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Why the EU’s rulebook for certifying permanent carbon removals will fail

2026-02-19T16:05:32Z

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0.0–300.0

The webinar attracted 250 registrations, indicating a growing interest in the Carbon Removal and Carbon Farming framework. Discussions focused on the sustainability of biomass, legal concerns, and the principles for permanent carbon removal.

The webinar attracted 250 registrations, indicating a growing interest in the Carbon Removal and Carbon Farming framework, which was once considered a niche topic
Sophia Martin and a representative from WWF introduced the agenda, which includes discussions on the Carbon Removal and Carbon Farming framework and its associated methodologies
A senior official will delve into the sustainability of biomass and the delegated acts related to permanent carbon removals, highlighting their involvement in the commissions expert group
Legal concerns regarding the Carbon Removal and Carbon Farming regulation will be addressed. The focus will be on how the delegated act fails to respect several stipulations outlined in the legal framework
Four basic principles for permanent carbon removal were identified. These include the necessity for carbon to be physically removed from the atmosphere and stored permanently
Issues within the delegated act include the use of biosphere removal for quantifying removals. There is also a lack of monitoring and verification for certain technologies like biochar
The discussion emphasizes the need for sustainable carbon removals. It acknowledges their importance in achieving carbon neutrality while ensuring they do not harm ecosystems or have unacceptable social consequences

300.0–600.0

The Carbon Removal and Carbon Farming framework is a complex accounting and certification scheme that faces significant political pressures. These pressures prioritize simplification over environmental rigor, potentially undermining the framework's scientific integrity.

The Carbon Removal and Carbon Farming framework is an accounting and certification scheme that faces significant complexity and political pressures. These factors hinder its scientific integrity
Political pressures favor simplification, prioritizing ease of use and low red tape over environmental rigor. This leads to a lack of balance in the framework
The framework employs four quality criteria: quantification, additionality, long-term storage, and sustainability. These criteria are essential for certifying removals and emission reductions
Permanent removals are currently limited to specific technologies, including biogenic carbon capture and storage, direct air capture, and biochar. Other technologies are still under consideration
The implications of the framework extend beyond technical accounting. It affects various EU policies related to climate, energy, and environmental regulations
The potential inclusion of permanent removals in the EU Emissions Trading System raises concerns about offsetting fossil fuel emissions. This necessitates precise quantification of these removals

600.0–900.0

The discussion highlights the complexities of carbon accounting, particularly regarding biomass emissions, which are often misrepresented in policy. The European Scientific Advisory Board has called for urgent action on climate change, emphasizing the need for rigorous standards in biomass sustainability criteria.

Removing carbon from forests at the expense of the land sink does not constitute a permanent removal from the atmosphere. This aligns with observations regarding the complexities of carbon accounting
The laws of physics remain unaffected by political ideologies, which significantly impact the rules under discussion. The European Scientific Advisory Board on Climate Change recently urged the EU to act decisively on climate change
Biomass emissions in the EU have been significant since the introduction of policy incentives in the 1990s. These emissions are often counted as zero in policy discussions, despite their substantial contribution to total emissions
The share of biomass emissions is comparable to those of the German economy. This contradicts claims that energy is derived solely from residues, as the increasing use of wood for energy undermines climate action
Sustainability criteria for biomass are undermining climate action, as noted by the Scientific Advisory Board. They stated that RED criteria should not qualify wood used for energy with carbon capture and storage
The delegated act currently under discussion includes relaxed reporting requirements and compliance routes for certification. These measures stem from a political compromise that fails to align with scientific standards

900.0–1200.0

The current framework for carbon removals has significant gaps, particularly in non-energy applications and the eligibility of feedstocks. The reliance on biochar as a permanent carbon removal solution raises concerns due to its association with deforestation and lack of monitoring systems.

Non-energy applications are not covered under the current rules. This creates a significant gap in the framework for carbon removals
The eligibility of feedstocks has been restricted to waste and residues. However, these definitions are still based on the Renewable Energy Directive criteria
Turning whole trees into biochar does not effectively remove CO2 from the atmosphere. It also allows continued Renewable Energy Directive subsidies to persist
Biochar is classified as a permanent form of carbon removal in the delegated act. However, its real-world application is more about carbon storage
The production of biochar has been linked to deforestation and forest degradation. This is particularly concerning in some African countries due to its environmental impact
There is currently no monitoring, reporting, and verification system for biochar. This makes it difficult to assess its effects on agriculture and land use
Carbon Removal and Carbon Farming credits must be certified by voluntary certification schemes. However, these rules are insufficient and have been copied from existing Renewable Energy Directive certification rules

1200.0–1500.0

The certification system for carbon removals has faced structural issues for over two decades, necessitating better regulatory frameworks to ensure climate benefits. The upcoming public consultation on the Renewable Energy Directive rules for the post-2030 period will significantly influence future carbon removal strategies in the EU.

The certification system for carbon removals has faced structural issues for over two decades. There is a need for better regulatory frameworks to ensure climate benefits
The upcoming public consultation on the Renewable Energy Directive rules for the post-2030 period is crucial. It will influence future carbon removal strategies in the EU
The European Commission has significant discretion in adopting delegated acts. However, it must adhere to strict legal limits that prevent changes to essential elements of the law
A key concern is the failure to distinguish between carbon removals and carbon storage. This undermines the scientific and legal integrity of the proposed regulations
The European Commission has breached Article 4 by failing to account for all associated emissions. This is critical for accurately assessing the impact of carbon removal activities
Biochar activities, categorized as permanent removals, do not comply with necessary monitoring, reporting, and verification requirements. This highlights a significant regulatory gap

1500.0–1800.0

The certification process for carbon removals is compromised by a failure to account for all greenhouse gas emissions, including those from carbon stock reductions and harvesting. This oversight undermines the integrity of climate mitigation efforts and raises concerns about the effectiveness of the proposed framework.

A breach of Article 7 and Article 8 indicates a failure to comply with environmental integrity requirements. This includes the need to protect biodiversity and ecosystems during certification processes
The certification process may lead to activities that are net harmful, undermining climate mitigation efforts. Ignoring land sector emissions can exacerbate these negative impacts
Article 4 emphasizes the importance of a quantitative assessment of net removal benefits. All direct and indirect greenhouse gas emissions must be accounted for in the life cycle of activities
The delegated act fails to include essential emissions in its calculations, such as those from carbon stock reductions and harvesting. This oversight compromises the integrity of the certification process
Linking to the renewable energy directive does not absolve the commission from meeting all Carbon Removal and Carbon Farming requirements. Both sets of regulations must be considered to ensure comprehensive compliance
The commissions approach reflects a political compromise that may favor less climate-aware groups. This imbalance raises concerns about the effectiveness of the proposed carbon removal framework

1800.0–2100.0

The proposed carbon removal units face legal challenges due to their weak standards, raising concerns about greenwashing. Organizations are urging policymakers to reject the delegated act and emphasize the need for stronger standards in carbon credits.

Legal challenges are anticipated due to the weak nature of the proposed carbon removal units. Trust in these units is crucial, and weak standards could lead to concerns about greenwashing
Organizations are urging policymakers to reject the delegated act. They emphasize the importance of stronger standards. If the act passes, buyers should seek better alternatives in the private sector
The Carbon Removal and Carbon Farming framework was intended to set a high standard for carbon credits. However, it has become a low benchmark, undermining the goal of improving carbon standards
Concerns have been raised about the integrity of the Carbon Removal and Carbon Farming units. If these units are weak, they will not hold significant value in the market
A comparison of the Carbon Removal and Carbon Farming methodologies with other crediting mechanisms is underway. This analysis aims to identify gaps and areas for improvement in the current framework
The investment analysis and biomass accounting requirements of the Carbon Removal and Carbon Farming framework are under scrutiny. These elements are crucial for ensuring the integrity and effectiveness of carbon credits

2100.0–2400.0

The Carbon Removal Certification Framework allows the European Commission to set baselines for additionality without requiring individual project demonstrations. This raises concerns about the integrity of carbon credits due to insufficient leakage accounting and questionable assumptions regarding the necessity of carbon credits for biochar production.

The standardized approach used by the Carbon Removal Certification Framework allows the European Commission to set baselines for additionality. This method does not require every project to demonstrate additionality individually
Methodology developers for the Paris Agreement crediting mechanism must provide documented evidence justifying the need for incentives from carbon-crediting programs. This requirement is not adequately addressed in the Carbon Removal Certification Framework
The assumption that biochar production requires carbon credits is questionable. The International Biochar Initiative reported that 50% of biochar produced in 2023 was made without such revenues
Accounting for biomass use is a significant issue. The Paris Agreement crediting mechanism requires full leakage accounting for emissions created by diverting biomass to Carbon Removal Certification Framework activities, while the framework does not have such requirements
The Paris Agreement crediting mechanism prohibits diverting biomass from existing uses to prevent leakage. In contrast, the Carbon Removal Certification Framework allows using biomass with existing uses, raising concerns about potential emissions implications
The lack of stringent leakage provisions in the Carbon Removal Certification Framework could undermine the integrity of carbon credits. This is especially concerning when compared to the safeguards established by the Paris Agreement crediting mechanism

2400.0–2700.0

The Carbon Removal and Carbon Farming framework faces significant challenges due to inadequate leakage accounting, which may lead to increased biomass consumption and higher emissions. Current carbon markets are characterized by low quality, raising concerns about market integrity and the effectiveness of carbon credits.

The lack of appropriate leakage accounting in the Carbon Removal and Carbon Farming framework risks increasing biomass consumption due to carbon removal activities
If leakage is not properly accounted for, it may lead to higher emissions in both the European Union and biomass-exporting countries
Current carbon markets exhibit characteristics of a low-quality market. Transparency issues favor lower-quality credits, which is problematic for market integrity
The Carbon Removal and Carbon Farming framework should strive to meet integrity standards. This alignment with best practices in carbon markets ensures that it does not compromise on quality
There is a tension within the Carbon Removal and Carbon Farming framework between adhering to European Union regulations and establishing a robust standard-setting instrument for carbon markets
A review of the Carbon Removal and Carbon Farming framework in 2026 presents an opportunity to enhance its robustness. This can help align it with the Permanent and Agricultural Carbon Market framework
Concerns about offsetting risks arise as the European Commission considers integrating permanent removals into the EU Emissions Trading System
The voluntary carbon market currently serves as the primary financing source for Carbon Removal and Carbon Farming activities. However, it is dominated by actors looking to offset their emissions

2700.0–3000.0

Concerns about double offsetting in the EU's Emissions Trading System highlight the lack of mechanisms to prevent the same carbon removal units from being used for multiple offsets. The urgency of addressing the climate crisis necessitates immediate action to enhance carbon removal efforts and reduce emissions effectively.

Concerns about double offsetting arise from integrating permanent carbon removals into the EUs Emissions Trading System. For instance, a carbon capture and storage plant in Stockholm has sold units to a major tech company while also receiving state subsidies
The current framework lacks a mechanism to prevent double offsetting, which poses a significant risk. Without proper checks, the same carbon removal units could offset emissions from multiple sources, undermining the systems integrity
A hope for the future is establishing a separate framework for permanent carbon removals. This framework should complement emission reductions rather than replace them, ensuring that carbon removals serve as an additional pillar of climate action
In the short term, the Technical Review and Consultation Framework can enhance knowledge about carbon removal technologies and their quantification. A quicker review process with more data requests, especially in the biochar sector, could facilitate learning and improve methodologies
The methodology for biochar application does not adequately consider its impact on soil carbon. It fails to account for the potential effects on soil organic carbon, which could lead to unintended consequences
There is a risk of double counting if biochar is applied to soil that also qualifies for soil organic carbon certificates. This overlap could result in credits being issued for both, which is unacceptable from an environmental perspective
The urgency of addressing the climate crisis is emphasized, as waiting for long-term benefits is not feasible. Immediate action is necessary to reduce emissions and enhance carbon removal efforts effectively

3000.0–3300.0

The counterfactual scenario is essential for assessing the impact of logging on carbon sequestration. The complexity of defining waste and residues in the wood industry complicates accurate evaluations.

The counterfactual scenario is crucial for understanding the impact of logging on carbon sequestration. Evaluating what would have happened if a tree had not been logged is essential for accurate assessments
Defining what constitutes waste and residues in the wood industry is complex. The current system allows operators to determine residues, complicating the identification of true waste materials
The cascading principle recognized in the Carbon Removal and Carbon Farming framework aims to ensure compliance with regulations. However, the implementation of this principle at the national level remains uncertain
Incentivizing the production of energy and carbon units from residues can lead to a windfall effect. This could encourage excessive production of residues solely for revenue generation
Concerns about the origin of sequestered carbon in projects like Baytrait highlight the importance of counterfactual analysis. Understanding whether carbon comes from the atmosphere is vital for evaluating project effectiveness
A reduction in logging in Sweden could have achieved significant carbon removal at a lower cost than current projects. This raises questions about the efficiency of public funding for climate initiatives

3300.0–3600.0

The quantification of carbon removals is complex, and simplifying feedstock criteria could alleviate burdens on the industry. The recognition of the Cascading News Principle in the Carbon Removal and Carbon Farming framework is a positive step, but its limited application does not fully address broader issues.

The quantification of carbon removals is complex. Simplifying the feedstock criteria could alleviate burdens on the industry. Excluding dedicated crops and forest biomass would narrow the pool to only fast-decaying residues
Recognition of the Cascading News Principle in the Carbon Removal and Carbon Farming framework is a positive step. However, its application remains limited to national subsidies, which does not fully address broader issues
Private standards for carbon certification have not been systematically compared to the Cascade approach. Some private standards may offer more robust investment analysis, but it is unclear if they are generally superior
Concerns about imported biomass highlight the risks of indirect land use changes. The EUs inability to monitor biomass sourced from certain countries complicates compliance with environmental regulations
The Carbon Capture and Storage directive includes liability and monitoring rules. These rules incentivize proper CO2 storage practices, but the long-term storage of CO2 presents inherent risks that require ongoing oversight
The current methodology for direct air capture has significant flaws, particularly regarding renewable energy usage. It allows for potential misuse of renewable energy credits, which could undermine the energy transition

3600.0–3900.0

The proposed rules for certifying permanent carbon removals contain significant loopholes that could undermine their effectiveness. Without addressing these issues, the rules risk failing to deliver real benefits for the climate and environment.

The proposed rules for certifying permanent carbon removals contain loopholes that undermine their effectiveness. If these issues are not addressed, the rules may fail to benefit both the climate and the environment
BiocCS, biochar, and direct action are particularly problematic under the current methodology. These methods require improved certification processes to minimize risks and ensure genuine environmental benefits
Concerns have been raised regarding the lack of trust in the proposed carbon removal methodologies. The absence of robust verification mechanisms could result in misleading claims about progress in carbon removal efforts
The webinar emphasized the need to object to the current rules before implementation. Failing to act could lead to a situation where the EUs carbon market is filled with ineffective solutions
Participants discussed the necessity for concrete improvements in the certification process for carbon removals. Suggestions have been made to the commission over the past three years to enhance the credibility of these methodologies
The discussion highlighted the potential damage caused by the flawed certification rules. Many problems have been identified, but time constraints limited the ability to address all concerns during the webinar