CMW’s feedback on the role of carbon dioxide removals in the Governance Regulation framework.

Good climate planning is the foundation of effective climate action.

But right now, EU Member States’ National Energy and Climate Plans (NECPs) are falling short, lacking transparency and proper assessments of how permanent carbon dioxide removals (CDR) will actually be deployed to help achieve net zero emissions.

The most popular CDR technologies come with real constraints: they compete for clean energy, water, and land, and can put pressure on food production, biodiversity, and the rights of local communities.

Without rigorous planning, the risk is clear: overreliance on CDR that deters real mitigation efforts and does not deliver.

The fix requires stronger governance at the EU level:

  • Dedicated space in NECPs for permanent CDR planning, assessment & reporting
  • MFF financing tied to the quality and completeness of climate plans
  • Full separate impact assessments on permanent CDR and its resource demand and trade-offs
  • A clear definition of CDR overreliance as insufficient climate ambition

Careful planning for a realistic volume of feasible, safely deployable CDR, with limited trade-offs, is necessary to carve out a credible and functional role for removals in climate policy.

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