The EU’s carbon removal certification framework aims to increase the use of carbon removals while guarding against greenwashing. What do experts think of the latest draft?
The EU carbon removal certification framework took another step towards adoption when in February, the European Council, the European Commission and parliament reached a provisional agreement.
Proposed in 2022, the CRCF is intended to accelerate the use of carbon removal solutions, which can include the planting of trees, biomass or more advanced technologies that directly capture carbon from the air.
According to the commission, the framework “sets out criteria to define high-quality carbon removals and the process to monitor, report and verify the authenticity of these removals”.
The February agreement also calls on the commission to build an EU-wide registry for removals within four years after the rules come into force — until this registry becomes available, certification schemes should provide public registries for users of removals, including companies, the council says.
The voluntary framework will now be considered by EU member states and the parliament’s environment committee before being given final approval. If adopted in its current format, the CRCF will cover four types of carbon removals:
Permanent carbon removals,
which could include carbon captured by direct air technologies, such as injecting carbon deep underground. This is supposed to store atmospheric carbon for several centuries;Temporary carbon storage in long-lasting products,
such as wood-based construction products, which should last for at least 35 years;Temporary storage from carbon farming
such as forest restoration;Soil emissions reduction from carbon farming,
with enhanced farming practices that protect soil and reduce its loss through erosion.
Temporary storage from both carbon farming and soil emissions reduction activities must last at least five years. Additionally, carbon removal activities must meet four criteria:
Quantitification:
companies will have to be able to prove that the carbon they claim has been removed can be measured;Long-term storage:
this can vary from a minimum of at least five years to several centuries, depending on the type of removal;Sustainability:
removal activities must contribute towards sustainability objectives, such as protecting biodiversity;Additionality:
a carbon project is additional if its associated emissions reduction or removal would not have taken place without the income generated by the sale of its credits.
According to a 2023 report compiled by institutions including the University of Oxford and the German Institute for International and Security Affairs, trees generally store carbon for between 10 and 1,000 years, while, in theory, carbon can be stored in geological formations for as long as 100,000 years.
Harmonisation is tricky
A previous version of the framework conflated the definitions of carbon removal and emissions reduction, says Mark Preston Aragonès, senior policy manager for carbon accounting at non-profit Bellona Europa. However, the creation of the four different types of removals in the latest draft has now resolved this confusion, says a briefing by non-profit Carbon Gap.
“The definition of ‘carbon removal’ is now aligned with that of the Intergovernmental Panel on Climate Change, ensuring much-needed clarity and a clear delineation between carbon removal and emissions reduction,” comments Carbon Gap.
The IPCC defines carbon removal as technologies, practices and approaches that remove and durably store carbon dioxide from the atmosphere, whereas emissions reduction refer to the lowering of an organisation’s or a country’s greenhouse gas emissions.
Bringing the different types of carbon removals under a common framework is not straightforward, however.
“The issue that you have perpetually in this market is that each of these activities is different,” Sebastian Cross, co-founder of carbon rating agency BeZero Carbon, tells Sustainable Views. “Trying to find a list of criteria that can capture that diversity while bringing the harmonisation you need to feed into something like a compliance scheme is hard to do.”
Different government-operated compliance schemes require different information, ranging from additionality tests, project information, ongoing performance monitoring and appropriate safeguards.
Methodologies under scrutiny
The European Commission is now working on developing methodologies for certifying carbon removals under the CRCF. Wijnand Stoefs, carbon removals policy lead at non-profit Carbon Market Watch, tells Sustainable Views that the methodologies used in the framework need to be “ironclad” and “a thousand times better than the voluntary carbon market”. The VCM has been dogged by scandals surrounding the integrity of projects, which last year resulted in a slump in the price of carbon credits.
Stoefs says these methodologies should be set according to conservative baselines and count all related greenhouse gas emissions, subtracting these from the “net carbon removal benefit”. A carbon removal activity provides a net carbon removal benefit when carbon removals (above the baseline) exceed any increase in greenhouse gas emissions arising from the activity’s implementation.
“Methodologies must be science-based, with accurate on-the-ground measurements being a pivotal element to verify the actual results of a project, rather than models with insufficient real-world checks,” Stoefs says. “There can be no doubt about the integrity of these units, but I’m worried that we’re going to get that. I’m not confident that we will have high-quality methodologies – the commission seems intent on rushing into this rather than taking its time.”
While for Preston Aragonès the proposal is an improvement on previous versions of the CRCF, he says: “We’re quite unhappy with the final agreement. It sets the course for removals to be used in an offsetting context when that isn’t necessarily the best way to go forward [with them].”
He notes that the CRCF’s additionality criteria focus on how much an activity goes beyond what is legally required and how much of the removal has occurred because of the activity’s “incentive effect”, rather than how much CO2 has been physically removed by the activity, and how many greenhouse gas emissions have been emitted in the process of doing so.
“While the incentive effect is certainly an important piece of information, it should only be a secondary step to certifying a removal activity — the first being to identify whether or not it is a removal at all,” he says.
Supporting greenwashing outside Europe
Since the framework only applies to activities happening inside the EU, experts have expressed concerns about companies’ access to credits generated outside the union, which could undermine the CRCF.
In its February announcement, the European Council said the commission should consider whether to allow geological carbon storage in other countries, as long as they were aligned with EU safety and environmental standards.
Kasia Wilk, head of public affairs and policy for Europe and Asia at renewable energy company Drax, observed in a blog last year that credits sold outside the EU “could not be subject to the same high standards, unless they are being given the option to comply with the voluntary framework”.
Meanwhile, Stoefs notes: “We’re actually supporting greenwashing activities outside Europe that we are banning and restricting ourselves within our continent.”
The framework is one of numerous attempts by the EU to stop organisations from using carbon removals to mislead consumers and investors. In February, MEPs confirmed a ban on companies making green claims based only on their use of carbon offsets. Companies must have reduced their emissions by as much as possible, and used offsets — which must be certified under the CRCF — only for “residual emissions”, in order to make such a claim.
These restrictions, together with the CRCF, are intended to work alongside the green claims directive — another piece of pending EU legislation intended to protect consumers from greenwashing.
“You shouldn’t really be using removals to offset anything,” Preston Aragonès says. “We would very much like to see a green claims [directive], which effectively bans the term ‘carbon neutral’ for organisations for anything that is not a country, so that we can actually have clarity on how much each entity is emitting.
“If they wanted to pay for removals, that’s fine to report that as well, but to portray it as ‘carbon neutral’ is misleading,” he adds.