Opening remarks and future of EU CRCF Market 

Christian Holzleitner, Head of Unit for Land Economy and Carbon Removals of DG CLIMA at the European Commission, opened the Expert Group meeting on Carbon farming on the 5th of February, 2026 where the experts are to discuss the first draft of the Delegated Act for Carbon farming activities under the Carbon Removals and Carbon Farming (CRCF) Regulation. The delegated act covers Agriculture and Agroforestry on mineral soils, rewetting and restoration of Peatlands, and Afforestation. 

Alongside the upcoming CRCF review and the announcement of a “carbon farming database”, the EU is taking measures to boost the adoption of CRCF units for the voluntary carbon market with: 

• the EU Buyers’ Club, to facilitate aggregation of private demand from within and outside value chains, 

• an EU purchasing facility for both public and private financing of EU procurement of CRCF credits and public support through pre-financing or price guarantees of CRCF credit purchases, 

• the creation of a knowledge sharing platform, “carbon farming database”, to reduce the costs of Monitoring, Reporting, and Verification (MRV) for project developers. 

How will CRCF units be used? 

The Commission has finally outlined its thinking on possible use-cases for CRCF units, which had not yet been communicated until now, in spite of early calls from NGOs to clarify the use-cases. Holzleitner explained how this voluntary carbon market could become a key enabling measure for EU Member States to achieve their national targets and flexibilities with EU-certified credits. The Commission anticipates that CRCF could support the Bioeconomy Strategy and ambitious EU climate targets, providing improved monitoring and databases for national inventories.  This suggests that CRCF units could be linked to the achievement of post-2030 national targets, potentially even used for compliance.  

Bellona acknowledges that carbon removals are needed to achieve climate neutrality and net negative emissions, and that EU certification is a first, necessary step towards scaling them up. However, removals should not be used as a flexibility or a ‘get-out-of-jail-free’ card from the responsibility of cutting emissions. Treating removals as a flexibility risk weakening the signal to cut emissions and gives the false impression that emissions reductions and removals are interchangeable. These concerns are reinforced by the fact that several CRCF drafted methodologies do not yet meet high-quality criteria in their current form: inconsistency with the EU CO2 Storage Directive, issues surrounding biomass sustainability and climate impacts and liability mechanisms. 

The delegated act for permanent removals (BioCCS, DACCS, biochar) has been formally approved by the Commission on the 3rd of February and will be up for political scrutiny for 2 months from Parliament and Council to adopt or reject. With the revision of the ETS planned for July 2026, the Commission is looking at various options for a role for permanent removals under the EU ETS. While it remains unclear whether CRCF-certified units will interact with the EU ETS, it remains a possibility. This would raise risks and would shift the aim of the CRCF from supporting the voluntary carbon market to underpinning the functioning of the EU’s compliance carbon market. As previously mentioned by Bellona, unless the sustainability and full life-cycle emissions of feedstocks used for permanent removals are resolved, the CRCF could put even more pressure on the land sinks and hinder the net negativity of issued CRCF credits. 

Carbon farming methodologies 

Carbon farming activities are divided into 3 types of activities: Agriculture and Agroforestry on mineral soils, Rewetting and Restoration of Peatlands and Afforestation. 

The morning session covered eligibility, activity and monitoring, planning and reporting and finally quantification of removals for carbon farming activities. Changes from the last iteration of the methodologies were discussed and put forward as the delegated act. In the afternoon, sustainability and liability aspects of the methodologies were discussed. 

A joint statement together with Carbon Market Watch, European Environmental Bureau (EEB) and Environmental Coalition of Standards (ECOS) was delivered by the different organisations during the Expert Group.  

What is included and what is not 

The scope has changed on eligibility: activities on marginal or degraded land are no longer specified, but crop rotation and combining trees with grazing (silvo-pastoral) are now included. However, the rules do not account for Indirect Land-use Change (ILUC). This means that if farmers change how they use their land, it could push food or feed production elsewhere, increasing deforestation or emissions. Even if the local project seems beneficial, science shows that ILUC changes are significant for such activities. In addition, enlarging the scope to croplands and grasslands could lead to even more competition and unintended environmental harm. At minimum, these activities should be excluded unless ILUC calculations are properly addressed accounted for in the methodology.  

Bellona regrets that, instead of being limited to degraded land – a “no-regret” option that could have helped restore life to depleted ecosystems – the scope of the afforestation methodology has been expanded to other activities in this delegated act. 

The methodology includes livestock grazing, but scientific evidence shows that livestock emissions often cancel out any carbon benefits. If these activities are allowed, all livestock emissions should be counted for or excluded altogether. The methodology as it stands does not require methane or nitrous oxide tracking, so the real climate benefit is not measured. 

The rules around tree planting are not strict enough, e.g. bans on non-native species, or weak justification for their use and could harm local ecosystems. 

Biochar and double accounting 

The link between biochar and carbon farming is mentioned but is unclear on what is expected in terms of double accounting and claiming of the credits between the two categories. 

For biochar, permanence is engineered into the material and the methodology discounts away the labile fraction of carbon, certifying only for the permanent fraction. However, for Soil Organic Carbon (SOC) projects, the soil is the storage medium itself and all microbial processed (including priming) directly change the credited carbon stock. This is why projects under temporary removals have reversals rules, a liability not attached to biochar units in the permanent removals delegated act. Because of the soil’s dynamics and the addition of both labile and permanent carbon from biochar addition, a simple subtraction of biochar units is not sufficient to prevent double claiming / stacking of units. 

Long-term commitments 

Temporary practices should be incentivised in the long-term, with the aim of storing captured carbon for at least several decades. Taking afforestation as an example, current provisions do not prevent operators from clear-cutting trees after 40 years and burning them afterwards for energy. This lack of commitment to preserving carbon stocks would reverse any positive long-term climate impact generated during the activity. 

Weak safeguards and potential loopholes for implementation 

Several provisions are vaguely worded and offer excessive flexibility for implementing the rules. For instance, quantification and uncertainty provisions seldom require ground data, there is unclarity around the updating of the baselines, and “existing databases”, “expert judgment,” and “scientific literature”, are relied upon without sufficient clarity. Similarly, the language governing harvests and clear cuts, the use of non-native and single species is vague and fails to adequately safeguard against biodiversity risks. These shortcomings must be addressed to strengthen the robustness of the scheme, offer clarity for operators, and to ensure both uniform enforcement and quality across the EU. 

Quantification 

Overall, there is still a lot of flexibility when it comes to quantification: rules are vague, with weak wording that could allow misuse. For example, phrases like “certification schemes may provide additional guidance” (instead of mandatory rules) or “expert judgment” (instead of hard data) should be removed. There is too much flexibility for baselines: farmers can use zero as a baseline for soil carbon, ignoring pre-existing vegetation.  This could lead to overestimating benefits or even fraud.  Bellona recommends having activity-specific baselines with clearer rules on how to select datasets for justifying and updating the baselines.  

The methodology should provide specific guidance on how to allow models to be used. The baseline should account for ILUC and carbon debt / payback periods to make sure climate benefits are realised on the timescale of the certification period. Moreover, albedo effects are not part of the quantification of the methodology. There is scientific evidence that shows tree covers affect the overall carbon removal of afforestation. 

Liability and risk assessment 

The delegated act should respect article 5 of the CRCF Regulation and remove the derogations regarding additionality and reinstate the common practice criterion. While trying to lower the cost of MRV by pooling together operators and common practises, this could lead to misuse and poor data collection with high ecological impacts. While moving away from an ill-defined common practice criterion is appreciated, this does not justify removing the criterion altogether. 

Clear “end-of-line” accountability needs to be clearly stated if carbon is lost or projects fail, as is the case in the Paris Agreement Crediting Mechanism (PACM). Bellona regrets that the methodologies lack clear penalties in the event that the stored carbon is released (e.g. due to avoidable and unavoidable reversals). 

Peatland restoration projects are inherently unpredictable in terms of stabilisation times, fluctuation of emissions, net emission reductions, biodiversity benefits, seasonal and climate change. Therefore, peatlands rewetting does require a liability mechanism; in line with existing mechanisms such as the UK Peatland Code or PACM. A systematic project-specific risk assessments would accurately quantify all risks, to ensure the risk rate reflects each project’s specific characteristics. Failure to do so could seriously undercapitalise buffer pools.  

Sustainability  

More ambition is needed for the sustainability criteria to go beyond existing laws and drive a positive change with measurable climate benefits, looking at biodiversity and ecosystem restoration services. 

The explicit reference to Do No Significant Harm (DNSH) as an overarching minimum rule for the sustainability criteria should be reintroduced as well as the minimum requirements for a circular economy from the previous draft. Generally, the rules lack clarity around how the minimum requirements are to be operationalised. At present, operators must simply not break the law, yet the CRCF, as a voluntary tool, should be the space to push for more ambition. Further, since these minimum requirements could be weakened in the future, provisions should be added to ensure this does not hinder the CRCF’s sustainability criteria. 

These requirements are not enough to prevent habitats of value to biodiversity being converted to afforestation with little biodiversity. Valuable habitats such as extensive grasslands, that are not necessarily designated for protection, could be replaced by agroforestry activities; the counterfactual scenarios are not being defined (loss of biodiversity from the activity) 

The mandatory co-benefits provisions should be more robust. In this current draft, operators “may” (instead of “shall”) choose one of the four options for compliance. Bellona is concerned that the current assessment is purely qualitative and does not require the use of indicators, such as those established under the Nature Restoration Law. Allowing compliance to be demonstrated through peer-reviewed literature alone is problematic, as relevant findings may be based on conditions that are not representative of the operator’s project, exaggerating potential biodiversity gains. This option should be rendered more robust by, for instance, demanding specificity to the ecosystem of the activity area.  

Finally, social safeguards should be embedded in the methodology. Article 8 of the CRCF Regulation states “the certification methodologies shall contribute to avoiding land speculation”. Addressing the social risks and requiring safeguards is crucial to avoid exacerbating inequalities in the land sector and to support rural areas across the EU. 

Read Bellona’s public response on the carbon farming draft delegated act here (closed on the 19^th of February 2026). 

Next steps

The Delegated Act for carbon farming is expected to be adopted by the Commission this year. With the adoption of the Implementing Act of the CRCF for registry and third-party verification, projects are expected to be certified under the CRCF in early 2027, with the issuance of the first CRCF credits.  

The Delegated Act for permanent removals is currently under scrutiny from Member States and European Parliament. The ETS is planned for a review in July 2026 from the Commission. 

The Commission is investigating the potential development of upcoming methodologies related to marine CDR (Ocean Alkalinity Enhancement, Direct Ocean Capture), carbon storage through mineralisation and Enhanced Work Weathering. 

The review the Commission’s legislative package for the CRCF framework is planned by the end of the year 2026. 

More broadly, the Commission has opened a few public consultations this year, with aspects relevant in the context of the CRCF: on the LULUCF regulation itself feeding into the questionnaire on the post 2030 climate architecture, the use of international credits and the Governance Regulation consultation.