Pulp and paper: CCTS targets, credits and carbon per tonne

Your fourth decimal is a cheque.

Your CCTS target runs to four decimals. Know before March if you buy credits or sell them.

What do you run?
Work out your credit positionBook a 20-minute call
CCTS MONITORING SUMMARYIntegrated pulp and paper unit · H1 2026-27
Ref.
PNP-H1-014
Output
1,60,000 t, Apr to Sep
Coal
1,15,000 t at 3,800 kcal/kg
Grid import
48,000 MWh
Black liquor
Biogenic, reported as memo
Target
1.2100 t CO₂e/t
Intensity
1.2385 t/t
Gap
0.0285 over target
H1 position
4,565 credits short
4 decimals

Example. Illustrative targets and figures.

The short answer

How do paper mills earn or owe carbon credits under CCTS?

Each listed mill has a target in tonnes of CO2e per tonne of product. Credits = (target minus actual intensity) × output. Below target, you earn credits to sell or bank. Above it, you buy credits, or pay twice the average credit price as compensation.

Last verified 3 October 2026. Sources at the end.

Sound familiar?

Integrated pulp and paper mills

I need to know by December whether we buy credits or sell them, mill by mill.

Recycled fibre and agro mills

We’re on the list. I have one engineer, a spreadsheet, and a verifier who wants a trail.

Packaging board suppliers

The buyer’s form asks for kg CO2e per tonne, by grade. We sent our ISO certificates.

Paraphrased from our conversations with paper mills and their buyers.

The fourth decimal is money.

Every number in your CCTS filing comes from a data choice. Here are three that mills make every month. Flip them.

The cleanest mill on the list emits 0.02 t a tonne.
The dirtiest emits 3.49.

Same gazette, same deadline. 2023-24 baseline intensities for the 53 listed pulp and paper units, from 0.0211 (agro) to 3.4859 (integrated). Required cuts to 2026-27 run from 0% to 13% (G.S.R. 739(E), 8 October 2025).

Why now

Who’s asking, and by when.

31 Mar 2027

Target year closes

The 2026-27 compliance year ends in March. It’s the tighter of the two targets.

2x

Missing costs double

A shortfall not covered by credits draws compensation at twice the average traded price.

63%

Materials and packaging

Unilever puts raw materials, ingredients and packaging at 63% of the emissions in its net-zero scope, and asks suppliers for product footprints.

30 Dec 2026

EUDR for paper

Pulp and paper sold into the EU need deforestation due diligence. Printed products were taken out.

Free CCTS credit calculator

Buyer or seller?

Set your output, coal, power and target. See your credit position, and which lever flips it.

0

How this is worked out
  • Coal: GCV × 4.1868 × 90.6 g CO2 per MJ for Indian coal, 85.2 for imported (CEA CO2 Baseline Database v22).
  • Grid power: 0.675 t CO2 per MWh, India’s weighted average for 2025-26 (CEA v22).
  • Biomass and black liquor: biogenic CO2, reported separately (IPCC 2006). Check BEE’s procedure for your unit.
  • Credits = (target − intensity) × output. Compensation if not surrendered: twice the average traded price (G.S.R. 739(E)).
  • Credit price is a scenario input. Trading hasn’t opened yet.
  • Scenario tool for planning. It isn’t your verified filing.

Answer the buyer by grade.

Your FMCG buyer’s supplier form. Same question, two answers.

Supplier_Carbon_Questionnaire_FY26.xlsxSheet: Packaging · row 7 of 24
Question 7 For each board grade supplied in FY 2025-26, state the cradle-to-gate footprint in kg CO2e per tonne, the method, the share of primary data, and your reduction target.

Question wording modelled on FMCG supplier questionnaires.

  • Keep the shelf. Send kg per tonne by grade before the buyer guesses with an average.
  • Sell the gap. Turn a long CCTS position into credits you can sell.
Straight answer: CCTS numbers follow BEE’s procedure, and it sets the final rules for your filing. Our calculator is for planning. For a product claim your buyer will publish, we’ll tell you if you need a full ISO 14067 study.
From the field

What paper teams ask first.

Mill heads and CFOs

“Show us the scenarios.”

Which lever flips each mill from buyer to seller over the next two years, and where it sits among the 53 mills on the list.

What Carbon-OS does

Reads SAP, prepares data in BEE’s format, benchmarks each mill against the gazette, and models scenarios before the money moves.

How it works

From SAP and the DCS to the BEE form.

Carbon-OS reads the data your mill already keeps. The same numbers feed your CCTS filing, your buyer forms and your BRSR.

  1. Connect

    SAP, DCS exports, lab GCV sheets, power bills.

  2. Baseline

    Rebuild 2023-24 and check it against the gazette.

  3. Track

    Intensity to four decimals, monthly, mill by mill.

  4. Act

    Scenarios, credit position, buyer forms, BRSR.

Method and boundary

CCTS
Plant fence, per the GEI Target Rules 2025 and BEE’s procedure. t CO2e per tonne of equivalent product.
Baseline
2023-24 baseline. Targets for 2025-26 and 2026-27.
Fuels
Coal by lab GCV and CEA fuel factors. Oil and gas from IPCC 2006.
Biogenic
Black liquor, bark, pith and agro residue reported as memo.
Power
Grid import × CEA v22. Captive power counted through its fuel.
Products
Cradle to gate per tonne of grade, ISO 14067 and GHG Protocol Product Standard.
Factors
More than a million emission factors, including CEA, IPCC and UK government.
Glossary

Eight terms, in plain words.

CCTS
India’s carbon market. Listed mills meet intensity targets or trade credits.
GEI target
Tonnes of CO2e per tonne of product a mill must hit in a year.
Equivalent product
Output converted to one unit, so different grades compare.
Carbon credit certificate
One tonne of CO2e below target, issued by BEE.
Environmental compensation
The charge for a shortfall: twice the average credit price.
RCF mill
A mill that makes paper from recycled fibre.
Black liquor
Spent pulping liquor burned for energy. Its CO2 is biogenic.
Cradle to gate
Emissions from raw material to the mill gate.
Where are you today?

Three questions. Your first steps.

See where we'd start with you.

Is your mill on the CCTS list?

Who asks you for carbon numbers? Pick any

Where does your mill energy data live?

Questions paper mills ask.

How many paper mills have CCTS targets?

53. The final rules of 8 October 2025 list 18 integrated, 28 recycled fibre or imported pulp, 5 agro-based and 2 specialty units.

What is the baseline year for paper mills under CCTS?

2023-24. Targets apply to 2025-26 and 2026-27.

How big are the cuts for paper mills?

From 0% to 13% by 2026-27 against the baseline. Six mills got flat targets.

What happens if a paper mill misses its target?

It surrenders credits for the gap. If it doesn’t, it pays environmental compensation at twice the average traded credit price.

How are carbon credits counted under CCTS?

(Target minus achieved intensity) × equivalent output. A positive result earns credits. A negative one must be covered by buying them.

What will a carbon credit cost in India?

Nobody knows until trading opens. BEE said it expected about $10 a credit at launch (S&P Global, November 2024).

Does black liquor count towards a mill’s emissions?

Under IPCC 2006 its CO2 is biogenic and reported separately. Confirm the treatment in BEE’s procedure for your unit.

Which grid emission factor should a mill use?

CEA’s weighted average for 2025-26 is 0.675 t CO2 per MWh. BEE’s procedure decides the factor for your CCTS filing.

Is paper covered by EU CBAM?

No. CBAM covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.

Does EUDR cover paper exports?

Yes. Pulp and paper stay in scope from 30 December 2026 for large and medium operators. Printed products were removed.

Why do FMCG buyers want carbon per tonne of board?

Packaging sits in their Scope 3. Unilever, for one, asks suppliers for product-level footprints.

Which standard covers a paper product footprint?

ISO 14067 sets the rules for a product carbon footprint. The GHG Protocol Product Standard is the other common method.

Bring one month of mill data. We’ll tell you which side you land.

Twenty minutes. Your coal, your power, your target. You leave with your credit position.

Book the 20-minute callor write to carbon-os@climes.io

Sources

  1. G.S.R. 739(E), GHG Emission Intensity Target Rules, 8 October 2025: 53 pulp and paper units, baselines, targets, credit formula, compensation at 2x
  2. CEA CO2 Baseline Database, version 22: grid 0.675 t CO2 per MWh for 2025-26; coal 90.6 and 85.2 g CO2 per MJ
  3. IPCC 2006 Guidelines, Volume 2, Chapter 1: black liquor and biomass as biogenic CO2
  4. CII, Best Practices Manual in the Paper Sector, Volume 13 (2025): benchmark energy use by raw material
  5. S&P Global, 1 November 2024: BEE expects about $10 a credit
  6. Unilever Supplier Climate Programme: product footprints from suppliers; 63% from materials and packaging
  7. Regulation (EU) 2025/2650: EUDR dates; printed products removed
  8. ISO 14067:2018: product carbon footprint

Facts on this page last verified 3 October 2026. Interactive figures are illustrative unless a source is named.

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