This report examines cross-cutting and specific issues in the carbon farming methodologies, covering agriculture and agroforestry on mineral soils, peatland rewetting and afforestation. This analysis builds on Carbon Market Watch’s (CMW) internal review of the draft delegated act, and the expert analysis of Oeko-Institut, GHG Management Institute, Carbon Plan, and Infras, who have previously collaborated with CMW to provide independent reviews of the methodologies (see here and here).

The results are troubling. The draft delegated act contradicts many basic legal requirements of the CRCF and standard integrity rules present in numerous private sector methodologies. The Commission should revisit the draft methodologies before sending them to the European Parliament and Council of the European Union for approval. Failure to do so means the other two institutions should object to the rules and ask the Commission to reconsider and respect the original CRCF mandate during the two-month window they have for feedback. 

This is particularly critical given that, in the upcoming post-2030 package, the Commission plans to use these units as a flexibility tool under the land use, land use change, and forestry Regulation, bearing wider implications for reaching EU targets. In addition, recent research funded by CMW has demonstrated that the CRCF sets a weaker standard than Article 6 of the Paris Agreement, a carbon crediting scheme enabling trading between participating countries. 

This is not only problematic for the EU’s ability to achieve its climate goals but also undermines the EU’s reputation and its ability to influence international climate ambition.