MiCA Crypto Alliance Provides Feedback on MESMERICE Sustainability Standards for Crypto Assets
The MiCA Crypto Alliance submitted its formal feedback to the MESMERICE study, led by Trinomics on behalf of the European Commission. The study explores how sustainability standards should apply to crypto assets across Europe.
As part of the consultation process, our General Secretary, Juan Ignacio Ibañez, contributed both through an interview and by attending a webinar where interim findings were shared. We welcomed the opportunity to engage in both settings and to help strengthen the proposed framework.
Our response highlighted several areas where further clarity and refinement are needed:
- Energy use should not be treated as intrinsically harmful. The source and context of energy are critical, with off-grid renewables and demand-response systems reshaping impacts.
- Avoid overly indirect environmental metrics. Generic LCA models often fail to reflect how blockchain networks operate in reality.
- Land use must be treated as absolute, not per transaction. Misapplied transaction-level metrics risk misleading comparisons.
- Per-transaction metrics distort real impact. They ignore Layer 2 scaling, flatten transaction value differences, and overlook the purpose of energy use.
- Protocol design matters more than consensus labels. Not all proof-of-work or proof-of-stake systems are alike.
- Industry-to-industry comparisons are preferable to country benchmarks. For example, comparing Bitcoin to gold, not to national energy grids.
- Carbon estimates must reflect current data. Excluding off-grid mining and Lightning Network activity leads to overstated emissions.
- Technical accuracy is essential. Bitcoin mining did not cause Spanish energy outages, and mining is not the same as asset creation.
We thank the Trinomics team for inviting Juan to contribute to the interview and webinar. We welcomed the opportunity to contribute and hope our feedback supports the development of clear, proportionate, and technically grounded environmental standards for the sector.
