On the 10th of November 2025, the European Commission’s Carbon Removal Expert Group (CREG) met to review the latest draft methodologies under the Carbon Removal Certification Framework (CRCF), focusing on permanent carbon removals and the upcoming certification scheme. While the overall group endorsed the draft, discussions revealed persistent concerns over biomass sustainability, governance, and liability mechanisms, as well as calls for stronger knowledge sharing and long-term review of the methodologies. 

The Commission will move ahead with the Delegated Act on permanent carbon removals, in spite of concerns highlighted by stakeholders. 

The Commission is to present a final draft for permanent removals in December, ahead of formal adoption in early 2026.  

According to the Commission’s Christian Holzleitner, the updated draft methodologies for direct air carbon capture and storage (DACCS), biomass conversion with carbon capture and storage (BioCCS) and biochar are now considered “very mature.” The version presented to the group builds on the July public consultation and incorporates several changes responding to feedback related to biomass sustainability and reporting, temporal matching to electricity and biochar permanence once applied to soils.  

In response to repeated calls from Bellona and others, the Commission confirmed that all CRCF methodologies will undergo review at least every 4 years, informed by data-sharing, workshops and continuous learning; a  conservatism factor regarding the measuring of permanent removals in biochar samples; clarified rules for feedstock sustainability under the Renewable Energy Directive (RED III) and changes in activity periods for certification. 

This knowledge-sharing clause is designed to maintain methodological robustness as science evolves – a feature welcomed by Bellona as essential for adaptive governance and long-term integrity.  

CCS-based removals 

For BioCCS and DACCS, the Commission aims to offer predictability and security for investors, with a 15-year activity period (previously 10 years) for CCS-based projects to enable access to finance and reinforcing the framework’s alignment with the EU’s 90% net-reduction target by 2040; without the CRCF becoming the reason  become to create retrofit or create a new bioenergy plant. 

Bellona welcomes the fact that suggested changes in the DACCS methodology were taken on board partially related to temporal matching for this technology: the need to transparently account for electricity consumption and interactions with the power grid when measuring lifecycle emissions for these projects. While Bellona would have preferred a more stringent monthly temporal correlation, the delegated act aims to accommodate early movers and increase investor certainty while balancing the fact DACCS credits should reflect energy-related emissions in the net removals calculation.  

Biochar 

The biochar methodology has clarified the methods for to certifying only the portion of biochar stable enough to be considered permanent under the CRCF rules, with conservative and clearer guidelines on analytical methods. Moreover, the Commission opted for a reduction of the biochar activity period, from 10 to 5 years, to better accommodate future improvements and evidence on biochar permanence. Specific contaminant thresholds (e.g. cadmium) are also adjusted upwards in the draft rules, with the Commission inviting formal feedback. The Commission reiterated it will adjust methodologies if robust evidence emerges and encouraged data-sharing to support future methodological refinements during the review. 

Together with Carbon Gap, ZEP, and Pyrolysis Denmark, Bellona reiterated the compromise for biochar presented during the public consultation period. In a joint statement, the organisations welcomed key improvements: shortening of the biochar activity period to 5 years and new provisions allowing certification schemes to request and share data to improve transparency and methodologies. As mentioned above, the introduction of a 2.5% conservativeness factor for measuring permanence using the “inertinite method”, and the removal of previous wording on “negligible reversal risk”. This is a significant aspect present in both the EU CCS Directive, and the Monitoring and Reporting Regulation linked to the EU ETS.  

A mixed reception of the Delegated Act amongst the Expert Group 

While the Commission’s presentation showed significant progress in the CRCF’s implementation, stakeholders including Bellona expressed divergent positions and worry that the methodologies were designed towards facilitating project development over robust carbon accounting and quantification of climate impacts. Issuing low-quality credits poses serious credibility risks for units generated by the CRCF and leaves uncertainties on associated claims. It also raises questions as to whether the methodologies are ‘probably the best in the world’, as claimed by the European Commission. 

Bellona still deems the methodologies to be imperfect, and they would require further improvements. Dr Louis Hennequin, our CDR Research and Technology advisor, also underlined missing elements essential for environmental integrity: 

• The absence of any liability mechanisms or credit buffers for reversal risks is a missed opportunity for Monitoring, Reporting and Verification (MRV) synergies between the carbon farming methodologies and the application of biochar into such agricultural soils. 

• The lack of full life cycle emissions embedded in the methodology for handling biomass for bioenergy (also relevant for the BioCCS methodology) including indirect land use change (ILUC) and carbon payback periods remain problematic for achieving climate benefits – and whether net negativity is actually realised – should be resolved in other EU legislations. 

Environmental NGOs, namely Carbon Market Watch and Fern, encouraged the European Parliament and the Council of the EU to reject the draft delegated act, citing unresolved issues with biomass carbon payback times, zero baselines, and missing safeguards against unsustainable feedstock demand. They warned that certifying removals without strict sustainability criteria could put EU land carbon sinks at risk, and compromise ETS integrity if permanent carbon removals are integrated into compliance markets such as the EU ETS. 

“Having low-quality removal methodologies used to offset fossil emissions will inevitably compromise the ETS’ integrity and delay decarbonisation,” the NGOs said in a joint statement. 

Bellona will not call for the Delegated Act to be rejected, but echoes the concerns highlighted by NGO partners. 

Certification Scheme 

The Commission confirmed that the CRCF certification scheme will be launched in 2026, drawing structural parallels with RED III. Experts, including Fern, warned against replicating the flawed RED’s fragmented national certification model and its loopholes. 

The Commission outlined two accreditation options – through national competent authorities or EU-level recognition – but most Member States are expected to prefer the former, seen as the “more harmonised” route. 

Next Steps in the Implementation of CRCF 

The carbon farming methodologies remain on track for a draft delegated act before the end of the year, followed by a public consultation in January/February 2026 and finally an adoption expected by April 2026. Further methodologies, such as for livestock management and improved forest management, are in progress for 2026. 

Updates were presented from the consultants on the technical assessment of certification methodologies for carbon storage and products pathways, noting growing interest in certifying long-lived carbon in products and stock changes in biomass-derived goods. The Commission flagged workstreams to define categories for carbon storage in products and clarified that methodologies will need to capture lifecycle impacts, permanence considerations, and product-specific durability metrics. Stakeholders were encouraged to submit evidence and data on product longevity and substitution effects to inform method development. The new methodologies will be shared in the coming weeks with the Expert Group. 

The Commission closed the session by announcing a programme of dedicated workshops and events in Spring 2026 on Mineralisation and Direct Ocean Capture and upscaling investment for permanent CDR: “the Carbon Market Place: united investors and innovators for carbon removal solutions”. 

As the CRCF nears implementation, Bellona reiterates its call for a precautionary and climate benefits approach to net negativity, ensuring that certified carbon removal credits represent genuine, additional, and durable positive climate impact.