The Carbon Removal and Carbon Farming (CRCF) framework is being implemented through a range of methodologies, each representing different methods that are deemed to have the potential to deliver carbon removals or emission reductions and/or increased carbon sequestration in the land sector.
This document looks at cross-cutting and specific issues for the so-called ‘permanent carbon removal’ methods (direct air capture and storage (DACCS), biomass with carbon capture and storage (BioCCS), and biochar), based on the draft delegated act published by the European Commission in July 2025.
This analysis builds on Carbon Market Watch’s (CMW) internal review of the draft delegated act, and the expert analysis of Oeko-Institut, which has collaborated with CMW to provide an independent review of an earlier version of the methodologies based on their extensive experience assessing voluntary carbon market methodologies.
The results are conclusive and damning. The draft delegated act contradicts the basic legal requirements of the CRCF and standard integrity rules present in many private sector methodologies.
There are four main concerns that are critical to resolve if these CRCF methodologies are to be considered credible.
First, additionality criteria are lacking, ignoring any potential future EU or member state level removals policy, and the emergence of public subsidies (which are already starting to be discharged).
Second, all biomass is wrongly deemed carbon-neutral (building on the definition written in the problematic Renewable Energy Directive – RED). Even though the CRCF legal text goes beyond the RED in terms of how it considers biomass accounting and sustainability. The methodologies should either quantify and address leakage concerns (such as indirect land use change), or, at the very least, explicitly ban the most damaging sources of biomass (such as forest biomass, imported biomass and dedicated crops). If not, the CRCF will lead to ecosystem degradation through demand (indirect or direct) for new land and biomass resources.
Third, long-term monitoring and liability is severely lacking from the biochar sections of the draft delegated act even though the CRCF legal text makes it clear that any ‘permanent’ removal methodology has to be consistent with the terms outlined in the CCS Directive. This rule is followed in the DACCS and BioCCS methodological sections.
Each of these concerns exacerbates a fourth problem: the lack of use cases for any units that are issued by certified projects. The European Commission missed out on a once-in-a-decade opportunity to push for a permanent removals target in its proposal to revise the EU Climate Law, even ignoring the advice of their own scientific advisory body. Without a defined and environmentally sound use case, it is impossible to consider whether these methodologies are ‘fit for purpose’ as the purpose remains hypothetical and unknown.
Oeko-Institut has warned that the current draft methodologies, “continue to set a much lower standard than the Paris Agreement Crediting Mechanism and best practice in the voluntary carbon market”, and that as it stands “the vast majority of CRCF units will not represent any actual emission reductions or removals”.
In addition, Oeko-Institut researchers state that “[t]he proposed CRCF methodologies are among the lowest quality methodologies that [Öko-Institut has] reviewed so far,” and that “[w]ithout fundamental improvement of the methodologies, the CRCF could seriously undermine EU climate action”.
If the final delegated act does not address these overarching and key issues, it will likely be legally challenged, creating uncertainty for developers and any potential use cases of units. In addition, any projects or units certified will be considered low-quality, undermining overall trust in the CRCF and any climate policy that builds upon it.
Buyers beware – the CRCF, as it stands, is not at all a guarantee of quality.
