In a Nutshell
The European Commission has proposed a voluntary regulatory framework for the certification of carbon removals (CRCF), which will be the first of its kind in width of covered CDR methods, pending adoption by co-legislators. The stated goal is to foster and accelerate the scale-up of sustainable carbon removals, which includes a wide variety of CDR methods to be applied by land managers, industries, and others to capture and store atmospheric or biogenic CO2, as well as fight greenwashing, and harmonise carbon removal market conditions.
The proposal includes and distinguishes 3 types of carbon removal categories: carbon farming (such as reforestation and soil carbon management), permanent carbon storage (such as BECCS and DACCS), and carbon storage in products (such as wood-based construction materials). In order to ensure the quality of carbon removals certified under the framework, removals need to meet several quality criteria (so-called “QU.A.L.ITY” criteria), covering the aspects of quantification, additionality, long-term storage, and sustainability.
Under the framework, the European Commission, assisted by an expert group, will develop methodologies for the certification of a range of carbon removal methods and recognise certification schemes. The certification schemes will have the obligation of listing certified removals in interoperable public registries, while certification bodies, supervised by Member States, will carry out certification audits and the issuing of certificates.
In its current state, the proposal does not align with scientifically widely accepted definitions of carbon removal as the definition also covers emissions reductions. It also does not outline any rules for how the carbon removal certificates generated under the framework could or should be used. The certificates could be used in corporate reporting, in contracts in supply chains, in voluntary markets, or to receive public support for carbon removal activities.
What's on the Horizon?
2023: In the next steps, the European Parliament rapporteur on the file (MEP Lidia Pereira, EPP, PT) will prepare her initial report, and discussions in the Parliament and Council will continue.
- The draft report is expected to be voted on in the Parliament’s Environment committee in September 2023 and then in its October plenary session.
- In the Council, a general approach on the text among EU Member States is expected in Autumn 2023.
2023: The expert group on carbon removals kicked off their work in March 2023. Among other tasks, the group will be providing technical advice to the Commission on the development of the methodologies under the CRCF.
2023: In parallel to the legislative process, work will be ongoing on detailed methodologies for different carbon removal activities that will be set out in Commission delegated acts.
Within one year of the implementation of CRCF, the Commission will have to assess the potential inclusion of carbon storage in products in scope of the LULUCF Regulation.
By 2026, the Commission will have to assess the potential inclusion of carbon removals with permanent storage in the EU ETS.
Deep Dive
Aim of the file
The CRCF will be the EU’s first certification framework that focuses exclusively on carbon removals. The stated goal of the file is a certification framework which creates trust in the quality and reliability of certified carbon removals among carbon removal providers, certificate buyers, and the public. The proposed framework also aims to increase transparency in the field of carbon removal certification, by creating public registries and methodologies for a wide variety of carbon removal methods, while also outlining requirements for monitoring, reporting and verification. As a result, interest and willingness to fund carbon removal activities and purchase certificates are expected to increase, leading to an expansion of carbon removal activities by current and potential operators. If adopted by co-legislators, the framework will form the basis of recognising and rewarding land managers, industry, and other carbon removal activity operators for high-quality carbon removals and their contribution to reaching the EU’s climate change mitigation goals.
Meaning for climate goals
By establishing this framework, the European Union works towards reaching its goal of climate neutrality in 2050 and net-negative emissions thereafter, both of which will rely heavily on significantly upscaling carbon removal. As the first legislative file focusing primarily on carbon removals, it also contains a definition of which, in the current proposal, also includes emissions reductions. Furthermore, the proposal does not provide any rules around the potential uses of certificates. Potential uses envisioned by the Commission range from the use of certificates to access funding from policies, such as the CAP, to the use on voluntary carbon markets.
Room for improvement
- Eliminate ambiguity as to what is and is not a removal
The current definition of carbon removals in the proposal also includes emissions reductions from biogenic carbon pools, and is not aligned with broad scientific consensus (see e.g., IPCC definition). In order to avoid conflation of emissions reductions and removals, and to allow the CRCF to become a global model for carbon removal certification, emissions reductions need to be excluded from the definition. - Ensure a strict separation between higher-durability and lower-durability removals
The currently proposed storage categories do not clearly differentiate CDR methods based on their carbon storage durability nor separate biological from geochemical storage media. Separation of these storage media is essential as the need and difficulty of MRV vary significantly between CDR methods based on their storage media. - Equip the framework to track how carbon removal is used so inappropriate claims can be policed
The CRCF requires provisions determining permitted uses of carbon removal certificates and certified units, to prevent mitigation deterrence, greenwashing and the erosion of public trust, especially regarding compensation claims for fossil fuel emissions based on lower-durability removal certificates. The current proposal lacks guardrails as to which claims can be made based on the characteristics of generated certificates and the CDR methods used to generate them.
Timeline
Communication on Sustainable Carbon Cycles by the European Commission announcing the development of the framework
Proposal for the certification framework adopted by the European Commission
First meeting of European Commission expert group on carbon removals
General approach expected to be reached by Member States in the Council
Development of methodologies for certification of different carbon removal activities
Trilogues between EU institutions and provisional agreement expected
Expected entry into force of the CRCF
Commission report expected on the potential inclusion of carbon storage in products in scope of the LULUCF Regulation
Commission will have to assess the potential inclusion of carbon removals with permanent storage in the EU ETS
Further reading
- Communication on Sustainable Carbon Cycles, European Commission
- Impact assessment accompanying the CRCF proposal, European Commission
- A Union certification framework for carbon removals, European Parliament briefing, 2023
- Carbon Gap White Paper: A Guide to Certifying Carbon Removal, 2022
- Carbon Gap reaction to the European Commission proposal on carbon removal certification, 2022
Last Updated
Official Document
Entity of Origin
Year
Policy Type
Status
File Type
Key Institutional Stakeholders
European Commission
DG Climate Action (CLIMA), Unit CLIMA C.3: Low Carbon Solutions (III): Land economy and carbon removals
European Parliament
Committee responsible: ENVI
Rapporteur: Lídia Pereira (EPP, PT)
Shadow rapporteur: Tiemo Wölken (S&D, DE)
Shadow rapporteur: Emma Wiesner (Renew, SE)
Shadow rapporteur: Ville Niinistö (Greens/EFA, FI)
Shadow rapporteur: Anna Zalewska (ECR, PL)
Shadow rapporteur: Mick Wallace (GUE/NGL, IE)
Council of the European Union
Council configuration: ENV
Links to other relevant policies
- Common Agriculture Policy (CAP) can promote the uptake of carbon farming practices by promoting changes in or the introduction of new agricultural practices relevant supported by the CAP.
- Land Use, Land-use Change and Forestry Regulation (LULUCF) covers goals and accounting rules for GHG emissions and removals for the LULUCF sector. CRCF focuses on carbon removals at project level, while the LULUCF looks at carbon removals at a larger landscape and national level.
- EU Emission Trading System (ETS) is the world’s first major compliance carbon market. By 2026, the Commission will have to assess the potential inclusion of carbon removals with permanent storage in the ETS.
- Renewable Energy Directive sets out rules for the sustainable use of biomass for energy generation, relevant to biomass use in BECCS.
- Nature Restoration Law targets increases in carbon stocks in several ecosystems, including in forests and agricultural soils.