Improving the EU CRCF methodologies

Key concerns include the absence of an overarching programme standard, problematic baseline settings, inaccurate accounting of GHG emissions, and insufficient definitions for the biodiversity co-benefit criteria. The framework also lacks clarity regarding the intended use of carbon removal certificates, raising concerns about potential greenwashing through offsetting practices.

We encourage the European Commission to extend the timeline of the methodology development and stakeholder engagement process to accommodate the concerns outlined in this paper, among others. In its current form, the process can potentially compromise the quality and credibility of the framework.

Carbon Farming and Agriculture Methodologies

The methodologies for specific carbon removal approaches require significant refinement. In agriculture, the combination of multiple distinct activities into a single methodology risks confusion and implementation challenges, and the inclusion of soil carbon raises significant greenwashing risks.

Carbon Storage in Buildings

For carbon storage in buildings, current conditions do not support credible certification, especially given new research showing that wood harvests create greater climate debt than the benefits from material substitution. The proposed minimum lifespan of 35 years for structural components is inadequate, considering buildings can last over a century.

Permanent Removals (BioCCS & DACCS)

Regarding permanent removals through BioCCS and DACCS, the methodology fails to adequately account for all relevant emissions throughout the lifecycle of these activities. Transportation emissions and indirect land use changes are notably absent from calculations. The proposed 25% allowable increase in biomass consumption for BioCCS facilities risks placing an increasing pressure on EU forests and land resources.

Certification Scheme Recognition, Governance and Verification

The certification scheme recognition structure requires strengthening. Current proposals rely too heavily on the Renewable Energy Directive, whose certification recognition process has significant weaknesses. The framework needs stronger requirements for stakeholder representation, more robust conflict of interest policies, and comprehensive procedures for handling non-conformities and complaints.

To maintain the CRCF’s credibility and effectiveness, these issues must be addressed through extended stakeholder consultation and more comprehensive and science-based methodology development. The framework’s success depends on ensuring that certified carbon removals represent genuine, additional, and permanent climate benefits whilst avoiding environmental harm.