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In 2026, a new kind of commodity risk is moving from sustainability teams to procurement, finance, and legal. It is not just the price of oil, gas, or power. It is the price of verified decarbonization. In other words, whether it is credits, reduction efforts, or supply chain adjustments, it can be measured and tracked. This opens new opportunities for strategic investments and accountability in sustainability efforts.
Europe’s Carbon Border Adjustment Mechanism, or CBAM, is designed to put a carbon cost on certain imported goods by requiring importers to report embedded emissions and, over time, pay for them through CBAM certificates. The European Commission states that CBAM runs in a transition phase from 2023 through 2025 and moves into its definitive regime in 2026. That timing matters because it pushes emissions accounting deeper into supply chains and turns climate data into a commercial variable.
A similar shift is underway in aviation and shipping. Sustainable aviation fuel, usually shortened to SAF, is a category of lower-carbon jet fuels. The EU’s ReFuelEU Aviation rules require aviation fuel suppliers to increase the share of SAF blended into jet fuel at EU airports over time. In shipping, the EU’s FuelEU Maritime rules set greenhouse gas intensity requirements for energy used onboard ships and include compliance flexibility tools that can support trading and pooling.
Each of these policies creates recurring demand for proof. That proof, in many cases, comes in the form of tradable certificates, credits, or compliance units. Together, they form what market participants call environmental commodities.
“Environmental commodities represent tradable instruments that enable transactions between people that need or want to decarbonize and those that have carbon reduction opportunities,” Marijn van Diessen, CEO of STX Group, wrote in emailed responses. “At a fundamental level, all of these instruments serve a similar purpose: they connect organizations that need or want to decarbonize with those that can deliver measurable emissions reductions.”
What environmental commodities are, in plain English
Environmental commodities are tradable instruments that represent a verified clean attribute. They often separate an environmental value from the physical energy or activity itself, then track that value through registries and compliance systems.
For renewable electricity, the primary instrument is an energy attribute certificate. In Europe, these are commonly called Guarantees of Origin. In the United States, they are Renewable Energy Certificates, often shortened to RECs. In many emerging markets, they are International Renewable Energy Certificates, or I-RECs. Each certificate typically represents one megawatt-hour of renewable generation. The certificate allows a corporate buyer to substantiate a renewable electricity claim even though electrons on a grid are indistinguishable.
Van Diessen described the logic succinctly. “They allow companies to credibly claim renewable electricity consumption, even though the physical electrons on the grid are indistinguishable,” he wrote.
For fuels, the market includes physical low-carbon fuels such as biofuels and renewable gas, as well as the compliance credits created when regulated systems reward lower-carbon alternatives. In some jurisdictions, credits are generated from delivering renewable electricity or renewable fuels into transport markets. Those credits can be used for compliance, purchased voluntarily, or both, depending on the program.
Van Diessen also pointed to biomethane, also called renewable natural gas, and to bio-LNG. “As globally traded commodities, biomethane and bio-LNG provide flexible options for buyers and suppliers to meet regulatory targets, hedge energy use, and monetize environmental attributes,” he wrote. The point is not that these instruments replace physical infrastructure. The point is that they create standardized, transferable evidence that decarbonization happened in a verifiable way.
Why markets matter even when regulation sets the rules
Policy defines targets and determines what counts. This in turn signals to markets what projects are scalable, can create jobs and opportunities . “Environmental commodity markets provide scaffolding on which the energy transition can actually be built,” van Diessen wrote. “They exist not to virtue-signal, but to put a price on emissions and translate decarbonization objectives into something that can be financed and delivered at scale.”
That statement is easier to understand when you translate it into terms of how commodity markets work. Buyers and suppliers are fragmented. Projects are dispersed across jurisdictions and technologies. Contracting can be complex. Trading helps create liquidity and price discovery. It also allows participants to manage timing risk and price volatility. In practice, this means a regulated target can drive demand for certificates and credits, while markets determine where the next dollar of investment flows. When markets function well, they can lower the cost of achieving policy outcomes by directing capital toward the most cost-effective projects first.
The finance signal investors are watching
One of the clearest signals that environmental commodities are moving into the mainstream is whether banks will finance them. Van Diessen said that was historically a constraint for producers and suppliers of low-carbon solutions. “Historically, many producers and suppliers of decarbonization solutions struggled to access flexible financing, particularly because banks were not accustomed to treating environmental commodities as reliable collateral,” he wrote.
He described borrowing-base financing as a structure that allows financing to be extended against the value of environmental commodities and used as security, supporting working capital for inventory, receivables, and risk management. Banks treat these instruments as financeable assets. That can improve liquidity and lower the cost of capital for projects that generate the underlying certificates, credits, and fuels.
What CFOs and general counsel should watch in 2026
Van Diessen flagged three risk themes that map closely to corporate governance.
First, regulatory fragmentation. Timelines and interpretations vary across jurisdictions. That can create contract uncertainty and basis risk, which is the mismatch between related markets or instruments. For multinational firms, fragmentation can also create conflicting disclosure expectations and inconsistent treatment of claims and contracts.
Second, expansion of carbon pricing and border mechanisms. CBAM is intended to bring carbon cost considerations into import supply chains, and carbon pricing programs are spreading. The practical implication is that embedded emissions data can become a pricing variable in procurement and trade.
Third, litigation and claims risk. Climate-related litigation is rising, including greenwashing allegations and board oversight claims. The practical implication is that documentation quality becomes a form of risk control. Registry evidence, eligibility criteria, and contract terms can matter as much as headline price.
Why this story is now an infrastructure story
Environmental commodities used to sit in the background of sustainability reporting. That is changing because regulation is widening the set of companies that must measure, report, and pay for emissions, and because transport-fuel mandates are creating recurring demand for verified low-carbon alternatives.
For investors and operators, the market is becoming less about messaging and more about infrastructure. It is about how decarbonization gets priced, how it gets financed, and how it gets proven.