'Pre-compliance' buyers purchase offsets from CDM projects that are in the pipeline awaiting registration by the CDM Executive Board and the subsequent issue of CERs (Neeff et al., 2007). In fact a whole new market segment called 'pre-CDM VERs' has emerged consisting of buyer demand for credits produced by projects that are awaiting their registration or issuance through the CDM regulator (Capoor and Ambrosi, 2007).
The Hamilton et al. (2008) survey of brokers found that only 42 percent of sales are currently being registered and was unable to confirm whether offsets sold were into the hands of a final buyer for retirement, or for on-sale. The authors concluded from the data that perhaps 30 percent of voluntary offsets purchased were for resale in a secondary market.
Given this manifest difficulty of tracking transactions, there is an obvious potential for the unwitting or deliberate sale of an offset more than once. Several new registries have been set up to account for voluntary offset transactions. Box 3.2 illustrates how double-counting of voluntary offsets can easily happen.
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