Biomass Pellets to a Thermal Plant: Who Gets the Carbon Credits — You or the Plant?
You buy the straw, run the pellet line and truck it to a coal power station owned by somebody else. So who owns the carbon saving — the supplier or the plant? The honest answer in India today is uncomfortable, and it has almost nothing to do with who is more deserving.
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On this page
- The only question that decides this: whose chimney?
- Fine — so the plant gets them?
- Additionality: the mandate that kills the credit
- What the plant actually gets — and why it isn't carbon money
- Should you write the credits into your supply contract anyway?
- Where a pellet business can genuinely earn carbon money
- Sell into buyers nobody is forcing
- Be the developer, not the vendor
- Notice who your customers are
- And the stubble that would otherwise have been burnt?
- The money that is actually on the table right now
- The short version
Quick answer
If I make pellets and sell them to a thermal power plant, do I get the carbon credits?
No — and in most Indian cases, neither does the plant.
The carbon saving happens when coal is not burnt. That happens inside the plant's boiler, on the plant's meters, in the plant's carbon accounts. You supplied a fuel. Under every registry rule that exists, the reduction belongs to whoever's boundary it occurs in — and that is the plant.
But the plant usually cannot sell it either, because co-firing 5–7% biomass is now compulsory for Indian coal plants. Carbon credits only pay for a change that would not otherwise have happened. A change the law already requires is not that change.
Figures as of August 2026. The ~1.2 tCO₂e ratio is derived from co-firing totals reported by the Ministry of Power (about 814,000 tonnes of biomass associated with roughly 0.97 million tonnes of CO₂ avoided).
The only question that decides this: whose chimney?
Carbon credits are not awarded for being useful. They are awarded to whoever's accounts the reduction lands in. Registries call this the project boundary, and it is drawn around physical equipment, not around goodwill or effort.
So draw it. Where, exactly, does the tonne of CO₂ stop existing?
Not in your pellet mill. Your mill emits — diesel in the collection trolleys, grid power for the hammer mill and the die, diesel again on the run to the plant gate. Nothing is saved there. The saving happens at the moment a boiler burns your pellet instead of a tonne of coal, and the coal stays in the ground.
That boiler belongs to the power company. So does the coal it did not buy, the fuel meter that proves it, and the emissions inventory the tonne disappears from. You sold a fuel to a company that made a decision. The decision is where the credit sits.
The rule, in one line
Supplying the means of a reduction is not the same as making the reduction. The diesel dealer does not earn a credit when a farmer switches to a solar pump. The pellet supplier does not earn one when a plant switches off some coal. In both cases the vendor sold a product; somebody else changed their behaviour.
This is not a technicality anyone can argue around. It is the same rule that stops two parties claiming the same tonne — double counting — which is the single fastest way to have a project rejected or a buyer walk away. If both you and the plant claimed that tonne, one of you would be selling air.
Fine — so the plant gets them?
In principle, yes. The plant would be the project proponent, using a methodology built for exactly this: ACM0006, electricity and heat generation from biomass, is the long-standing route for biomass burnt in a power station.
In practice, in India, in 2026 — mostly no. And the reason is the second rule, which is the one that actually kills this whole idea.
Additionality: the mandate that kills the credit
The Ministry of Power's revised biomass policy — issued 8 October 2021 and modified on 16 June 2023 — mandates biomass co-firing in coal-based thermal power plants: 5% from FY 2024-25, rising to 7% from FY 2025-26. It runs under the SAMARTH mission (Sustainable Agrarian Mission on Use of Agri-Residue in Thermal Power Plants), launched in July 2021 to move crop residue out of the fields and into the boilers.
That mandate is why your business exists. It is also why the carbon credit does not.
The test the mandate fails
A carbon credit pays for a reduction that would not have happened without the credit revenue. That is the additionality test, and every registry — Verra, Gold Standard, and India's own CCTS offset mechanism — applies it.
When a law already compels the action, the credit revenue is not what caused it. The plant co-fires because it must. So the mandated 5–7% is not additional, cannot be credited to the plant, and therefore cannot be handed down to you either. You cannot inherit a right that never came into existence.
There is a narrow gap above the line. NTPC has demonstrated co-firing well beyond the mandate — 20% torrefied biomass at Unit 4 of its Tanda station — and Talwandi Sabo has taken large-scale torrefied pellets. Volume above the compulsory 7% is not legally required, so an additionality case can at least be argued for it.
Note what that gap does not change: it is still the plant's project, in the plant's boundary, on the plant's meters. A wider gap does not move the credit to the fuel supplier's side of the fence.
What the plant actually gets — and why it isn't carbon money
This part matters commercially, because it tells you what the buyer across the table is really optimising for, and therefore what you can and cannot charge for.
| What the plant gets | Status | Why it matters to you |
|---|---|---|
| RPO credit | Real. MNRE confirmed in September 2019 that power generated from biomass co-firing is renewable and counts towards non-solar Renewable Purchase Obligation. CERC set the calculation method in Order No. 03 of 2025, dated 13 August 2025. | This — not carbon — is the plant’s prize. It will not sign it away to you. |
| Penalty avoidance | Real and sharp. Six thermal plants were hit with roughly ₹61.85 crore in combined penalties in December 2025 for missing co-firing targets. | Your leverage on price. Compliance pressure, not climate ambition, moves tenders. |
| CCTS compliance credits | Not available. Thermal power generation is not among the nine notified CCTS compliance sectors (aluminium, cement, chlor-alkali, pulp & paper, iron & steel, fertiliser, petroleum refining, petrochemicals, textiles). | Do not price a “carbon premium” into your pellets. There is no carbon revenue on the other side to fund it. |
| Tradable carbon credits | Effectively unavailable for the mandated 5–7%. Arguable only for volume above the mandate. | The thing you asked about is, for most tonnes, worth nothing to anybody. |
Read that table once more before your next price negotiation. Your buyer is buying regulatory compliance. It is buying an RPO number and the absence of a penalty notice. It is not sitting on carbon revenue it is refusing to share with you — because there is none.
Should you write the credits into your supply contract anyway?
Yes. Not because it will pay you next year, but because it costs nothing and it keeps a door open.
Fuel and power contracts in mature markets deal with this through an environmental attributes clause. It defines the whole family of instruments — renewable energy certificates, carbon credits, Carbon Credit Certificates under CCTS, and any similar instrument recognised in future by law or by a registry — and then says explicitly who owns them.
What to put in the contract
- Define the term widely. "Environmental attributes" should cover RECs, RPO attributes, carbon credits, CCCs and any future instrument, so a rule change in 2028 does not fall through a gap in a 2026 contract.
- Concede RPO. Reserve carbon. The plant is buying for RPO and penalty relief; fighting that loses you the order. Carbon rights above the mandated share are a separate matter and worth reserving or splitting.
- Carve out your own upstream. Never sign a blanket assignment of "all environmental attributes arising from the biomass". That wording can reach backwards into your feedstock chain and block claims you might legitimately make on the farm side later.
- Keep the data rights. Tonnage, moisture, GCV, source villages, collection dates. If sustainable-biomass certification or traceability ever becomes a paid attribute — and for export buyers it already is — that record is the asset, and only you can create it.
Where a pellet business can genuinely earn carbon money
Here is the part worth acting on. The mandate that blocks the credit at a thermal power plant does not exist anywhere else. Every other coal-burning boiler in India is unregulated on this point — and that is precisely what makes it creditable.
Sell into buyers nobody is forcing
A textile mill, a paper unit, a food processor, a chemical plant, a distillery, a brick kiln — each running a coal or furnace-oil boiler for process steam. No law compels any of them to switch. If they switch to your pellets, that is a genuine change caused by the project, and the additionality argument that fails at the power station succeeds here.
The methodology route is well established: CDM's AMS-III.B (switching fossil fuels) has been used in India for exactly this — one documented fuel-switch project at a chemical plant moved steam generation to biomass briquettes for around 7,250 tCO₂e a year. India's own CCTS offset mechanism list includes industrial fuel switching and biomass-based electricity and heat generation, with a project start date on or after 1 January 2025.
Be the developer, not the vendor
This is the structural shift, and it is the whole point of this article. At a thermal plant you are a fuel vendor and the credit is out of reach. At an industrial boiler you can be the project proponent — if you finance or install the boiler conversion, sign the multi-year fuel agreement, hold the metering, and register the project in your own name.
One factory will not pay for validation and annual verification. A portfolio of twenty similar boilers under one programme will. Aggregation is the business model; it is the same logic that makes an FPO viable in a farm carbon project.
Notice who your customers are
Several of those industrial buyers — textiles, pulp and paper, fertiliser, petrochemicals, cement — are CCTS compliance sectors, with legally binding emission-intensity targets for FY 2025-26 and FY 2026-27 against an FY 2023-24 baseline. Roughly 740 entities are covered.
A mill that misses its intensity target must buy certificates or pay compensation. Switching its boiler fuel improves that number directly. That is a buyer with a statutory reason to pay you more than the calorific value of your pellet is worth — which is exactly what the power station does not have.
And the stubble that would otherwise have been burnt?
It comes up in every conversation, so deal with it plainly: the avoided-burning claim is real but very small, and mostly not yours.
Burning a tonne of straw releases only about 0.08 tCO₂e of the gases that actually count — most of the carbon in that smoke was pulled from the air by the same crop months earlier, so it nets out. And there is a trap in the logic: if you are paying money for that straw, you have proved it was never going to be burnt. Straw with a buyer is straw with value.
We worked the numbers through in detail in carbon credits for stubble and crop residue. The short version: at realistic volumes the annual audit costs more than the claim is worth.
The money that is actually on the table right now
Carbon credits are the wrong thing to chase for a pellet plant supplying thermal power. These are the right things, and they are available today.
| Scheme | What it gives | Conditions worth knowing |
|---|---|---|
| MNRE — National Bioenergy Programme (Biomass Programme) | Central Financial Assistance of ₹21 lakh per MT-per-hour for non-torrefied pellet plants, or 30% of plant & machinery cost, whichever is lower — capped at ₹1.05 crore per project. Briquette plants get ₹9 lakh per MTPH, capped at ₹45 lakh. Torrefied plants are supported at a higher rate. | Apply for in-principle approval through the BioURJA portal before commissioning. Revised guidelines dated 27 June 2025 tie the full CFA to an 80% capacity utilisation factor over 10 continuous hours, pro-rata below that, and nil under 50%. |
| CPCB — paddy straw pelletisation & torrefaction | One-time aid of ₹14 lakh per tonne-per-hour for pelletisation, capped at ₹70 lakh per proposal; ₹28 lakh per TPH for torrefaction, capped at ₹1.4 crore. | Paddy straw only, and only from NCT of Delhi, Punjab, Haryana and the NCR districts of Rajasthan and Uttar Pradesh. Disbursed via State Pollution Control Boards. No O&M support. |
| RBI — Priority Sector Lending | Biomass pellet manufacturing is an eligible PSL activity. | Changes what your working capital costs — often worth more over a decade than any credit you were chasing. |
| SAMARTH vendor listing | Placement on the Ministry of Power's published vendor database, visible to procuring GENCOs. | Access to tenders. NTPC alone has run tenders in the hundreds of thousands of tonnes. |
The short version
If you remember only this
- The credit follows the boiler, not the invoice. The reduction happens where the coal isn't burnt — inside the plant's boundary. Selling the fuel does not transfer it.
- For the mandated 5–7%, nobody gets a credit. The law already requires it, so it is not additional, so it cannot be issued — not to the plant, and not to you.
- Your buyer has no carbon revenue to share. It is buying RPO compliance and penalty relief. Thermal power isn't even a CCTS compliance sector. Price accordingly.
- Put an environmental-attributes clause in anyway. Concede RPO, reserve carbon rights above the mandate, carve out your upstream, keep the data. It is free.
- The real carbon opportunity is off the grid. Industrial and captive boilers switching from coal voluntarily — that is where additionality survives and where you can be the project developer instead of the vendor.
- Aggregate or don't bother. One boiler cannot carry validation and annual verification. Twenty can.
- Take the subsidy that exists. MNRE CFA, CPCB support, PSL lending and SAMARTH listing are worth real money now, unlike a credit that cannot be issued.
Running a pellet line, or planning one, and want to know where the carbon actually is? Ask for a free eligibility check. We will map your feedstock, your buyers and your contracts against what can genuinely be registered — including when the honest answer is that nothing can.
Current as of August 2026. General information only — not legal, financial or regulatory advice. Policy positions, mandate percentages and subsidy rates change; verify against the current Ministry of Power, MNRE, CPCB and BEE notifications before making an investment decision.
Frequently asked questions
I supply pellets to a thermal power plant. Can I claim the carbon credits?
No, not by default. A carbon credit is issued to whoever's project boundary the emission reduction occurs in. The reduction happens when the plant burns your pellet instead of coal — inside the plant's boiler, measured on the plant's meters, removed from the plant's emissions inventory. You are a fuel supplier, and supplying the means of a reduction is not the same as making it. The same rule stops the plant and the supplier both claiming the same tonne, which would be double counting.
So the thermal power plant gets the carbon credits instead?
In principle it is the plant's to claim, under a methodology such as ACM0006. In practice, in India, usually not. Biomass co-firing of 5% became compulsory for coal-based thermal power plants from FY 2024-25 and 7% from FY 2025-26 under the Ministry of Power's revised biomass policy. Carbon credits only pay for reductions that would not have happened without the credit revenue, and an action the law already requires fails that test. So for the mandated share, no credit is issued to anybody.
What about biomass co-fired above the mandated 7%?
That volume is not legally required, so an additionality case can at least be made for it — NTPC has demonstrated 20% torrefied co-firing at Tanda, for instance. But it changes who has an argument, not where the credit sits. It remains the power plant's project, in the plant's boundary, on the plant's meters. As the pellet supplier you would still need it assigned to you contractually.
Can I put a clause in my supply contract giving me the carbon credits?
You can, and you should — but understand what you are getting. Use an 'environmental attributes' clause defining renewable energy certificates, carbon credits, CCTS Carbon Credit Certificates and any future equivalent instrument. Expect to concede the RPO attribute, because RPO compliance is the plant's actual reason for buying and it will not give that up. Reserve carbon rights above the mandated share, and carve out your own upstream feedstock so a blanket assignment does not block claims on the farm side later. It costs nothing and protects you if the rules change.
Should I charge the power plant a premium for the carbon benefit?
No — there is no carbon revenue on the other side to fund it. The plant's benefit is regulatory: power from biomass co-firing counts towards non-solar Renewable Purchase Obligation, and co-firing avoids penalties, which are substantial — six plants faced roughly ₹61.85 crore in combined penalties in December 2025 for missing targets. Thermal power generation is not one of the nine notified CCTS compliance sectors either, so the plant is not earning compliance credits from your pellets. Price on calorific value, reliability and penalty pressure, not on carbon.
Where can a pellet manufacturer actually earn carbon credits?
By supplying buyers nobody is forcing. Industrial and captive boilers — textile mills, paper units, food processors, chemical plants, distilleries, brick kilns — burn coal or furnace oil for process steam with no co-firing mandate on them. If one switches to biomass, that is a genuine, project-caused change and additionality survives. The route is a fuel-switch methodology such as CDM's AMS-III.B, and India's CCTS offset mechanism list includes industrial fuel switching and biomass-based heat and electricity, for projects starting on or after 1 January 2025. Crucially, you can be the project proponent rather than a vendor — if you finance or install the conversion, sign the multi-year fuel agreement, hold the metering and register in your own name.
How many credits would an industrial fuel-switch project generate?
A single factory boiler is small. One registered Indian small-scale fuel-switch project, moving a chemical plant's steam generation to biomass briquettes, produced around 7,250 tCO2e a year. At that scale one site cannot carry the cost of validation plus annual third-party verification. The business only works as a programme — twenty or more similar boilers aggregated under one registration, which is the same aggregation logic that makes an FPO viable in a farm carbon project.
Do I get carbon credits for stopping stubble from being burnt?
Barely, and probably not at all. Burning a tonne of straw releases only about 0.08 tCO2e of the gases that are actually counted, because most of the carbon in the smoke was absorbed from the air by that same crop months earlier. There is also a logical trap: if you are paying farmers for their straw, that proves it had value and was not going to be burnt, which removes the additionality. At realistic volumes the annual audit costs more than the claim is worth.
How much CO2 does one tonne of biomass pellets actually save?
Roughly 1.2 tonnes of CO2 when it displaces coal, based on the Ministry of Power's own reported totals — about 814,000 tonnes of biomass associated with close to 0.97 million tonnes of CO2 avoided. The exact figure depends on the calorific value of your pellet and of the coal it replaces; NTPC specifies pellets at a GCV of 3,000–4,200 kcal/kg, and roughly 1.14 tonnes of 3,800 kcal/kg pellets are needed to match a tonne of 6,000 kcal/kg bituminous coal on energy content.
What government support is available for a biomass pellet plant?
Several things, all worth more than the credit you cannot get. MNRE's National Bioenergy Programme gives Central Financial Assistance of ₹21 lakh per MT-per-hour for non-torrefied pellet plants or 30% of plant and machinery cost, whichever is lower, capped at ₹1.05 crore per project, with briquette plants at ₹9 lakh per MTPH capped at ₹45 lakh — applied for through the BioURJA portal before commissioning, and tied to an 80% capacity utilisation factor under the revised guidelines of 27 June 2025. CPCB separately offers ₹14 lakh per TPH for paddy straw pelletisation capped at ₹70 lakh, and ₹28 lakh per TPH for torrefaction capped at ₹1.4 crore, restricted to paddy straw from Delhi, Punjab, Haryana and the NCR districts of Rajasthan and UP. The RBI treats biomass pellet manufacturing as eligible for Priority Sector Lending, and the SAMARTH vendor database lists suppliers to procuring GENCOs.
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Devendra Kumar Jha
LinkedIn ↗Devendra is a Director of Agpro Consulting Private Limited and leads AgriCarbon Credits — its sister concern, and the agriculture arm of carboncreditconsulting.in — helping Indian farmers, FPOs, cooperatives and agribusinesses assess, design and monetize agriculture carbon projects.
- Agri-carbon project design & advisory
- FPO, cooperative & agribusiness programmes
- Soil carbon, agroforestry & rice methane pathways

