$11.66
$21.90
bear $11.66
base $17.33
bull $21.90
margin of safety $11.00
market price* $18.95
Business condition attached to the margin of safety
The 2026 EU ETS review has concluded without lowering the legislated cap reduction path (4.3% a year through 2027, 4.4% from 2028) and without adding a hard price ceiling or a large release of reserve allowances.
What it is. The COtwo Advisors Physical European Carbon Allowance Trust is not an operating company. It is a grantor trust, listed on NYSE Arca, that holds European Union Allowances (EUAs) - the permits that power plants, factories and airlines covered by the EU Emissions Trading System must surrender for each tonne of CO2 they emit - in an account at the EU's Union Registry. The trust began operating on June 17, 2025. At May 31, 2026 it held 19,700 EUAs (0.197 per share) marked at $92.75 each (about EUR 79), plus $13,754 of cash, against $1,160 of liabilities, for a net asset value of $18.40 per share on 100,000 shares. Its only recurring cash flow is outgoing: a sponsor fee of 0.79% of net assets a year, which the sponsor uses to cover all other trust expenses. In its first fiscal period (to November 30, 2025) that fee, net of $378 of interest, was $7,332, or $0.05 per share; there is no debt and no interest expense. How we value it. A trust like this earns nothing, so there are no business earnings to project. What a shareholder owns is a fixed, slowly shrinking slice of EUAs that can be sold at the market at any time, minus the ongoing fee. We therefore value each case as the realisable value of the EUAs and cash per share, less the present value (at 6%) of ten years of sponsor fees, which is roughly the cost of holding the shares for a decade. We charge the fee for ten years rather than forever because shares can always be exited at market, and the trust can be liquidated at asset value; the fee is a cost of holding, not a permanent liability. We do not credit any rise in carbon prices from the passage of time; each case instead asks what an EUA is worth under a named, already-legislated or already-observed condition. The trust's reported operating cash outflow of $1.64 million in its first period is simply the purchase of the EUAs it holds, not a cost of running it, and we treat it that way. What drives the value. EUA prices are set by EU law, not by a business. The supply cap falls by 4.3% a year through 2027 and 4.4% a year from 2028, free allocation to industries covered by the Carbon Border Adjustment Mechanism is being phased out from 2026, and the Market Stability Reserve removes surplus permits. Against that, the trust's own May 2026 quarterly report highlights politically driven regulatory risk from the comprehensive review of the EU ETS expected to conclude at the end of the third quarter of 2026, and the Market Stability Reserve can also release allowances when prices spike. Under the current framework EUAs have traded as high as roughly EUR 100 (early 2023) and as low as roughly EUR 53 (February 2024). Base case: $17.33 per share. EUAs stay at the May 2026 mark of $92.75; the holding is worth $18.40 per share and ten years of fees cost about $1.07 per share in today's money. No price change is credited in either direction, because we cannot name evidence that moves the median price from where the market sets it today. The trust owes essentially nothing ($0.01 per share), so asset value and shareholder value are the same. Bear case: $11.66 per share. The 2026 ETS review loosens supply or adds price containment and EUAs fall back to about EUR 53, the low they actually reached in February 2024 under the same legislative framework. That puts the holding at about $12.38 per share, less about $0.72 of fees. A further, smaller risk is the trust's size: with under $2 million of assets and only two creation baskets of 50,000 shares outstanding, the sponsor's fee income is about $15,000 a year, and the shares traded at a 4.5% discount to net asset value at the end of May 2026. If the trust were wound up, holders would receive their share of the EUA proceeds after costs, so this is mainly a trading-cost risk rather than a loss of the underlying value. Bull case: $21.90 per share. The legislated cap reduction and the phase-out of free allocation tighten supply as written and EUAs return to about EUR 100, the level reached in early 2023 under the same framework. The holding would be worth about $23.25 per share, less about $1.35 of fees. What would make this wrong. The value of these shares is the value of an EU carbon permit and nothing else. A political decision to weaken the system - a lower cap trajectory, a hard price ceiling, or a large release of reserve allowances - would cut the value directly, and a falling euro against the dollar lowers it too. Conversely, the shares only reflect a gain if carbon prices rise; the trust itself adds no value and charges 0.79% a year. The margin-of-safety price is set well below today's asset value, so that a return to the asset value seen today, rather than a speculative rally, is what the estimate relies on.