The UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE (UNFCCC) is an international environmental treaty that was adopted in 1992 by 154 nation states at the UNITED NATIONS CONFERENCE ON ENVIRONMENT AND DEVELOPMENT (UNCED), also known at the ‘Earth Summit’ which took place in Rio de Janerio, Brazil. It entered into force in 1994. The ‘Convention’ sought the stabilization of greenhouse gas concentrations in the atmosphere and placed different responsibilities on three categories of signatories; developed countries (listed in annex 1), developed countries with special financial responsibilities (listed in annex 2), and developing countries (listed in annex 3). Annex 1 countries were called upon to adopt national policies with a view to reducing carbon emissions to their 1990 levels. Annex 2 countries were called upon to provide new and additional financial resources to meet the costs incurred by developing countries in complying with their obligation to produce national inventories of their carbon emissions. Annex countries were then required to submit their inventories to the UNFCCC.