Achieving net zero will require a significant ramp-up of carbon dioxide removal (CDR) alongside rapid decarbonization (IPCC 2023). In practice, we will have to scale from around 2 gigatonnes of CDR to around 10 gigatonnes per year by 2050. However, only a small fraction, around 2 million tons, are considered durable carbon removal. As such, we will need to develop an industry that will grow 40%+ year on year for the next 26 years.

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This unprecedented growth can only be achieved through a joint effort by businesses and governments. In Europe, the Green Deal provides the framework for achieving net-zero by 2050. However, CDR is not yet integrated into key policy vehicles. To fill this gap, the EU is currently developing the so-called Carbon Removal Certification Framework (CRCF), the missing building block to leverage CDR in EU climate policy. This is arguably the most ambitious attempt by any public body to date to define what CDR is and how to certify it. The CRCF is likely going to become the gold standard globally and is thus of paramount importance.

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What is the Carbon Removal Certification Framework?

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The CRCF, first proposed by the European Commission in 2022, sets out to create a unified certification scheme for carbon dioxide removals. The CRCF categorizes carbon removal into three key areas:

1. Carbon Farming such as soil carbon and afforestation/reforestation
2. Permanent Carbon Storage/Removal such as Biochar Carbon Removal (BCR), Direct Air Capture and Storage (DACS), Enhanced Rock Weathering (ERW), and Bioenergy with Carbon Capture and Storage (BECCS)
3. Carbon Storage in Products such as wood-based construction materials and concrete

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All of these are subject to "QU.A.L.ITY" criteria—Quantification, Additionality, Long-term Storage, Sustainability—to ensure their effectiveness.

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The CRCF will eventually include a range of methodologies that will lay out how certification will occur for each carbon removal approach. It will include a range of methodologies that will lay out the fundamental principles and requirements for how certification will occur for each carbon removal approach. The CRCF will also define what certification bodies will look like and how a European single registry can be used to avoid double counting and keep track of CDR across the Union.

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What is the impact of the CRCF?

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The stated aim of the CRCF is to boost the development of removals across the EU and fight greenwashing. While the CRCF explicitly does not provide guidance on how these certified removals are to be used, it is expected to have a major impact in at least three ways:

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1. ‍EU Climate Policy: All policies relating to CDR from now on are expected to link to the CRCF for quality assurance of removals. Examples are the Green Claims Directive (GCD), the Industrial Carbon Management Strategy (ICMS), and the 2040 Climate Targets to name a few. Most importantly, it is also expected that the inclusion of CDR in the EU Emission Trading Scheme - by far the biggest compliance market in the world - will be tied to the CRCF.‍
2. National Climate Policy: The EU has 27 member states with a net-zero target by 2050 at the latest and - soon - even more ambitious decarboniation (and removals) targets for 2040. To achieve these, a range of domestic policy vehicles will be needed, from public procurement, to feed-in-tariffs, to contracts for difference. Governments won’t recreate the wheel and simply utilize the CRCF in national policy.‍
3. Voluntary Carbon Markets (VCM): Likely the most immediate impact will be felt in the VCM, a market expected to reach US$200 billion by 2050 globally and growing at a ate of 500%. Buyers will align their purchasing behavior with the CRCF for two reasons: anticipating compliance and following best practice.

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Summing up, the CRCF will have a huge impact on CDR in Europe and beyond. It is therefore of paramount importance that the CRCF end up being high-quality and inclusive.

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Can the CRCF live up to its potential?

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The ambition behind the CRCF is substantial. However, the journey from proposal to implementation has been far from smooth. The original proposal by the EU Commission in November 2022 was welcomed as a good foundation, but full of challenges. Arguably the biggest flaw was a lack of differentiation between the units that will be generated from carbon farming, permanent removals, and carbon products. This would have de facto equated a soil carbon with a direct air capture unit, leaving the door wide open for mitigation deterrence.

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Many issues have been addressed throughout the legislative process involving the European Council and European Parliament. However, these players brought their own challenges, particularly the Parliament’s focus on an extremely narrow definition of permanent removals, which would de facto limit it to DACS and BECCS with geological storage. While highly promising, these two approaches currently account for <0.1% of global durable CDR. Other CDR approaches such as BCR, ERW, and mineralization in durable products - between them almost 95% of durable CDR today - do not rely on vast CO₂ transport infrastructure and the availability of suitable natural CO₂ storage sites, and could help to bridge the gap until the necessary CO₂ infrastructure is developed.

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This approach of picking winners already led to significant mobilization by the CDR industry, resulting in an open letter signed by over 350 companies including Microsoft, Shopify, and the Negative Emissions Platform calling for tech-openness in the CRCF. It advocated for definitions of carbon removals and permanent storage that are inclusive and aligned with the best available science.

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What happened on February 20th?

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Early in the morning on February 20th, the final Trilogue came to a successful end. This is a crucial step in the European legislative process, as it marks the moment when the three EU institutions - Parliament, Council, and Commission - reach an agreement on the legal text of a file.

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While we are still awaiting the final details, here is a sneak preview of what we expect to be the decision. First, there are many great successes to celebrate:

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• ‍Different units: The CRCF now distinguishes between carbon farming vs permanent removals vs carbon product units. Treating units of varying durability differently is crucial to ensure these qualitatively very different solutions are used appropriately.
• ‍Definitions: The CRCF is now aligning its definition of carbon removal with the IPCC’s. It also features a permanent removal definition that is tech-open and does not pick any favorites.
• ‍Use cases: While not going so far as to define the exact use of CRCF units, the text now does call for clear linkages to other regulations, e.g. the Green Claims Directive (GCD) and the Corporate Sustainability Reporting Directive (CSRD).

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However, not all is rosy and some challenges remain:

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• ‍Emission reductions: A result of the strong agriculture lobby/interest in Europe (38% of the EU budget goes to ag), the CRCF - a framework for carbon removals - is still plastered with emission reduction clauses and carve-outs. While the use of different units (see above) avoids the worst, it is still a significant blowback. Emission reductions should not have found their way into this framework.
• ‍Monitoring and liability: Specific mentions of the 2009 CCS Directive were not taken out from the section regulating monitoring and liability of permanent removal (Article 6,2,a), which could cause issues for any approach not using geological storage, e.g. BCR or ERW. This is not a deal breaker, and very much open to legal interpretation, but it would have been cleaner to remove these mentions altogether.
• Certifying non-EU removals: Climate change is a global problem and will require global solutions. Conditions to carry our CDR tend to be much more favorable in the tropics than in more temperate countries. As such, it would be important to be able to certify, and then use, removals from outside the EU under the CRCF. Currently, the CRCF limits itself to considering geological storage in European non-EU countries.

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What is left to do?

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Following the progress made on the CRCF, the focus now shifts towards the detailed development and implementation of methodologies crucial for operationalizing the framework. This responsibility lies squarely with the EU Commission which has been tasked with delivering the first set of methodologies within 12 months of the regulation's implementation (expected in Q4 2024). This timeline suggests that by the end of 2025, these foundational methodologies should be established, guiding the certification of carbon removal activities across the EU.

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Key Steps in Methodology Development:

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• ‍Expert Group Meeting in April: A critical milestone in the development of these methodologies is the expert group meeting scheduled for April 15-17th. For those not attending in person, there will be a public livestream available.
• ‍Developing a broad range of methodologies: It is imperative that the EU COM commits to developing at least four, if not five, methodologies, rather than the initially proposed two. This expansion is crucial for accommodating the diverse spectrum of carbon removal technologies and practices that could contribute to the EU's climate targets. To achieve this, the Commission should develop methodologies that bring clarity on the key policy positions for each carbon removal pathway, but are not as prescriptive as a typical registry methodology is today.
• ‍Market reflection and inclusion of Biochar Carbon Removal (BCR): Any methodology developed must accurately reflect current market trends and the significant contributions of various carbon removal methods. Specifically, overlooking BCR would be imprudent, considering it accounted for 93% of total carbon removal deliveries in 2023, has a technology readiness level (TRL) of 8-9 for advanced facilities, and boasts as many as six voluntary carbon market standards. It is simply the most shovel-ready solution to achieve climate relevance in this decade.

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The Road Ahead

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The Trilogue's agreement on the CRCF marks a huge milestone for carbon removal policy in Europe and beyond. The CRCF in its current form represents - by far - the most well-developed and impactful legislation on defining what quality carbon removal looks like and how to certify it.

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However, it will still take some time before the CRCF will fully come into force. We expect formal adoption of the CRCF in the Plenary in April, just before the European elections, followed by implementation at the end of 2024. The Commission will continue work in parallel, hashing out the details through the development methodologies and delegated acts, the first of which should be expected in early 2025 and no later than end of 2025.

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We can also expect increasing discussion on the inclusion of the CRCF into other EU policy, as we are already seeing with the Green Claims Directive. Inclusion of permanent removals certified by the CRCF into the EU ETS will be of particular interest, with the Commission expected to deliver a proposal no later than 2026.

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As we approach these important dates, it is vital for everyone interested in European climate policy to stay involved and continue to make their voices heard. If I have learned one thing in the last 15 months, it is that coordinated industry advocacy works. Let’s all work together to ensure that CDR policy is progressive, inclusive, and actually helps the sector achieve the growth to gigatonne scale we need.

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