The draft EU Carbon Removal Certification Framework is at risk of doing more harm than good to the climate and biodiversity, while encouraging climate inaction.

On 30 November, the European Commission published its proposal for a Carbon Removal Certification Framework (CRCF), which starts putting in place the first very basic building block for a system for the certification, monitoring and accounting of carbon removals in the EU. This is supposed to heed the advice of the Intergovernmental Panel on Climate Change (IPCC) on the need to remove carbon dioxide from the atmosphere if we want to keep global heating below 1.5°C. 

But does it really do so? 

In short, no. This proposal defines carbon removals poorly, equates temporary storage with permanent storage and fails to set limits on the use of these techniques to only those that benefit the climate. In addition, the proposal does not map out how the CRCF will interact with EU policies already dealing with some types of nature-based removals, such as the Land Use, Land Use Change and Forestry (LULUCF) regulation or the Common Agricultural Policy (CAP). This risks slowing down the deep and sustained emissions cuts we urgently need and could pave the way to greenwashing. 

Bad role model

One troubling omission in the draft CRCF is the role that carbon removals will play in EU climate policy and what uses they can legitimately be put to.  While mentioning in the recitals (which are the non-binding part of the legislation) that removals are needed to counterbalance residual greenhouse gas emissions and achieve climate neutrality in the EU, the Commission does not actually outline the roles they envision carbon removals playing in the coming decades and even century to cope with the climate crisis.

The CRCF must be premised on the fundamental principle that removing carbon dioxide must only supplement, rather than substitute, deep emission reductions. Removals are needed to balance the very last emissions that cannot be eliminated and then to mop up some of the excess greenhouse gases in the atmosphere, thereby actively lowering atmospheric greenhouse gases concentrations. Without clarifying this role, the CRCF perpetuates the misconception that carbon removals can be used to postpone emission reductions rather than to clean up the atmosphere, thereby incentivising what is known as ‘mitigation deterrence’, i.e. misusing removals to delay decarbonisation efforts.  

Not only does the CRCF mislead by omission, it leaves the door open for using carbon removals on voluntary carbon markets’, where companies can purchase them to offset their emissions. This indicates that the Commission is happy to engage in offsetting using potentially very low quality removals, which could be worse than zero sum, as the temporarily stored carbon would be at huge risk of re-entering the atmosphere and joining the emissions it was considered to be ‘offsetting’. Thereby enlarging our carbon footprint at a time we need to shrink it massively.

Moreover, giving companies the option of using removals to ‘compensate’ for their emissions could lead to preposterous and greenwashing carbon neutrality claims camouflaging climate inaction. 

Lost in definition

In addition to not answering the question of how carbon removals should be used, the CRCF makes a more fundamental error by giving a deeply flawed answer to the question, ‘What are carbon removals’. It goes without saying that to have a solid and correct certification system, removals should be well defined as a concept first, to ensure that only real removals are being certified. 

The proposal lumps together a broad range of activities, in particular, the CRCF illogically defines emissions reduction from natural carbon sinks as removals. By no means should emissions avoidance or reduction be equated with real removals. For carbon removal activities to act as effective climate tools, carbon must be sourced directly from the atmosphere, stored for at least several centuries and ideally much longer, and the whole removals process must actually capture more carbon than it releases.

This error is compounded by the focus on three types of “carbon removal activities”: permanent storage, storage in products, and carbon farming. Each of these stores carbon for very different durations, presents monitoring difficulties and runs very different risks of reversals, and some of these activities will not lead to removals at all. The irony is lost on the Commission that only one of the three types is defined as leading to permanent storage, which should be a fundamental criterion for all removals. Why are non-permanent removals even included in this scheme? To become a meaningful climate tool, the CRCF should only focus on removal activities – be they nature or technology-based solutions – that end in permanent storage.

The broad definition is problematic also because it ignores the very diverse effects on the climate and ecosystems of each of these methods. For example, in the case of carbon farming, there are major differences in climate impact between carbon stored in trees, soil or peatlands: this proposal ignores those differences. 

Substandard quality

Problems persist when it comes to the quality criteria (QUantification, Additionality, Long-term storage and sustainabiliITY or QU.A.L.ITY) that the CRCF uses for certifying removals, starting with a messy formula for the quantification of carbon removals. At the same time, the definition of the baseline, crucial to quantify the benefit of a removal and ensure it is ‘additional’ to what would have been achieved without the removal activity, is vague and left irresponsibly for future non-legislation (such as delegated or implementing acts whose drafting process allows for limited democratic participation).

The ultimate inconsistency is the criterion of long-term storage. While the general principle is for removal activity to ‘aim’ at ensuring long-term storage, the CRCF allows for the temporary certification of non-permanent carbon farming and carbon storage in products. However, the strategy does not spell out what happens with carbon credits or offsets that have used these temporary certificates. This should be, according to the Commission, a way to incentivise land managers and other economic operators to monitor and keep carbon stored for longer.  However, this doesn’t prevent polluters offsetting permanent emissions with temporary storage. In addition, the use of ‘liability mechanisms’ for reversals is not fleshed out, which means those responsible for the intentional or accidental rerelease of carbon into the atmosphere could get off scot free.

Some relief is given by the sustainability objectives that need to be taken into account by removal projects. The goal is to make sure that removal activities have a ‘positive or neutral impact’ on ecosystems. This includes climate adaptation, protection of water resources, pollution prevention, and, critically, the protection and restoration of biodiversity and ecosystems. However, the specific requirement for carbon farming to have a positive impact on all the sustainability objectives was dropped compared to an earlier version of the proposal, preventing this controversial practice from at least positively contributing to the wellbeing and restoration of natural ecosystems. In addition, even though the sustainability criteria seem to enshrine sound environmental safeguards, the proposal fails to address and implement social protection concerning land rights to prevent land grabbing and protect small scale-farmers and local communities.

Removed from reality

As shaped, the EU’s Carbon Removal Certification Framework is not the climate tool we deserve and need right now. With its ambiguity, the Commission has missed a key opportunity to lay the scientifically sound groundwork for effective, dedicated and separate EU removal targets and policies to complement EU action on climate.

The proposal leaves many crucial questions to be addressed in later stages, creating space for misinterpretation and potential loopholes. This vagueness undermines the purpose of the CRCF itself, which is to fill a gap on removals in EU climate legislation. Moreover, there is a risk that this gap will be filled in counterproductively by the European Parliament and/or the Council of the European Union. 

The science is clear that we will need to remove carbon from the atmosphere this century to help avert the worst of the climate breakdown. Creating a certification system to ensure carbon removals are real is a necessary step to determining how carbon dioxide removal should be delivered, while understanding the environmental and social impact linked to it. Without this, it is just so much hot air.