Carbon dioxide removal is any human activity that removes CO2 from the atmosphere and stores it in a manner intended to be permanent [1]. CDR is expected to play a vital role in the European Union’s plan to reach net-zero by 2050. The latest report by the IPCC confirms this, saying that “CDR is an essential element in global scenarios that limit global warming to 1.5 degrees Celsius” [2].  

Although removals are an integral part of climate mitigation, its complex nature provides pitfalls that can be managed through robust policy frameworks. We therefore see the European Commission’s upcoming proposal on Carbon Removal Certification Mechanism (CRCM) in a positive light.  

As a first step, it is important to ensure the definition of CDR serves as the foundation for the CRCM. Beyond this, three key basics should guide any subsequent work in order to ensure truly positive climate impacts.  

Removals are additional to reductions 

Emission reduction measures reduce the amount of CO2 accumulating into the atmosphere, whereas removals actively take CO2 out of the atmosphere with the intention of reducing the atmospheric concentration. Since removals will be limited, absence of sufficient emission reductions would result in continued accumulation of CO2 in the atmosphere. Thus, CDR measures need to be additional to emissions reduction measures, which are the major drivers of climate mitigation. As highlighted by the IPCC, CDR would only counterbalance ‘hard-to-abate’ residual emissions, which are often defined ambiguously. Focusing on reduction measures should leave as little residual emissions as possible to be tackled by removals.  

The EU ETS works to decrease the CO2 emitted into the atmosphere by incentivising reduction measures and the inclusion of removals would deter this goal. Keeping reductions and removals separate is important in ensuring that emitters do not continue to dump CO2 into the atmosphere. In the short- to medium-term, removals require their own space, separate legislation, accounting and framework with a possible view to broader integration in the long-term. 

Monitor carbon flows accurately and ensure permanence  

Accounting for how much CO2 is removed from the atmosphere is important in evaluating true climate benefits. To do so requires a full life cycle analysis to quantify the various parameters that influence a removal. For example, by considering the emissions due to transportation and growing of biomass, a holistic account is formed for emissions along the value chain. More important is the question of permanence, or what is the likelihood that the CO2 storage will not be reversed. Ensuring the permanence of removals is a crucial foundation for CDR and is necessary to accurately assess the climate benefits of the various methods. Certain forms of removals (land sinks) remove carbon for a much shorter timescale, compared to geological storage. This is important as any monetary benefits that would stem from removals would need to be validated through a robust monitoring, reporting and verification (MRV) framework. These calculations can be difficult, as considerations of such varying timescales and risks of reversals are difficult to quantify, but are necessary to ensure a real, verifiable permanent CDR. A thorough MRV framework would provide clarity of: 

• Net amount stored: How much CO2 is truly removed and accounted for from the atmosphere and how much GHG was emitted in the process of doing so. 
• Permanence and risks of reversals: How likely is it that the CO2 will be stored permanently and what are the timelines for possible reversals?  

Separate the sinks 

The ambiguity in storage timelines, risks, and accounting form complications in CDR. To mitigate such complications, short carbon cycle (land based) and long carbon cycle (geological) removals need to be kept and managed separately. By creating a framework where these different removals are not fungible, recognises the different properties that they have, allowing for unique approaches to thrive without incoherent claims. Land based removals such as reforestation are more reversible and only store CO2 for several decades to centuries. Equating this to geological storage which has a timescale of thousands of years would result in inaccurate accounting of removals. Separate, non-fungible sinks are important in realising the true potential of the proposed CDR framework.    

Approaching each type of removal uniquely provides space to also tackle its limitations. Removals are, first and foremost, a climate mitigation measure (if done correctly), and evaluating unique removals in line with this consideration is paramount. Carbon farming is viewed as an advantageous CDR approach as its co-benefits are favourable (increased biodiversity), but evaluating the climate mitigation potential of carbon farming, it becomes clear that removals are the co-benefit. For such approaches where CDR is the co-benefit, it is still important to quantify the amount of CO2 removed, but the removal must not commoditised. This would promote only real, verifiable and permanent CDR, and the Carbon Removal Certification Scheme (CRCM) is the first step in ensuring that.  

Getting the CRCM right is a necessary step so that in the short-term, CDR can incentivise climate mitigation on top of reduction measures, in the mid-term, counterbalance a minimal amount of residual emissions only with high quality removals (for example, geological storage) and in the long-term, tackle historical emissions, making the EU net negative.  

Bellona’s full response to the public consultation is available here: Bellona consultation response CRCM 2.5.22

1 Tanzer, S. and Ramírez, A., 2019. When are negative emissions negative emissions? Energy & Environmental Science, 12(4), pp.1210-1218. 

2 https://report.ipcc.ch/ar6wg3/pdf/IPCC_AR6_WGIII_FinalDraft_TechnicalSummary.pdf