Federal Labor has yet to consult three Labor-led regions about the use of Kyoto carbon credits that would undermine their own efforts to curb greenhouse gas emissions to meet Paris climate targets.

The Morrison government has declared it would count an expected surplus of 367 million tonnes of carbon dioxide-equivalent from an "over-performance" during the current Kyoto Protocol. Such an inclusion - not explicitly ruled out by Paris rules - would more than halve the forecast abatement effort of 695 million tonnes.

Kyoto carryovers in play: The Tarong coal-fired power station, near Kingaroy in Queensland.

Mark Butler, Labor's climate spokesman, said his party had "sought advice and is continuing consultation on the issue".

That consultation, though, is yet to include the ACT, Victoria and Queensland - each of which will have emissions reduction goals to 2030 that exceed the national target. Any use of a Kyoto surplus to dilute the Australian goal means their extra ambition could allow other states a free ride.