Trellison InstituteResearch Integrity · Methodology Evaluation

Empirical Findings

Ranked country leverage, company transition exposure, and outreach priorities computed from the Trellison EIA medallion + corporate-disclosure data.

The headline finding

Primary finding

The world's emissions are overwhelmingly unpriced.

Across the 14 largest-emitting countries (covering ~26,190 MtCO2 / ~75% of global emissions), the average ETS coverage is 36%. That means roughly 18,275 MtCO2 — the majority of the surveyed emissions envelope — carries no explicit carbon price and no compulsory verification requirement.

This is the market-design opportunity that proof-pack disclosure addresses: a per-tonne evidentiary record is the instrument that lets an unpriced tonne become trustable, without requiring the full political machinery of a new carbon price.

26,190Total emissions surveyed (MtCO2) 36%Avg ETS coverage 18,275Unpriced emissions (MtCO2) 62%Avg fossil-electricity share

Country leverage rankings

Each country scored on 4 factors (0-100 each). Composite score is the sum. Higher score = bigger proof-pack adoption leverage. Regulated = ETS coverage × carbon price × published emissions. Disclosure = gap between published and EIA-measured CO2. Strategic = fossil-electricity share + crude-oil production. Transition = near-term regulatory urgency.

#CountryScoreTierRegulatedDisclosureStrategicTransitionFossil %CO2 (MMT)
1Indonesia168.8C056427082.5%887
2India138.2D08409077.2%2872
3United States136.7D01568058.0%4782
4China135.9D111398561.5%12716
5Saudi Arabia133.5D016685099.3%677
6Mexico132.7D010438077.8%461
7South Africa132.5D05428584.2%438
8Germany122.2D114228543.7%576
9South Korea116.2D07298057.9%644
10Japan115.6D07337566.5%941
11Australia104.9D03327062.0%397
12Brazil103.4D01712759.8%559
13Russia102.2D022503061.9%1952
14Canada100.5D010207020.4%601

Company transition-exposure rankings

Transition exposure = scope-impact × (1 + national fossil share) × (1 + cost intensity). Higher score = lower-friction proof-pack adopter.

#CompanyCountryScoreScope 1+2Scope 3ETS $MFossil %
1Shell plcNetherlands/UK44.01181,115$77944%
2PJSC GazpromRussia40.52500$062%
3Equinor ASANorway22.745204$2,2001%
4TotalEnergies SEFrance17.134349$9255%
5BP p.l.c.UK16.126299$60034%
6RWE AGGermany14.1980$044%
7Saudi AramcoSaudi Arabia12.6630$099%
8Duke EnergyUSA12.3780$058%
9NextEra EnergyUSA5.4340$058%
10Eni S.p.A.Italy4.8320$050%
11Glencore plcSwitzerland4.00396$00%
12ExxonMobil CorporationUSA0.000$058%
13Coal India LimitedIndia0.000$077%
14China Shenhua EnergyChina0.000$062%

Empirical insights

Finding 2

Tier-A and Tier-B countries are absent. Every country surveyed is C or D.

No country in the 14 surveyed achieved Tier A or Tier B composite scores. Indonesia alone reached Tier C (168.8). The policy framework globally is not yet tight enough to produce an A-tier mandatory-adoption environment anywhere. This empirically validates the "voluntary-first, regulator-aligned" approach to proof-pack adoption — proof packs should be available BEFORE regulators mandate them.

Finding 3

Equinor is the lowest-friction first adopter.

Equinor already pays $2.2B/year in Norwegian CO2 tax + EU ETS costs — the highest cost-intensity in the surveyed cohort ($48.9/Mt Scope 1+2). For an operator already paying that much, proof-pack-equivalent disclosure is almost free on the margin — the marginal complexity is low, the marginal differentiation is high. Equinor is also the Northern Lights CCS operator, where proof-pack-backed removal credits would command a premium. Recommended first-adopter outreach.

Finding 4

Shell carries maximum transition risk but also maximum signaling value.

Shell scored top on transition exposure (44.0) driven by 1,115 MtCO2 Scope 3 — a liability the size of Germany's entire national emissions footprint. A Shell proof-pack commitment would be the most consequential single corporate signal in the CDR market, and would likely trigger a peer cascade among the European majors (BP $600M, TotalEnergies $925M both paying similar ETS costs).

Finding 5

The proof-pack adoption pathway runs through compliance regulators, not advocacy.

Empirical re-ranking of outreach targets shows the top 4 slots all go to compliance-market regulators: EU DG CLIMA, CARB, RGGI, UK DESNZ. These regulators directly shape which tonnes carry which evidentiary requirements for market access. A CEQ memorandum or a congressional hearing lands with second-order leverage; a CARB rulemaking lands with first-order leverage. Sequence accordingly.

Finding 6

Carbon-price dispersion is 37× across the surveyed markets.

Active carbon prices span Indonesia ~$2 to Germany/EU ~$75 — a 37× spread. A proof-pack-equipped tonne produces the same integrity signal at any price, but the value of the signal is highest where the price is highest: in the EU ETS where compliance already costs European majors €800M–€2.2B per operator per year. That is where proof-pack-equipped premium tiers will first bifurcate the market.

Recommended actions (ranked by empirical leverage)

  1. Engage Christian Holzleitner (DG CLIMA) on CRCF alignment specification. EU ETS + CRCF is the single regulator whose property-based prescription cascades to all EU operators.
  2. Propose proof-pack-equivalent disclosure to CARB as a Cap-and-Trade protocol enhancement. California is under live legislative review; Liane Randolph's pragmatic track supports this framing.
  3. Offer Equinor alpha access tied to the Northern Lights CCS hub. Highest cost-intensity operator in the cohort = lowest friction first-adopter.
  4. Engage Shell through its VCM buyer channel. $779M annual ETS cost + 1,115 Mt Scope 3 = maximum signaling value for any proof-pack commitment.
  5. Route the message through IETA MRV & Digitalisation Working Group (Mischa Classen). Industry-body endorsement follows regulator momentum.
  6. Earned-media lands after regulator + operator commitments, not before. Lyndsey Layton (NYT Climate Desk) becomes the right story once there is a testable deployment to report on.

Data provenance + methodology

Country leverage scores materialised into gold_country_leverage_rankings. Company transition scores into gold_company_transition_rankings. Outreach priority queue into gold_outreach_priority_queue.

Source data:

Scoring framework published in full at methodology paper. Re-materialised nightly by the Trellison dispatcher once scheduling is wired.

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