The 6^th Expert Group meeting was held online on the 26^th of March 2025 to discuss the updates of the methodologies for permanent removals – DACCS and BioCCS – as well as biochar and carbon storage in buildings. In its opening remarks, the Commission highlighted plans to develop CRCF methodologies for: 

• Carbon removals through CO₂ mineralisation into products (permanent CCU) 

• Enhanced rock weathering (ERW) 

• Marine carbon removals (mCDR) 

Comments from Bellona on the previous expert groups can be found here and the details of Bellona’s response to those methodologies are publicly available.  

Carbon storage in buildings  

An update and FAQs were shared by the Commission, although no new methodology was shared for this category of the CRCF, which has seemingly been deprioritised. The updated Technical Assessment Paper will be shared in Q2 2025, with the development of draft methodology for new and renovated buildings in Q3/4 2025, alongside some technical workshops. 

It is crucial that the upcoming CRCF for temporary carbon storage in buildings does not undermine the Whole Life Carbon framework under the revised Energy Performance of Buildings Directive (EPBD). There should be coherence and hierarchy between the two frameworks, where the CRCF acts as a supplementary information tool to assess the carbon storage of a building, without generating units for offsetting or counterbalancing of emissions. An enhanced coordination between DG CLIMA and DG ENER would facilitate the complimentary implementation of those policies and make sure to promote the use of bio-based products over others. Finally, risks of double accounting should be clearly addressed. 

DACCS/BioCCS 

Near final methodologies for DACCS and BioCCS were shared ahead of the Expert Group meeting. The Commission plans to have a final methodology by June 2025.  

Bellona welcomes some of the modifications of the latest methodology. Acknowledging the potential of co-firing applications with mixed flue streams, such as waste to energy operators is positive development. The confirmation of CO₂ origin via ¹⁴C testing is also a good addition to verify the captured carbon is atmospheric or biogenic; for installations with mixed flue gases, their fossil CO₂ emissions should be subtracted in the quantification of a net carbon removal benefit. Moreover, more transparency regarding the sustainability requirements of the biomass inputs under the Renewable Energy Directive (RED) III were explicitly included (e.g. transport emissions, type of feedstock), the details on the transport of the biomass and their databases, and the information to be included in the certificate of compliance.  

As previously stated, the DACCS methodology is comprehensive. Nevertheless, switching from monthly matching to annual matching until 2029 for the electricity generation following the Renewable Fuels of Non-Biological Origin (RFNBO’s) rules is deemed problematic as carbon intensity and price of renewable electricity is highly variable over a year and this change could be sensitive for hydrogen producers who are met with hourly matching requirements. Furthermore, some stakeholders have called for the further relaxation of this rule with the addition of a grandfathering clause, which Bellona is strongly against on the basis that this could allow DACCS projects to divert much of the renewable energy in areas with carbon intensive grids not suitable for DAC, while counting their energy-related emissions as zero until the end of a project’s lifetime. 

However, there are still some concerns about the overall carbon negativity of BioCCS projects as currently the methodology still does not reward projects according to their overall carbon negativity potential and climate benefits but recognises a business model. The emissions from the bioconversion stage of the activity are not described and are not subtracted from the carbon balance of the activity. The complexity of biomass carbon balance and the zero rating of renewable energy in the energy sector are not addressed. The carbon accounting should take into account the atmospheric uptake from biomass production (carbon payback period, if and when the biomass is regrown). Feedstocks and stringency of sustainability of EU biomass should be a core part of the methodology and is still missing. 

Bellona’s full comments on the draft DACCS and BioCCS methodology can be found here and below.

• Draft Technical Specifications for the Certification of Permanent Carbon Removals Through DACCS and BioCCS (pdf)

Biochar 

Significant steps forward have also been made in the methodology for biochar, such as further alignment between the methodologies using biomass as an input. Bellona welcomes the fact that further guidance on biochar quality for different applications and relevant EU regulations is added to the methodology.  

Regarding the scope, it is unclear why the definition of ‘system boundary’ was removed and yet is referred to throughout the methodology. System boundaries are a critical part of determining the system for a LCA assessment and therefore a consistent definition should be provided. This is particularly relevant for feedstocks production feeding into a biochar process (e.g. upstream and downstream associated GHG emissions). Related to this, Bellona recommends that biomass feedstock sourcing, biochar production and biochar storage locations must all be within the EU, to reduce the risk of carbon leakage and incentivising unsustainable biomass production practices and forest degradation outside EU borders. Additionally, it must be clearly reflected in the methodology and the life-cycle approach to carbon accounting, that the physical removal of CO₂ from the atmosphere occurs during biomass growth and does not occur during the conversion of biomass feedstock via pyrolysis to biochar. 

Moreover, monitoring and liability were once again discussed at the expert group: on permanence (beyond the inertinite fraction) and the environmental impact of biochar application in agricultural soils. The lack of accurate verification of biochar application to soils, and the impacts on the application site post-deployment jeopardises transparency and credibility of the certification scheme. Multiple scientific papers call for longer-term field experiments to understand the local impacts of biochar application. While the presence of contaminants in biochar, namely in trace elements, have been restricted in the methodology, soil health and variable local conditions has been overlooked. Furthermore, if an area is used for biochar application as a permanent removal, this same area should be excluded from carbon farming certification for soil organic carbon to avoid double counting of removals. 

Bellona reiterates that the methodology for biochar, or indeed any open system CDR, should follow the same stringency and robust monitoring as well as associated liability mechanisms to address any potential storage reversals required from the CO₂ Storage Directive. According to the CRCF Regulation text, liability mechanisms should be consistent with the obligations in the CO₂ Storage Directive. In the case of carbon removals via biochar, storage liability ends upon application, yet the storage should continue for several centuries with potential storage reversal remaining unmonitored and with no recourse of damages. It is critical that more time is dedicated to discussing liability requirements for carbon removal via biochar, or any open system CDR that may generate permanent removal certificates in future under this CRCF certification framework.  

Bellona’s full comments on the draft biochar specifications can be found here and below.

• Draft Technical Specifications for the Certification of Permanent Carbon Removals Through Biochar (pdf)

In conclusion, Bellona recognises the efforts put into the changes of the technical documents to be presented as delegated acts to the expert group in June 2025 with its adoption and scrutiny period in Q4 2025. The major caveat remains the fact that the methodologies do not characterise how the biomass is sourced and how it is converted which is very likely to overestimate the climate benefits of units generated under this framework.