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

15 December 2022
30 November 2022
7 March 2023
11 May 2023
21-22 June 2023
Sep/Oct 2023
Q3-Q4 2023
Oct/Nov 2023
Q4 2023/ Q1 2024
2023
Q4 2023/Q1 2024
2024
2025
2026
15 December 2022

Communication on Sustainable Carbon Cycles by the European Commission announcing the development of the framework

30 November 2022

Proposal for the certification framework adopted by the European Commission 

7 March 2023

First meeting of European Commission expert group on carbon removals

11 May 2023
Draft report from the rapporteur in the European Parliament

 

21-22 June 2023
Sep/Oct 2023
Expert group meeting on industrial removals
Q3-Q4 2023

General approach expected to be reached by Member States in the Council

Oct/Nov 2023
Expert group meeting on certification process
Q4 2023/ Q1 2024
Expert group meeting on the 2024 work programme
2023

Development of methodologies for certification of different carbon removal activities

Q4 2023/Q1 2024

Trilogues between EU institutions and provisional agreement expected

2024

Expected entry into force of the CRCF

2025

Commission report expected on the potential inclusion of carbon storage in products in scope of the LULUCF Regulation

2026

Commission will have to assess the potential inclusion of carbon removals with permanent storage in the EU ETS

Further reading

Last Updated

24/04/2023

Official Document

Entity of Origin

Year

2022

Status

File Type