Twenty nations including Japan, Italy and Australia may be releasing more greenhouse gas pollution than they agreed to under the Kyoto Protocol.

As a penalty for missing their goals under the treaty, the nations are required to buy permits for every excess ton of carbon dioxide released through 2012. That will total 2.3 billion permits for the 20 nations, according estimates by New Carbon Finance, a research firm in London.

The potential penalty — 36 billion euro, or about ¥4.4 trillion, based on current permit prices — and the fact that only a minority of 37 Kyoto signatory nations may meet their pledges, bode poorly for international efforts to limit global warming.