What is it?

The CRCF is a first-of-its-kind regulatory regime defining high quality carbon removal and setting standards for monitoring and certifying removal initiatives. In doing so, it aims to promote reliability, comparability and transparency across the carbon removal market, ultimately driving demand for effective carbon removals and countering greenwashing. The law extends to carbon removal initiatives within the EU, with adherence to the framework voluntary (at least initially).

How will it work?

The framework provides a foundation for a credible and robust certification regime across Europe, focusing on a range of key carbon removal methods and setting criteria to compare quality between them. Importantly, this includes quantification accurately accounting for a credit’s impact, and durability distinguishing between ‘permanent’ carbon removals (such as bioenergy with carbon capture and storage and direct air capture) and ‘temporary’ methods (such as soil management and carbon storage in products). It also defines a transparent certification process, with standard procedures, third party verification and traceable credit issuance stored in public registries.

Why is it important?

The CRCF’s passing is a significant policy development, with its definition of quality likely to act as a benchmark for emerging rules globally. Most immediately, the CRCF is a starting point to integrate removals into other key European proposals, including rules governing environmental claims under the Green Claims and Empowering Consumers directives, as well as how durable carbon removals will be considered for inclusion into mandatory obligations under the EU Emissions Trading Scheme by 2026 (with potential commencement by 2030, and if not sooner within the UK ETS).

The CRCF’s progress will undoubtedly echo across the carbon removal market, particularly among credit buyers. Whilst there is emerging consensus on the role of removals within climate mitigation efforts, both at a global and corporate Net Zero level, the market for higher durability carbon removal is still nascent. With the exception of a number of high-profile ‘first-movers’, buyer behaviour continues to be influenced by some of the well-documented delivery and reputational risks associated with carbon avoidance credits. At this critical moment for the market, the CRCF’s regime will drive the integrity of the removals ecosystem, going a long way to galvanise buyer trust and confidence.

What are we looking out for next?

Before it is ready for implementation (possibly by 2025), final amendments and more detailed certification methodologies will now be agreed by European members supported by industry experts throughout 2024. As the framework develops, we hope to see greater progress to:

• Clarify how corporate buyers will be permitted to use removal credits to make legitimate environmental claims against their emissions. Guidance is needed for how different CRCF certificates can be used and how fungible each type of credit will be, supporting purchasers to take buying decisions and prevent greenwashing.

• Define a certification process able to incorporate any safe and effective removal method that meets established principles and quality standards. Important calls within industry have been made to encourage the CRCF to remain ‘technology neutral’, favouring the widest range of removal technologies that can meet evolving scalability, durability and price needs. Any omissions from the framework for key technologies, such as enhanced rock weathering, biochar and ocean-based removals, will resonate across the market.
• Better differentiate removal methods based on their durability, and avoiding any equivalences with emissions reduction activities.  Definitions should make clear what the framework considers ‘permanent’ carbon removal and how associated credits can be used, strengthening the incentives for corporate buyers to favour high durability removal initiatives.

Now, businesses and governments need to come together in full force to invest comprehensively – directly into carbon removal suppliers, via voluntary carbon credits – and drive the sustainable business models and policy support for carbon removals to meet the exponential growth required.

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