31 July 2026). Flow argues the other way: Brent at USD 130.80/bbl and Gulf Coast ULSD at USD 5.206/gal (EIA spot, 15 September) mean diesel has repriced up while feedstock has not followed, widening the renewable-diesel margin, lifting RD generation and credit supply.

Desk view: Judgment — flow bearish against a structurally tightening bank; we weight structure here because the bank is drawing down two quarters ahead of the flow read and the margin move is not yet visible in a reported quarter.

1c. RECs

No citable traded REC price on our tape, and no fresh development in the last 24 hours. The desk tracks RPS in 15 states; per-class figures only — a solar carve-out SREC and a bundled Class I REC differ by an order of magnitude and do not average.

2. Voluntary carbon (VCM)

SBTi: no news overnight. Standing context: the Corporate Net-Zero Standard v2.0 published 11 June 2026; validations against V2.0 open 1 February 2027, V1.3.1 submissions close 31 January 2028, V2.0 mandatory 1 February 2028.

Removals / Puro: ADM announced on 21 September its planned entry into the CDR market from its Columbus, Nebraska corn complex, with more than 800,000 tons of annual removal capacity ; credits are undergoing certification and issuance by Puro.earth under its Geologically Stored Carbon methodology (Edition 2024) , with initial issuance expected by end of year, pending audit completion and a 15-year crediting period (ADM release).

Desk view: Judgment — bearish engineered-removal price, bullish volume. A single supplier adding six figures of annual issuance into a thin CDR market ahead of SBTi V2.0 demand arriving in 2027 is a supply event before it is a demand event. Article 6 / GCC: nothing new the desk holds.

3. International

EU ETS (EUA) — Mark: EUR 86.73 (2026-09-22, Most liquid futures settlement (Dec26), EUA, settlement observation), +0.2% vs prior same-basis mark. Primary print EUR 85.53 (2026-09-22, latest EEX auction clearing price).

What moved: A quiet, marginally firmer session; mark and same-day auction clearing are within EUR 1.20, a normal primary-secondary spread.

Why: Rows show surplus narrowing (+113.7 Mt 2027) and flipping to deficit in 2029, on the LRF path in Directive (EU) 2023/959. COM(2026) 616 remains a proposal. Henry Hub at USD 2.97/MMBtu (EIA, 15 September) is a US, not EU, print and carries no read-through here; the desk holds no TTF level.

Desk view: Judgment — constructive on the curve, neutral spot.

UK ETS (UKA) — Mark: GBP 58.12 (2026-09-22, Most liquid futures settlement (Dec26), UKA, settlement observation), +0.2% vs prior same-basis mark. Primary print GBP 58.68 (2026-07-31, official monthly average UKA settlement price, Dec futures).

What moved: Marginally firmer; the Dec26 differential to EUA is −21.9% in common currency, narrowing to −19.4% by Dec28.

Why: Rows deficit throughout on SI 2020/1265 Table B as amended by SI 2026/392 (maritime extension, in force 1 July 2026); linkage remains a standing desk view, not a dated event. These rows carry no bank or reserve.

Desk view: Judgment — bullish the UKA-EUA differential, neutral outright.

Other: NZU last print NZD 51.00 (2026-09-04) — 18 days old against a 7-day cadence, a last print rather than a mark, and no delta is quoted against it. ACCU last print AUD 37.50 (2026-05-15, CER QCMR March quarter 2026), an administered-cadence quarterly print. No directional call on either.


Corrections & notes