# Eligibility criteria

The eligibility criteria requirements that are **applicable to all projects under this methodology** are detailed in the sections below. Other eligibility criteria requirements shall be taken from the [Rainbow Standard Rules](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/rainbow-standard-rules):

* Measurability
* Real
* TRL
* Minimum impact

## Additionality

To demonstrate additionality, Project Developers shall perform **regulatory surplus analysis, plus either investment or barrier analysis**, using the [Rainbow Additionality Template](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/procedural-templates/additionality-evaluation-template).

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{% tab title="Regulatory surplus analysis" %}
**Regulatory surplus analysis** shall demonstrate that there are no regulations that require or mandate project activities.

Project Developers must demonstrate that CO<sub>2</sub> capture was not mandated under an Emissions Trading System (ETS). A site may be eligible if the site had already met its ETS obligations, and the captured CO<sub>2</sub> exceeded those required reductions, and the site complies with the [No double counting ](#n1iy4xaxuthk-1)criteria.

At the European Union level, projects automatically pass the regulatory surplus analysis, which has been conducted by the Rainbow Climate Team. Project Developers are only required to provide a country-level regulatory surplus analysis.
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{% tab title="Investment analysis" %}
**Investment analysis** may be used to prove that revenue from carbon finance is necessary to make the project investment a financially viable and interesting option. The investment may cover:

* The creation and launching of new sites
* Expansion of capacity of existing activities
* Expansion by installing new processes

Business plans shall be provided as initial proof for investment analysis. During verification, audited financial statements shall be used to demonstrate that the initial estimates from the business plan were reasonable, and that carbon finance was used as initially described for the expected investment.

For launching brand new sites, additionality can be simply demonstrated if the business plan shows that carbon finance is expected to make up at least 80% of the company’s revenue, as detailed in the [Rainbow Additionality Template](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/procedural-templates/additionality-evaluation-template).

Note that for investments in expansion, **only the additional carbon removals and avoidance enabled by the expansion shall be eligible for Rainbow Carbon Credits.**
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{% tab title="Barrier analysis" %}
**Barrier analysis** may be used to prove that the project faces financial, institutional, or technological barriers to ongoing operations that can only be overcome using carbon finance. Examples include but are not limited to:

* Financial barrier: financial analysis demonstrating that the project is not financially viable, evidenced by net cash being lower than the working capital requirements, or proof that the project is not meeting the projected financial targets in the business plans and loan documents, and that carbon finance would make it financially viable.
* Institutional barrier: description of new regulation that the project must make costly changes to comply with, with financial analysis showing that the project cannot fund the changes on their own, and carbon finance is necessary to make it viable.
* Technological barrier:
  * proof that the project's carbonated product struggles to be cost-competitive with baseline products. Carbon finance may be used to lower the selling price of the project’s product, making it more competitive.
  * proof that the large amount and cost of R\&D required for an innovative technology makes the technology unfeasible to scale without carbon finance.&#x20;

For any type of barrier analysis, **audited financial statements must be provided** as proof. These documents should either demonstrate the financial status to prove financial barriers, or show that the project could not independently fund solutions to overcome institutional or technological barriers.
{% endtab %}
{% endtabs %}

## Permanence <a href="#n1iy4xaxuthk" id="n1iy4xaxuthk"></a>

The permanence horizon for projects certified under this methodology is 1000+ years. This is ensured in part by the eligible uses of carbonated materials, which include only materials that won't be incinerated (i.e. concrete).

Carbon is considered [permanently stored](#user-content-fn-1)[^1] upon **mineralization/material production**, but the final end use of the material affects its risk of reversal. Therefore, Project Developers shall provide information on:&#x20;

* **the expected end use** of carbonated products, including the building/structure type and geographic location, and
* **the type of carbonate produced** and its specific risk of reversal under different heat and pH conditions, and
* justification that **exposure to reversal risks are negligible**, addressing the risk of exposure to high temperature (e.g. burning) and to acids (e.g. acid rain, acidic groundwater infiltration...).

If Project Developers can provide the required information at the time of production (e.g. through signed sales contracts limiting the final use of the product), credits may be issued upon production. If this information is only available once the carbonated product is sold, credit issuance shall be delayed until the point of sale or provision of the required information.

#### Risk of reversal <a href="#ufd5h5pvzv82" id="ufd5h5pvzv82"></a>

Project Developers shall fill in the [Rainbow Mineralization risk evaluation](https://docs.rainbowstandard.io/~/changes/171/methodologies/mineralization-of-alkaline-materials-ex-situ/risk-assessment-template) to **evaluate the risk of carbon storage reversal**, based on social, economic, natural, and delivery risks.

Project Developers shall assign a likelihood and severity score to each risk, and provide an explanation of their choices. The Rainbow Certification Team shall evaluate the assessment and may recommend changes to the assigned scores.

The Project Developer, Rainbow Certification Team, or the third-party auditor may suggest additional risks to be considered for a specific project.

Each reversal risk with a **high or very risk score** is subject to:

* **risk mitigation plan**, developed by the Project Developer, that details the long-term strategies and investments for preventing, monitoring, reporting and compensating carbon removal reversal, or
* **additional contributions to the buffer pool**, at a rate of 3% of verified removal Rainbow Carbon Credits for each high or very high risk

## No double counting <a href="#n1iy4xaxuthk" id="n1iy4xaxuthk"></a>

Project Developers shall sign the [Rainbow MRV & Registry Terms & Conditions](https://docs.rainbowstandard.io/~/changes/171/other/terms-and-contracts/terms-and-conditions-for-project-developers-mrv-+-registry), committing to follow the requirements outlined in the [Rainbow Standard Rules](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/rainbow-standard-rules), including not double using or double issuing carbon credits.

The following double counting risks have been identified for alkaline material mineralization projects. Project Developers shall follow the outlined requirements for each risk.&#x20;

<table data-full-width="true"><thead><tr><th width="170">Double counting risk</th><th width="250">Explanation</th><th>Requirement</th></tr></thead><tbody><tr><td>Double issuance of carbon credits with downstream material users</td><td>Users of low-carbon concrete may seek to issue carbon credits in building methodologies in regulated or voluntary carbon markets</td><td><ul><li>Identify all direct downstream users/buyers/actors in their supply chain.</li><li>Provide the company/organization name, name of an individual contact person at the company/organization, and their contact information (email address at minimum).</li><li>Provide signed agreements and/or sales contract clauses stating carbon credits have already been issued, and users will not claim benefits or issue carbon credits for the product.</li></ul></td></tr><tr><td>Double claiming of removals or reductions with EPDs</td><td>If there is an EPD for the carbonated product, then  carbon removals and/or avoidance may be claimed by downstream users throughout the supply chain, who may issue credits or claim other environmental labels for the carbon benefit already counted and sold elsewhere</td><td><ul><li><p>Provide the product’s EPD (if there is one), including:</p><ul><li>actual GWP values with carbon benefits, as required by norms/standard, and</li><li>a clause specifying when users must exclude carbon benefits in calculations using values from the EPD.</li></ul></li><li>For ex-ante projects that don't yet have an EPD, a signed statement may be provided to validate the project. Credits shall only be issued ex-post upon providing the EPD as described above.</li></ul></td></tr><tr><td>Double issuance of carbon credits with upstream CO<sub>2</sub> capture (e.g. DACCS projects)</td><td>Carbon capture projects are well incorporated in carbon markets (e.g. BECCS, DACCS), and Project Developers must agree on which entity is issued credits/how to repartition credits or carbon finance</td><td><ul><li>Identify all CO<sub>2</sub> suppliers in their supply chain.</li><li>Provide the company/ organization name, name of an individual contact person at the company/organization, and their contact information (email address at minimum).</li><li>Provide signed agreements and/or sales contract clauses stating carbon credits have been issued by the CO<sub>2</sub> user, and CO<sub>2</sub> suppliers will not claim/issue the same carbon benefits in the carbonated material.</li></ul></td></tr><tr><td>Double claiming of removals or reductions with ETS</td><td>CO<sub>2</sub> used for mineralization may be captured from heavy emitting industry sites that are covered by an ETS. When the site captures CO<sub>2</sub> emissions, they can claim the benefit in the ETS, or participate in the carbon credit issuing project, but not both.</td><td><ul><li>Demonstrate that the CO<sub>2</sub> supplier is not covered by an ETS.</li><li>If the CO<sub>2</sub> supplier is covered by an ETS, provide their official ETS reporting documents, showing that reductions that were issued carbon credits under the present methodology are not included in ETS reporting.</li><li>For ex-ante projects that don't yet have an updated ETS reporting document, a signed statement may be provided to validate the project. Credits shall only be issued ex-post upon providing the ETS reporting document as described above.</li></ul></td></tr></tbody></table>

## Co-benefits

Project Developers shall prove that their project provides **at least 2 co-benefits** from the [UN Sustainable Development Goals](https://unstats.un.org/sdgs/indicators/Global-Indicator-Framework-after-2024-refinement-English.pdf) (SDGs) framework (and no more than 4).

Common co-benefits of projects certified under this methodology, and their sources of proof, are detailed in Table 1. Project Developers may suggest and prove other co-benefits not mentioned here.

SDG 13 on Climate Action by default is not considered a co-benefit here, since it is implicitly accounted for in the issuance of carbon credits. If the project delivers climate benefits that are not accounted for in the GHG reduction quantifications, then they may be considered as co-benefits.

*Table 1 Summary of common co-benefits provided by projects certified under this methodology. Co-benefits are organized under the United Nation Sustainable Development Goals (UN SDGs) framework.*

<table><thead><tr><th width="214">UN SDG</th><th width="266">Example</th><th width="113">Proof</th><th>Indicators</th></tr></thead><tbody><tr><td><strong>SDG 12.2</strong> <em>Achieve the sustainable management and efficient use of natural resources</em></td><td>The project’s <a data-footnote-ref href="#user-content-fn-2">circularity </a>will be measured by the <a data-footnote-ref href="#user-content-fn-3">Material Circularity Indicator (MCI)</a>, according to the Ellen MacArthur Foundation's methodology, and compared to the circularity of the baseline product.</td><td>Types of inputs used and waste status</td><td>% circularity, % improvement from baseline</td></tr><tr><td><strong>SDG 9.4</strong> <em>Upgrade infrastructure and retrofit industries to make them sustainable</em></td><td>Increase strength, durability and lifetime of concrete, extending infrastructure lifespan.</td><td>Internal testing, R&#x26;D results</td><td>% extended lifespan</td></tr><tr><td><strong>SDG 8.4</strong> <em>Improve global resource efficiency in consumption and production</em></td><td>Reusing alkaline waste materials in the mineralization process diverts them from other waste treatment methods.</td><td>Invoices and operations records</td><td>tonnes of waste material used</td></tr><tr><td><strong>SDG 6.3</strong> <em>Improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials</em></td><td>Projects that carbonate and reuse cement wastewater contribute to improved and useful wastewater treatment and water quality</td><td>Invoices and operations records</td><td>m<sup>3</sup> of wastewater used</td></tr></tbody></table>

## Substitution

The carbonated material shall fulfill the same function and meet the same quality and performance standards as the baseline material it replaces. Project Developers shall prove this using representative test results from pilot testing, R\&D laboratories, or full-scale operations.

Project Developers shall justify that using their carbonated product in concrete (or other final product) leads to the same quality and performance as the baseline material, considering:

* durability
* service lifetime
* compressive strength (where relevant)
* use-phase mineralization (where relevant)
* other performance characteristics related to non-concrete end uses.

If the expected use-phase carbonation in the baseline scenario is larger than the project scenario, this shall be accounted for in the baseline [GHG quantification](https://docs.rainbowstandard.io/~/changes/171/methodologies/ghg-quantification#id-8422amp7fe3k-2). Inversely, if the project is expected to lead to larger use-phase removals, this shall be conservatively excluded from quantification. It may be considered a [co-benefit](#co-benefits).

## Environmental and social do no harm

Project Developers shall prove that the **project does not contribute to substantial environmental and social harms.** Projects must follow all national, local and European (if located in Europe) environmental regulations, and prove such compliance using, for example, permits, certifications, or licenses.

In addition to completing the [Rainbow Mineralization risk evaluation](https://docs.rainbowstandard.io/~/changes/171/methodologies/mineralization-of-alkaline-materials-ex-situ/risk-assessment-template) below, Project Developers must prove the following elements:

For **fossil CO**<sub>**2**</sub>**&#x20;use**, Project Developers shall prove that the CO<sub>2</sub> was not generated or emitted for the sole purpose of carbon storage, and that it was captured from an existing CO<sub>2</sub> emission source.

For **biogenic CO**<sub>**2**</sub>**&#x20;use**, Project Developers shall prove that the original biomass used to generate the biogenic CO<sub>2</sub> meets the EU's [RED III](https://eur-lex.europa.eu/eli/dir/2018/2001) Article 29 sustainability criteria for biomass (even if the project is not located in the EU). This includes the following, summarized here for informative purposes only:

* If the biomass is proven to be waste, no further sustainability requirements apply (refer to the positive list in the Rainbow [Biomass feedstock](https://docs.rainbowstandard.io/~/changes/171/biomass-carbon-removal-and-storage-bicrs/carbon-capture/biomass-feedstock#waste-status) module).
* If the biomass is not waste, Project Developers shall prove that it did not come from:
  * Primary or old-growth forests
  * Highly biodiverse forests or other wooded land designated as such by competent authorities.
  * Protected areas for rare or endangered ecosystems/species (unless proven that biomass production does not interfere with conservation goals).
  * Highly biodiverse grasslands
  * Heathland, wetlands, or peatlands
  * Recently deforested, converted or degraded ecosystems (within past 20 years)
* Forestry biomass shall follow the requirements listed above, and
  * Respect international, national and regional legal requirements
  * Promote forest regeneration by avoiding large clear-cuts or extraction of stumps/roots
  * Protect biodiversity and soil quality
  * Come from sustainably managed forests

#### ESDNH risk evaluation

Project Developers shall fill in the [Rainbow Mineralization risk evaluation](https://docs.rainbowstandard.io/~/changes/171/methodologies/mineralization-of-alkaline-materials-ex-situ/risk-assessment-template), to evaluate the identified environmental and social risks of projects. The identified risks include:

* Heavy metal leaching from stored alkaline feedstock
* Dust and particulate generation from alkaline feedstock storage and handling
* Water use in the mineralization process
* Fugitive CO<sub>2</sub> leaks during the mineralization process
* Hazardous waste generation from the use of chemical additives
* Leaching pollutants from carbonated products during the use phase
* Demand for fossil CO<sub>2</sub> as a valuable product increases fossil fuel output
* Pressure on unsustainable or nonrenewable biomass use for biogenic CO<sub>2</sub> generation
* Environmental impacts from opening a new mine or quarry to obtain alkaline feedstock

Project Developers shall assign a likelihood and severity score of each risk, and provide an explanation of their choices. The VVB and Rainbow’s Certification team shall evaluate the assessment and may recommend changes to the assigned scores.

All risks with a high or very high risk score are subject to a [Risk Mitigation Plan](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/rainbow-standard-rules/general-eligibility-criteria#risk-mitigation-plan), which outlines how Project Developers will mitigate, monitor, report, and if necessary, compensate for any environmental and/or social harms.

Additional proof may be required for certain high risk environmental and social problems.

The Project Developer, the Rainbow Certification Team, or the VVB may suggest additional risks to be considered for a specific project.

{% hint style="info" %}
Note that the **life-cycle GHG reduction calculations account for the climate change impacts of most environmental risks**. Nonetheless, Project Developers shall transparently describe any identified GHG emission risks in the risk evaluation template.
{% endhint %}

{% hint style="info" %}
All risk assessments must also address the [Minimum ESDNH risks ](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/rainbow-standard-rules/general-eligibility-criteria#minimum-esdnh-risks-to-assess)defined in the Rainbow Standard Rules.
{% endhint %}

## Leakage <a href="#ekfzu5nkmddm" id="ekfzu5nkmddm"></a>

mineralization of materials must not contribute to activity shifting leakage. The following leakage risks are already covered by other requirements in this methodology:

* **Displacement of baseline mineralization**: a small amount of atmospheric carbon removal via mineralization may be modeled in the [Baseline Scenario](https://docs.rainbowstandard.io/~/changes/171/methodologies/ghg-quantification#baseline-co2-stored) where relevant, effectively deducted from the project's carbon storage.
* **Increased emissions during use**: leakage emissions from use of carbonated products downstream of the project are mitigated by the [Substitution](#substitution) requirement, where project materials must have the same performance as baseline/replaced products.
* **Upstream and downstream emissions**: considered in the life-cycle based GHG quantifications.

Any material sources of leakage that cannot be mitigated shall be conservatively included in the GHG calculations.

## Targets alignment <a href="#ekfzu5nkmddm" id="ekfzu5nkmddm"></a>

Projects that **issue avoidance RCCs on the basis of cement reduction** must prove that they lead to at least a **73% reduction in GHG emissions** compared to the baseline scenario. This is aligned with the [European Union’s 2040 Climate target](https://climate.ec.europa.eu/eu-action/climate-strategies-targets/2040-climate-target_en) and described in the [Rainbow Standard Rules](https://docs.rainbowstandard.io/~/changes/171/rainbow-standard-documents/rainbow-standard-rules/general-eligibility-criteria#targets-alignment).

The scope of the reduction is concrete production impacts for the given concrete mix design. This is assessed at the project-level for determining the baseline scenario, and shall be proven by following the [GHG quantification](https://docs.rainbowstandard.io/~/changes/171/methodologies/ghg-quantification#calculations-avoidance-from-reduced-cement) section.

This eligibility criteria may be **disregarded for projects that only issue RCC on the basis of carbon storage from mineralization**.

[^1]: Baciocchi, R., Costa, G., 2021. CO2 Utilization and Long-Term Storage in Useful Mineral Products by Carbonation of Alkaline Feedstocks. Front. Energy Res. 9. [URL](https://doi.org/10.3389/fenrg.2021.592600).

[^2]: Goddin, J., Marshall, K., Pereira, A., Tuppen, C., Herrmann, S., Jones, S., Krieger, T., Lenges, C., Coleman, B., Pierce, C., Iliefski-Janols, S., Veenendaal, R., Stoltz, P., Ford, L., Goodman, T., Vetere, M., Mistry, M., Graichen, F., Natarajan, A., Sullens, W., 2019. Circularity Indicators: An Approach to Measuring Circularity, Methodology. <https://doi.org/10.13140/RG.2.2.29213.84962>

[^3]: Ellen Macarthur Foundation, ANSYS Granta, 2019. An approach to measuring circularity. Published in 2015, adapted in 2019. [URL](https://emf.thirdlight.com/link/3jtevhlkbukz-9of4s4/@/preview/1?o)
