If done well the Carbon Removal Certification Mechanism (CDR-M) can determine what is actually Carbon Dioxide Removal (CDR) or not, and keep false solutions out of this field. Time and resources are scarce and must be invested in real removals, and not in CCU and temporary storage. These may have climate benefits (by crowding out fossil carbon or delaying emissions), but that does not make them equal to CDR. 

A key issue for the certification mechanism is not addressed in this questionnaire or in the related call for evidence: what are the certified ‘units’ or ‘methodologies’ going to be used for – where will demand come from?

If the CRC-M leads to inclusion of removals in EU emission reduction policies (such as the ETS or ESR) then it will be a very dangerous distraction and a big mistake leading to, at best, a zero-sum game.