On July 10^th, 2025, the European Commission presented the draft delegated act on permanent carbon removals under the Carbon Removals and Carbon Farming Certification Regulation (CRCF), at the Carbon Removal Expert Group Meeting (CREG). While, formally, the meeting is intended as an opportunity for the Commission to receive input on the draft methodologies, some of the concerns raised around biomass sourcing and biochar have still not been addressed. Time was allocated for discussion on the methodologies but any significant changes in the draft are unlikely to be made before the public consultation period begins. 

Bellona welcomes the EU’s ambition to produce a reliable monitoring framework which can enable the scale up carbon removals and create demand for Carbon Dioxide Removal (CDR). However, the current draft for permanent removals falls short in terms of consistency with the Regulation’s legal text and scientific integrity.  

The presented methodologies did not differ significantly from their last iteration, especially in the case of biochar. Therefore, Bellona’s previous feedback raised during CREG meetings remains relevant. 

The CRCF Regulation requires that methodologies go beyond the biomass sustainability criteria of the Renewable Energy Directive (RED III), yet this proposal fails to do so. Moreover, the Regulation states that it should be consistent with the CO₂ Storage Directive. This is however not the case for biochar, which is left without any strong monitoring or liability provisions, disregarding the precautionary principle and the current scientific consensus on the permanence of biochar. 

To manage these uncertainties, the Commission’s methodologies should respect the precautionary principle, relying on the conservative estimates rather relying only on novel, promising, yet unvalidated, scientific research. As highlighted recently by Carbon Direct, we otherwise run the risk of certification protocols outpacing the science in terms of the assessment of permanence. Nevertheless, the absence of any monitoring and liability requirements after the application of biochar remain a fundamental issue. 

Bellona has joined Carbon Market Watch, Clean Air Task Force, ECOS, Fern and the European Environmental Bureau in calling on the Commission to significantly revise the methodologies and ensure that the delegated act is strengthened to guarantee CDR delivers real and lasting climate benefits.  Read the joint statement below.  

Bellona and other NGOs involved in the Expert Group remain committed to constructively engaging and improving the methodologies, based on the best available science.  

The draft delegated act and combined methodologies will be subject to a public consultation from the end of July until September, followed by a formal “scrutiny period” by the Council and the European Parliament. Bellona, together with other NGOs, urge Member States and Members of the European Parliament to call for significant improvements or a pause on the methodologies in the absence of these changes.