Words and Phrases - "commodity"

An entity is engaged in the purchase and sale of carbon offsets and enters into a purchase contract with Seller. Is the Offset considered a "financial instrument" for GST/HST purposes; in particular, does paragraph (f) of that term's definition apply to the Offset?

After ruling that the Offset is not considered a financial instrument and is intangible personal property, CRA first referred to para. (f) of the definition and stated:

[The] common dictionary meaning [of “commodity”] generally recognizes the term within the financial market as a bulk good, product, merchandise, article, physical asset, or other type or kind of tangible property. We have not established a direct link or connection between the Offset and any underlying commodity.

Furthermore … the wording within the Agreement, does not point towards these Offsets being in fact traded at any time on a recognized commodity exchange. However, since the Offset is not an option or a contract for the future supply of a commodity, it does not matter if they are traded on an exchange. …

Lastly … [re] paragraph (i) … i.e. "an option or a contract for the future supply of money or anything described in any of paragraphs (a) to (h)" also … has no application in the case at hand. That is, the Agreement does not represent an option or a contract for the right to buy or sell money or a financial instrument at a specified price within a stipulated future time period or a stipulated future date.

… By transferring the Seller's right or interest to the Offset, the Seller is making a supply of intangible personal property … [and] GST/HST will generally apply to this supply if the Seller is a GST/HST registrant making the supply in the course of a commercial activity.