Carbon Removal Certification Framework: a missed opportunity to set the right course

Apr 10 2024

The EU came to a preliminary agreement on the Certification Framework for Carbon Removals however Bellona has called for more clarity on how they will and won't be used.

The agreement is a substantial improvement to the Commission’s original proposal, Bellona said, but fails to incorporate key guardrails on how future certificates issued by the framework will be used, or more importantly, how they will not be used. This leaves many unanswered questions which will need clarification in the coming months and years. 

The framework establishes four different types of activities to be covered by the framework, from emission reductions in soils, to temporary carbon storage in carbon farming and in products, and permanent carbon removals. Vitally, these units will be distinct from each other, however, it remains unclear how the units will be used differently. This is a first missed opportunity to further disentangle the complexity which will necessarily emerge from trying to regulate very different activities under the same framework.  

It is significant that some of the activities covered by the framework are explicitly labelled as being temporary in nature, with a duration of only five years for carbon farming activities, although this raises further questions as to how these units may be credibly used in practice. It is also worth noting that marine environments are explicitly included in the scope of the framework, in spite of the immense complexity of quantifying the climate benefit of marine-based activities.

"It remains to be seen how different activities with such different characteristics and storage uncertainty can be managed under the same framework. We can’t compare soils to rocks," said Dr. Allanah Paul, CDR Research & Technology Advisor.

Bellona has long called for a robust definition of Carbon Dioxide Removal to be included in EU legislation. The Certification Framework establishes a first definition for carbon removal in EU policy and effectively ensures that only the permanent storage of atmospheric or biogenic CO2 can qualify as a permanent carbon removal activity. On the other hand, it is unclear if all emissions associated with the activities will be included in the quantification of units, potentially overestimating the net climate benefit of each unit generated by the framework. 

Fundamentally, the Certification Framework is geared towards the generation of individual quantified units, with the expectation that they may be used for offsetting. Yet, an offsetting-based model is unlikely to generate a physically and socially credible outcome, even with the guardrails introduced in the agreement. The explicit references to the Green Claims Directive and Corporate Social Responsibility Directives are welcome additions to the text, as is the requirement that units generated must be used for the EU’s NDC, rather than 3rd parties or international schemes such as CORSIA. Nonetheless, the framework should have been explicitly directed towards financing models other than conventional offsetting, but falls short of doing so.

The Certification Framework expects to rely on the Commission’s Expert Group on Carbon Removals, of which Bellona is a member, to provide input to the methodologies which will be developed. While the agreement establishes initial guidelines on the content of these methodologies, it does little more than this. Meanwhile, it is questionable if the Expert Group will be able to provide the necessary scrutiny to these methodologies, given the dearth of independent and academic representation in the group.

"The anti-greenwashing tool promised by the Certification Framework has yet to materialise, more work will be needed in the coming months and years," said Mark Preston Aragonès, Senior Policy Manager, Carbon Accounting.


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