EU’s Carbon Removals Certification Framework is certifiably problematic

Alarm bells for the climate were set off last week by a leak of the European Commission’s proposal for a Carbon Removal Certification Framework (CRCF). The draft leaves many important questions unanswered and vital issues unaddressed, and could usher in an era of greenwashed and money-wasting carbon removals. 

On 30 November, the European Commission is due to publish its proposal for a Carbon Removal Certification Framework (CRCF). The CRCF regulation is supposed to set out how carbon removals will be certified, monitored and accounted for in the EU (if you are unfamiliar with carbon removals, here is an overview of what they are, their potential and pitfalls). The regulation will cover removals that involve permanent storage, as well as more problematic temporary, and hence reversible, removals such as storage in soils and products.

While the CRCF has the potential to address a gap in the EU’s current climate policy framework,  our analysis of a leak of the draft proposal shows that it runs the serious risk of becoming a tool for greenwashing, wasting precious climate finance and ultimately harming the EU’s climate targets and actions. 

However, the Commission’s barebones proposal for a regulation leaves many important questions unanswered and many vital issues unaddressed.

Even the basic question, “What is a removal?” is not consistently answered, with the proposal clearly stating that permanent storage has to last for at least several centuries. However, this correct threshold is then not applied in all so-called ‘carbon removal activities’. Likewise, and equally astounding, emission reductions in the agricultural and forestry sectors, which do not actually remove carbon from the atmosphere but simply add less, could somehow be certified as removals. 

For carbon removals to act as effective climate tools, they must guarantee that the carbon extracted from the air is stored safely and securely for several centuries. Despite the vital importance of this multigenerational storage, the Commission fails to set rules for, or even define, permanent storage, who is liable for reversals, and what liability they carry. In addition, reporting requirements, monitoring periods, additionality or baselines are poorly defined and regulated. These may be technical concepts, but they are crucial to determine whether an actual carbon removal is taking place, or just something that vaguely resembles one. If false removals would be certified under the CRCF, public money could be wasted on projects with little to no climate impact and companies could make brazen greenwashing claims based on those false removals. 

On the critical issue of responsibility in case a removal is reversed and the carbon ends up back in the atmosphere (also known as liability for reversals), the leaked proposal only refers to addressing them through ‘appropriate liability mechanisms’. This failure to set out clear rules for who is responsible for reversals that might occur decades or even centuries from now leaves the door wide open to temporary solutions masquerading as permanent storage, which effectively lands future generations with the burden of making up for today’s low quality removals – in addition to the consequences of emissions and climate change itself. At worst, this could mean that companies sell non-permanent removals to other companies that can pretend that their permanent fossil emissions are no longer important or their responsibility, and that no one is held responsible or accountable once those captured GHGs are released back into the atmosphere.

On top of this, social safeguards have been completely forgotten – land grabbing and other impacts on local communities and smaller scale farmers are currently being entirely ignored by this regulation. 

In addition, biomass is described as carbon neutral, even though this has been proven to be a patently false assumption many times. The planting, growing, harvesting and transporting of biomass all generate significant emissions, while the carbon embedded in burned biomass might take years or decades to be recaptured by, for example, trees planted to replace logged and burned trees. 

What’s the use?

The key question the proposal focuses on is how removals can be certified. The equally important question of how removals should be used is deemed beyond its scope and not answered at all, which poses the danger that carbon removals will be misused for the wrong purposes, such as delaying emission reductions and greenwashing, figuratively sucking oxygen away from their most effective utility of removing excess carbon from the atmosphere after all possible emissions reductions have been achieved. 

This also means there is no clarity on how the CRCF would fit into the EU climate policy framework, such as obvious interactions with the Land Use, Land-Use Change and Forestry framework (LULUCF) regulation, which also covers removals by forests, or the Common Agricultural Policy (CAP). Different ‘types of financial incentives’ for removals are set out, some of which are highly problematic such as voluntary carbon markets, but without outlining how the certification of removals will need to be radically different depending on the envisaged use of the removal. 

Three types of “carbon removal activities” with very different storage durations (geologic storage, carbon farming and products) are listed. These three types cover a wide variety of potential removal methods, with very different potential storage timelines and risks of reversal. They should be kept separate to ensure transparency on the value of the activity for the climate. 

However, these three types of storage are not kept separate in any way. The CRCF risks labelling storage in products and in soils as equally valuable and long-term as geological storage, even if such storage shouldn’t justify being accounted as a removal. In addition, several methods under the heading of carbon farming (most notably soil organic carbon sequestration) are practically impossible to monitor and verify, meaning reversals are likely to happen undetected. Public funds could, then, be invested in sequestering carbon in soils, which would then be reported as part of the EU’s climate targets, while any reversals couldn’t be detected and would, therefore, be ignored.

The proposal states that GHG emissions due to the implementation of a carbon removal activity have to be accounted for and subtracted from the carbon removals, but this requirement is waived for carbon farming activities. While this is likely done to promote peatlands rewetting (a removal method that would first lead to emissions before becoming a large carbon sink), it creates a massive loophole. Farmers could, for example, burn or cut down a forest to clear land before applying to be certified for removing carbon, and then get paid for storing carbon in those recently cleared soils.

Do no harm

That said, there are also some very good points in the proposal. The most important ones relate to the environmental sustainability objectives that need to be taken into account. All activities must have a ‘positive or neutral impact’ on a host of objectives, including climate adaptation, protection of water resources, pollution prevention, and, critically, protection and restoration of biodiversity and ecosystems. Even better, carbon farming activities and anything related to the production of biomass (which includes bio-energy and carbon capture and storage) must have a positive impact on all these sustainability objectives. This closes the door on many potentially damaging practices.

Once the proposal comes out on 30 November, Members of the European Parliament and representatives of EU countries will start the processes of transforming the Commission’s proposal into legislation. The massive loopholes and yawning gaps in the Commission’s proposal may give the co-legislators free rein to engage in political horse trading and to water down this faulty blueprint. MEPs from rural areas, for example, may leap at the opportunity to fill in the many blanks in such a way as to maximise subsidies for agricultural businesses, with minimal ‘administrative burdens’ on monitoring carbon stocks and, therefore, no to little climate benefits. The European Commission needs to show leadership and fill in these blanks before the proposal comes out or they will ignite a free-for-all, with the climate losing out. Removals need to have an impact on slowing down or even reversing the climate breakdown, otherwise they are, at best, a distraction from the urgent need for emission reductions.

The key question will be: will this certification scheme become a tool for tackling the climate crisis, or a financial benefit for companies. Carbon Market Watch will be heavily involved in this process to ensure it becomes the former, and target the European Parliament and Council on this legislative file.

Read the joint NGO letter to the European Commission on the CRCF

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