In April 2024, the European Parliament approved the preliminary agreement of the Carbon Removal Certification Framework (CRCF). Building on this, the 5^th meeting of the Carbon Removals Expert Group took place between the 21^st and 23^rd of October 2024. Ahead of the expert group meeting, detailed documentation and proposed methodologies were shared, divided into three different streams:  

• Permanent carbon removals, namely Direct Air Carbon Capture and Storage (DACCS), Biogenic Carbon Capture and Storage (BioCCS) and biochar, covered in Day 1. 

• Carbon farming with Agriculture, Peatland and Forestry, covered on Day 2. 

• Long-lasting biogenic carbon storage in buildings and rules on third-party verification and certification schemes, covered on Day 3. 

Bellona participated in the Expert Group meeting and subsequently submitted three consultation responses on the proposed methodologies.  

Permanent Carbon Removals  

The first morning of the Expert Group covered the proposed methodologies for Bio-CCS and DACCS and represents one of the last opportunities to give feedback before it is drafted as a delegated act by the Commission before H1 2025. This agenda item was significantly more open for discussions than other days, as a way for the Commission to read the room and welcome feedback.  

Similarly to the previous Expert Group meeting, critical concerns about the land carbon sink and the harvesting of biomass remain. The methodology heavily relies on the Renewable Energy Directive (RED III) criteria to determine whether the biomass used for BioCCS is sustainably sourced, as well as zero-rating the emissions from biomass. These criteria are considered insufficient to avoid potential use of unsustainable biomass with overall high associated carbon emissions and could result in positive emissions over the complete value chain. Bellona sees this methodology as an opportunity to go beyond the RED III requirements and to further elaborate on the accounting of biomass conversion, with transparent system boundaries and inclusion of more comprehensive sustainability requirements regarding biomass and land use.  

While the methodology appears robust in the direct air capture and the CCS components, further clarification is necessary in the quantification of DACCS, to ensure that only the atmospheric fraction of CO₂ captured by DAC can be considered towards the carbon removal benefit. 

The afternoon session was allocated to biochar. There is still no consensus in the scientific community to suggest that biochar is a permanent carbon removal process, nor on its impact on soil carbon stocks sequestration and albedo effects if applied to soils. The level of confidence in biochar permanence is supported only by a selected range of scientific literature. As permanence and liability are inherently linked, inconsistencies between removal types within the permanent removals are problematic, jeopardising the credibility of theoretical generated units for the VCM. The methodology for biochar should follow the same stringency and robust monitoring required from the CO₂ Storage Directive as an open system. The monitoring is not only relevant to ensure the permanent storage of the removed carbon, but also to monitor and measure co-benefits and environmental impacts of biochar application to the soil.  

Carbon Farming 

The second day of the Expert Group meeting recorded the highest attendance from experts between the three days, especially for the forestry session in the afternoon. However, there was very little time for participants to ask questions to the experts and the panels compared to the previous day for permanent removals. This set of methodologies is seen as less advanced than permanent removals technologies and yet is expected to follow a similar CRCF timeline. The elements of the carbon farming methodologies drafted cover 3 activities: soil carbon in mineral soils and agro-forestry, planting of trees on unused and severely degraded land, and peatland restoration through rewetting. 

For all methodologies, Bellona suggests that “temporary carbon sequestration” or “temporary carbon storage” may be more appropriate as removals within the carbon farming scope of activities only provide temporary storage of carbon and therefore do not fit into the definition of carbon removal. Similarly to the conversations on BioCCS, sustainability criteria for the activities remained at the heart of the discussions. While some aspects are unclear regarding the use of fertilisers and water resources; other sustainability aspects are inconsistent. Biodiversity co-benefits should be mandatory in soils and forests, however these must be distinct from the activity. In soil carbon in mineral soils, the enhancement of organic carbon stocks in the soil was both the activity and one of the mandatory co-benefits. Bellona recommends that clear minimum standards and indicators are defined for biodiversity enhancements in carbon farming projects, that could be linked more explicitly to the Nature Restoration Law.  

The next methodology iteration must address the quantification of baselines in more depth to ensure these reflect the real conditions and the real removals. Bellona would welcome, for example inclusion of criteria on soil sampling across seasonal variability, integration of initial carbon stocks in the defined baseline conditions and carbon break even times for above ground biomass. A combination of model-based approaches, remote sensing and ground in situ measurements are needed to accurately assess and monitor these activities, but criteria for selected combination should be clearly specified in the methodologies . 

Activity and monitoring periods should be aligned between agroforestry and forestry methodologies as they are many similarities in how the carbon is sequestered and how it can be quantified, and the relevant carbon pools.   

Bellona agrees that restoration of peatlands through rewetting is an emission reduction activity as it prevents CO₂ from being emitted and there remains many unknowns about the effectiveness of the restoration of a given peatland in reducing emissions. The restored ecosystems can take years to decades to stabilise under the new conditions, emissions can fluctuate and can even be sources of greenhouse gases initially, and each peatland ecosystem will likely have a unique response.  Hence in these activities it is crucial to ensure local communities, stakeholders and local experts are informed and can bring in their local expertise into the implementation of peatland restoration projects, especially where land use is affected. 

Carbon storage in buildings & verification rules 

Finally, the third day consisted of panel discussions on the methodology for long-lasting biogenic carbon storage in new buildings. While consultants who prepared the methodology were eager to get feedback on quantification and sustainability; additionality, monitoring, and liability were not on the agenda.  

Bellona calls for a conservative approach for the quantification of associated GHG emissions to ensure it accounts for actual flows of carbon, incentivises renovation with biobased products instead of new builds and stimulates the use of existing materials. There is a need to strike a balance between scientific accuracy and practicality for users, but it should not be at the expense of climate benefits. As the value of carbon storage and opportunities for innovative bio-based products are understood, this framework is not about carbon removal. Unless a cradle-to-cradle life-cycle analysis of the whole building shows a carbon negative balance and there are assurances that the bio-based materials will not emit CO₂ back into the atmosphere, such products should not be able to generate certificates that might be used for offsetting emissions. In practice, it is not likely that bio-based materials in buildings can provide sufficient assurances that carbon will not be re-emitted in future and therefore the generation of certificates for offsetting should be explicitly excluded. 

Potential uses of the certificates suggested by the Commission include use in public procurement guidelines, to attract investments, and increase of building value. Net-zero and climate neutrality claims are also considered, which Bellona believes to be deeply problematic, given the issues with demonstrating a clear net negative balance across the building itself.  

Key challenges remaining and next steps  

It remains challenging to see how these methodologies are meant to be completed and approved by the experts for the timely delivery for draft delegated acts of the CRCF next year. The different methodologies exhibit vastly different levels of maturity and scientific understanding, with many gaps left to be filled in a short amount of time. Based on their current scopes and content, it is unclear 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.  

Bellona strongly encourages the EU Commission to reevaluate zero baselines in many activity types, and zero rating of biomass, perpetuating the widespread perception that bioenergy is always carbon neutral, while in reality net associated emissions from biomass use can be substantial depending on their carbon cycle. 

Furthermore, the current state of these methodologies is a missed opportunity to implement a modular approach for the set of methodologies across the certification framework, which was initially understood to be a key feature of the CRCF methodologies. This methodology could clearly define its constituent modules for capture via biomass-based removals or Direct Air 2 Capture with a common CCS-based storage module that could be reused across different technological pathways.  

Comments from Bellona on the previous expert groups can be found here and here.

Bellona’s Consultation Responses

• Draft Technical Specifications for the Certification of Permanent Carbon Removals Through DACCS (pdf)
• Draft Technical Specifications for the Certification of Permanent Carbon Removals Through Biochar (pdf)
• Technical Assessment of Certification Methodologies for long-term temporary biogenic carbon storage in buildings (pdf)
• Draft elements for an EU certification methodology on carbon removals and emission reductions through carbon farming under the CRCF (pdf)