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CRCF: The EU’s carbon removal certification failure

The EU’s lacklustre attempt to forge a certification system for carbon removals is so riddled with holes that the process needs to be rebooted to avoid doing more harm than good.

The Carbon Removal Certification Framework (CRCF) is yet another policy file where the climate has taken a backseat to business and economic concerns. The CRCF will promote greenwashing, rather than prevent it. While the name refers only to carbon removals, it will also certify temporary storage of carbon and even emission reductions from soils.

Carbon Market Watch calls on member states and members of the European Parliament to reject this provisional deal reached last night – the CRCF should be sent back to the drawing board.

“Is the final outcome perfect? No. Is it good enough? Also no,” says Wijnand Stoefs, CMW’s lead expert on carbon removals. “The CRCF deal is deeply problematic. Even the fundamental principle that removals must complement, not substitute, emission reductions has been violated. Instead of providing the strong foundation for future EU carbon removals policy, the CRCF has plunged it into quicksand.”

Litany of errors

The list of mistakes and shortcomings is far too long. 

The CRCF will allow carbon removals, temporarily parked carbon, and emission reductions to be used to offset emissions. This undermines the core principle of removals complementing rather than substituting emission reductions.

The units certified by the CRCF will be double counted by both the voluntary carbon markets, and the EU’s nationally determined contributions (NDC) and climate policies. Allowing both governments and companies to claim the same CRCF results may considerably reduce climate ambition and slow the rate of climate action.

In addition, the CRCF not only accepts but also incentivises short-term storage of carbon, such as in so-called ‘carbon storage products’ and soil, as a climate solution (which has very limited benefits for the climate). To have any climate benefit whatsoever, temporary storage needs to last for at least a century, as our research demonstrates, not the 5 years for carbon farming projects or 35 years for carbon storage products under the CRCF. Moreover, this temporary quick fix could be used for greenwashing purposes to supposedly  ‘offset’ or even ‘inset’ emissions.

The sustainability criteria for biomass are not strict enough, which will likely lead to increased demand for biomass that will destroy nature and threaten biodiversity in and outside the EU. Carbon farming projects should focus on nature protection and restoration, rather than trying to quantify the unquantifiable and monetising uncertain and unreliable soil carbon stocks.

Removals, sequestration in the land sink and emission reductions threaten to be severely overestimated. Current emissions (for example related to forestry practices or coal-fired power plants) will be discounted from the quantification of net-carbon removals. All associated emissions must be fully accounted so as to quantify net removals in a scientifically robust manner.

Hot potatoes and silver linings

Many hot potatoes have simply been pushed down the line to be dealt with again in two years’ time rather than dealing with them now. This includes the potential inclusion of livestock emission reductions (which should be out) and the need for corresponding adjustments when units are sold on the private market (which should be in).

“The EU institutions and member states seem to have decided that the CRCF should be a tool for deterring climate action rather than stimulating it,” observed Stoefs. “The EU should have banned offsetting in voluntary and compliance frameworks (e.g. EU ETS and CORSIA) and double counting rather than allow the CRCF to slow down decarbonisation efforts.”

The deal does, however, also contain a smattering of good elements. Mandatory biodiversity co-benefits for carbon farming have been included (though slightly watered down compared with the European Parliament’s initial position), activities with different climate impact will generate different units (the Commission proposal just had one type of unit ignoring the variety of activities under the scheme), the periodic review will take into account the impact of biomass consumed, and CRCF units will initially be ineligible for use towards third-country NDCs or for the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

Far from over

The deal sealed last night is not the final or even arguably the most important step in the development of the CRCF. The first review in 2026 will be critical, and the practice-specific methodologies will also have to decide on many thorny issues such as liability, baselines and additionality. These are not minor issues, and research has shown that the delegation of power in the CRCF is unconstitutional

The creation of methodologies by the European Commission through delegated acts will likely be an opaque and undemocratic process, with limited opportunity for input by civil society and heavily lobbied by incumbent industry. 

All in all, this is a missed opportunity, and it would take years to rectify the CRCF’s obvious failings. In the meantime, the pressure will be on the European Commission to improve the quality of the scheme and its units through the development of environmentally sound methodologies. At the same time, potential buyers of CRCF units should be aware that their quality and climate impact cannot be taken for granted, and proceed with caution. CRCF units should only be used for contribution claims, not for offsetting emissions.

This is why CMW calls on policymakers to reject this deal, and to rethink what would make the CRCF both an environmental and economic success that can genuinely contribute to the EU’s climate objectives. 

“If this deal is not rejected by MEPs and member states down the road, the onus will be squarely on the European Commission to salvage the CRCF through the formulation of watertight and robust methodologies,” concludes Stoefs. “These should only incentivise activities that will actually aid the climate and environment in the real world, not just on paper.”


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