With the recent approval of the preliminary agreement of the Carbon Removal Certification Framework (CRCF) in April 2024 by the European Parliament, discussions in the 4^th meeting of the Carbon Removals Expert Group, on April 15-17, shifted gears. For the first time, the expert group had a framework to work with and the basic methodologies for various removal activities (carbon farming, permanent carbon removals, carbon storage in products) were on the agenda.  

The three-day meeting covered the certification framework and registries on Day 1, carbon farming activities on Day 2, with permanent carbon removals and carbon storage discussed on Day 3. This article serves to summarise the 4^th meeting of Carbon Removals Expert Group and is interspersed with Bellona’s analysis. 

Day 1 – Certification Framework and Registries 

After multiple calls to clarify potential use cases (see comments from Bellona for example, here and here), the Commission provided a first indication as to how the certified units and compliance certificates generated could be used in practice, alluding to potential corporate claims under the Corporate Sustainability Reporting Directive or under Green Claims Directive, Energy Performance of Buildings Directive for carbon storage in products, or in post-2030 climate policy. However, this did little to allay fears of greenwashing – further details remained scant and the risk of offsetting fossil emissions with temporary carbon farming units appears to remain. Bellona and other stakeholders continue to call for separate targets for permanent carbon removals and land-based sequestration, to safeguard geological net-zero that aligns the carbon storage time scale with the time the emission remains in the atmosphere and contributes to warming.  

The Commission is also tasked with exploring the feasibility of accounting for and covering carbon removals under emissions trading without undermining necessary emissions reductions, with a report due by July 2026. The CRCF is expected to play a role as an MRV tool which may underpin such an approach, however significant questions remain as to how these schemes may interact in a manner which does not result in the offsetting of emissions which could otherwise have been prevented or abated. 

Day 2 – Carbon Farming 

Critical questions surrounding the quantification and baselines emerged from discussions about the technical assessment reports of carbon farming activities (agriculture, forestry, and peatlands) on Day 2: How will activities satisfy regulatory or financial additionality requirements under the CRCF when practices or legislative obligations for nature restoration already exist? Is it possible to accurately quantify and monitor the carbon sequestered in open fields and ecosystems, without an unreasonable burden on individual actors?  

It is questionable for activities that cannot be easily or accurately quantified can generate robust units and whether the CRCF regulation should be used to incentivise unquantifiable activities, or if this is opens the door to greenwashing. As an alternative to a carbon-centric business model, the climate benefit generated from carbon stored in carbon farming activities could be seen as a co-benefit, for example, of the wider and sustained transformation of the agricultural sector to whole farm productivity and resilience, on time scales longer than political cycles (see Project Credible).  

Day 3 – Permanent carbon removals and carbon storage in products 

The final day of the Expert Group covered permanent carbon removals and carbon storage in products, with the entire morning allocated to exploring some of the methodological questions for Bio-CCS and DACCS. This agenda item was significantly more advanced than others, given much of the methodological work is intended to be drawn from existing work stemming from the Innovation Fund and other EU policy such as the Renewable Energy Directive (RED).  

In this vein, the use of the sustainability criteria from the RED to handle the biomass component of Bio-CCS projects was questioned and subject to debate, due to concerns that the current approach of zero-rating biomass which meets certain criteria may significantly underestimate negative climate and biodiversity effects. Also for Bio-CCS projects, Bellona emphasised that capital emissions from the construction of CO₂ capture, transport and storage infrastructure should also be included since these could be substantial emitting processes (see our assessment here). 

For DACCS, the use of the rules designed for the production of electrolytic hydrogen (RFNBOs) designed under the RED were suggested. Bellona strongly urges the Commission to apply temporal and geographical correlation on an hourly basis, as per the full implementation of the rules for RFNBOs, and to ensure that additional renewable energy is deployed to power the Direct Air Capture of CO₂, as stipulated in the “Additionality” Delegated Act under RED II.  

The afternoon session firstly covered biochar, although much of the discussion pertained to the permanence of carbon storage. While recent scientific research suggests a storage permanence significantly above prior expectations, the absence of field studies was flagged by several participants, including Bellona, as being problematic. Carbon storage in products was also discussed where the complexity in tracking and accounting for the carbon in different building components, across different lifetimes and potential owners was evident, as was the difficulty of meeting the financial additionality requirement, since the practice of using wooden materials in construction is a long-established business model.  

General remarks 

It remains challenging to see how the CRCF, and the certified units it will eventually generate, will be used in the plethora of ways it could have been used. Given the design of the Quality criteria and the requirement for financial additionality, it appears the methodologies can only be used in the context of the voluntary carbon market, which is not an appropriate long-term tool for climate mitigation, especially if non-permanent activities are used to counterbalance CO₂ emissions. It will be important to explore how the methodologies developed with the support of the Expert Group can be used to provide finance towards the activities covered by the CRCF in means other than the offsetting of emissions. 

As the Expert Group delves deeper into technical details, there is a need for a more official and clarified role for input from academic experts, such as from the growing number of EU-funded research consortia on CDR, to ensure the process is driven primarily by scientific knowledge and not only economic interests. Currently, there is no direct pathway to channel this expertise into this expert group on removals and there is a lack of transparency from the Commission on the experts participating in the process, who they are and how they are selected, as well as how the focus sub-groups were selected.  

More information on the Expert Group on Carbon Removals is available here: https://climate.ec.europa.eu/eu-action/sustainable-carbon-cycles/expert-group-carbon-removals_en