This study assesses the draft certification methodologies proposed by the European Commission
under the Carbon Removal and Carbon Farming Regulation (CRCF) for carbon farming activities.

According to our assessment, the proposed CRCF certification methodology for carbon farming does not adhere to key integrity principles in the voluntary carbon market and sets a lower standard than the PACM. It includes several shortcomings that risk to undermine the integrity of units issued under the CRCF. Particularly, flexibility in choosing monitoring approaches, insufficient consideration of uncertainty, omission of leakage sources such as ILUC, as well as insufficient additionality and permanence requirements are likely to lead to many CRCF units that are not backed by actual emission reductions or removals.

Several issues we identified contradict principles set in the CRCF Regulation itself, including unclear requirements for updating baselines, omission of leakage sources, missing incentives for maintaining carbon stocks over several decades and missing liability mechanisms to address reversals for soil emission reduction activities.