The European Green Deal (Green Deal) is a vast network of European Union legislation that addresses all aspects of ecological transition, touching on key sectors such as energy, transport, industry and forest management. Presented by the previous European Commission (2019-2024), this ambitious plan recognizes that achieving carbon neutrality by 2050 will require more than just reducing emissions, but we'll also have to rely on carbon dioxide removal (CDR) technologies. to offset our residual emissions.
In this context, the EU is gradually integrating CDR into its current legislation. A central pillar of this integration is the Regulatory framework for carbon certification (CRCF)which aims to become the basis for all future CDR regulations. This framework aims to clarify what constitutes CDR, establish criteria for identifying high-quality disposal practices, and guarantee the reliability and transparency of projects on a European scale.
Approved in trialogue on February 19, 2024, is a major step forward in promoting permanent CDR certification, carbon storage in products and "carbon farming" (agricultural practices that improve carbon storage, a late addition which led to a change of name to Carbon Removals and Carbon Farming regulation). The CRCF thus became the foundation on which all EU CDR policies were built.
CRCF objectives
The CRCF's main objective is to promote the adoption of reliable CDR methods and high quality. A central aspect of this framework is the way it defines the permanence carbon storage (i.e. that once a tonne of CO2 has been stored, it is not re-emitted in the long term). Previously, there was no clear distinction between carbon credits derived from short-term solutions (such as temporary storage in forests or soil) and those linked to long-term storage (for example, the BECCS or DACCS with geological storage that can last several thousand years). This lack of differentiation was one of the main factors behind the creation of these regulations.
In addition to the permanence of storage, another crucial objective of the CRCF is to improve the quality of our products. traceability and transparency of carbon credits credits throughout their lifecycle, from CO2 capture to final storage. This includes rigorous measurement, reporting and verification (MRV) protocols to ensure that credits reflect real, additional and measurable reductions in CO2 emissions.
Finally, another CRCF ambition is to facilitate harmonization of carbon markets, both nationally and internationally. The eventual aim could be to ensure greater interoperability of carbon credit systems between different countries (As the EU ETS or the Swiss ETS), while maintaining high quality standards. This harmonization would increase market liquidity while preserving the environmental integrity of credits.
Certifiable carbon dioxide removal categories
The CRCF defines and differentiates three main categories:
- Permanent CDR : Practices that capture and store atmospheric or biogenic carbon (from organic matter) for several centuries.
- Carbon storage in products : Practices that capture and store carbon in sustainable products for at least 35 years, with ongoing monitoring during the certification period.
- Carbon farming : Any land or coastal zone management practice, over a period of at least five years, that temporarily captures and stores carbon in soils or reduces soil emissions.
These three categories established by the CRCF make it possible to clearly distinguish permanent from temporary solutions, and thus to assign different time scales to each carbon management method. This is particularly important when integrating technologies such as biochar or enhanced rock weathering, which store carbon for several centuries, and can therefore be classified as permanent CDR technologies.
These distinctions allow for technological diversity in the CRCF, which is the only way to develop the CDR. The CRCF will introduce specific methodologies to certify a wide range of carbon removal practices. The European Commission, assisted by a expert panel, will be responsible for developing these methodologies, which will cover various technologies such as direct air capture with storage (DACCS), bioenergy with carbon capture and storage (BECCS), or biochar. Existing certification systems will also be taken into account to ensure that activities comply with CRCF criteria. To ensure the reliability of these different categories, the CRCF imposes strict criteria for their certification.
CDR quality certification criteria
The CRCF requires precise quantification of CDRs, based on QU.A.L.ITY quality criteria (QUantification, Additionality, Long-term Storage, and SustainabilITY) to ensure that CDR projects deliver real, measurable benefits:
- Quantification Accurate measurement of carbon removals is essential to ensure that credits represent real reductions. Quantification must take account of uncertainties, and be compatible with the national greenhouse gas emission inventories (National Carbon Accounting Tools).
- Additionality Carbon removals must be directly attributed to the incentives created by the certification framework. This means that without these incentives, these reductions would not have taken place.
- Long-term storage To avoid carbon re-emissions, projects must guarantee carbon storage over several decades, or even centuries, particularly for agricultural and natural solutions where the risk of reversion is high.
- Durability Activities must respect broader environmental and social objectives, such as biodiversity and community well-being. They must avoid any negative impact on the environment (e.g. protection of biodiversity, central to the use of biomass-based CDR).
Integrating the CRCF into the European Green Deal
The CRCF was the missing piece needed to seamlessly integrate CDR into a wide range of European climate policies, and was designed to work in concert with other EU instruments. By defining robust certification, monitoring and verification standards, the CRCF ensures the credibility and effectiveness of carbon removal projects, paving the way for their integration into all strata of the European Green Deal.
- Green Claims Directive : This directive, which is currently being negotiated, governs the way in which companies communicate about their climate actions, and in particular their neutrality. It recognizes the CRCF to enable companies to claim carbon credits that will be certified by this framework. In addition, another regulation on the publication of sustainability information, the CSRDThe European Union's Emissions Trading Scheme (ETS) requires companies to declare separately their greenhouse gas emissions and the carbon credits they use to offset these emissions, while specifying the quality and source of these credits. The CRCF, by providing a certification framework for carbon offset credits, ensures that the credits used meet strict standards of transparency and credibility.
- Industrial Carbon Management Strategy (ICMS): The European Commission's ICMS defines the role of carbon management technologies, including certain CO2 removal methods, in the EU's decarbonization. It proposes measures to develop them. Indeed, the ICMS forecasts that 280 MtCO2 by 2040 and 450 MtCO2 by 2050 will have to be captured on a European scale. The preamble to the CRCF makes explicit reference to the CDR support actions provided for in the ICMS and stresses the importance of defining specific targets, thus going beyond communications on 2040 targets by defining the central role of CDRs in achieving carbon neutrality.
- 2040 targets : The EU's climate objectives for 2040 include the need to establish separate targets for permanent carbon removal. This distinction is made possible by the existence of a clear European framework.
Potential of CDR integration in the European carbon market (ETS)
One of the most significant impacts of the CRCF is its potential role in facilitating the integration of CDRs into the EU Emissions Trading Scheme (ETS). The ETS, established in 2005, is one of the world's largest markets for carbon allowances. covers emissions, accounting for around 40 % of European emissions. It obliges companies to buy credits for their CO₂ emissions, encouraging a gradual reduction in emissions. From numerous scenarios for integrating CDR into ETSs. All of them require some form of solid certification to guarantee the system's longevity.
The CRCF could enable the ETS to include CDR technologies in the years to come. By July 31, 2026, the European Commission must submit a report assessing the potential integration of negative emissions technologies (NETs) into the ETS. This will include an assessment of how CDR can be accounted for in the market without compromising emission reduction efforts.
The CRCF can help ensure that only high-quality CDRs can be traded on the ETS market. Without the CRCF, CDR integration into the ETS would be difficult and could threaten the integrity of the ETS.
Impact of CRCF on companies
The CRCF has a major impact on companies, whether they are purchasers or suppliers of carbon credits. For buyers, the CRCF enables them to guarantee the quality of the carbon removal credits they acquire, thanks to a process recognized by the public authorities. This certification reduces reputational and compliance risks, while offering greater transparency. It allows companies to engage in carbon removal projects with confidence, knowing that CRCF-certified credits meet high standards and are tracked in a public registry, simplifying the management and authenticity of credits.
For sellers, the CRCF offers a competitive advantage by clearly distinguishing high-quality carbon credits, often more expensive, less sustainable solutions. This ensures that permanent carbon removal projects, such as biochar or direct air capture, are recognized and valued at their true worth.
Implementation and future of CRCF
Following the provisional agreement of February 2024, the focus is now on developing the methodologies needed to operationalize the CRCF. The first methodologies for DACCS, BECCS and biochar should be available by the end of 2024, with completion scheduled for 2026. Methodologies for other technologies will follow. The framework should be fully operational by the end of 2026 or early 2027.
The CRCF is therefore much more than just a certification framework: it provides the basis for integrating carbon removal solutions into all EU climate policies. By facilitating the adoption of high-quality CDRs, defining clear targets for permanent and temporary removals, and providing a solid framework for the integration of CDRs into the ETS, the CRCF ensures that carbon removal is not an isolated effort, but a central element of the EU's overall climate strategy.
Ultimately, the CRCF's impact will be decisive in achieving the EU's ambitious climate goals, including carbon neutrality by 2050. This framework could not only boost business and investor confidence, but also help make Europe a world leader in the management of high-quality carbon offset credits.
What about AFEN? The role of French players in the development of CRCF
AFEN (Association Française pour les Émissions Négatives) has positioned itself as a key player in contributing to the success of the CRCF and its implementation over the coming years.
- Represent CDR nationally: As the European Union implements the CRCF, AFEN's role will also be to ensure that France makes a significant contribution to the collective effort, while capitalizing on its own strengths. In particular, AFEN will have to ensure that France adopts clear and ambitious CDR objectives, in line with European targets. Furthermore, in the future development of CRCF methodologies, AFEN is participating in the effort to ensure that national specificities are taken into account. Not all EU countries share the same strengths when it comes to deploying carbon removal technologies. France, for example, is the world's 5th largest exporter of agricultural products, a major sector for CDR and biomass-based solutions (Biochar, BECCS, etc.). AFEN will be able to defend these advantages to European decision-makers, ensuring that these national assets are integrated into future discussions and methodologies.
- Prepare the ground for CDR integration into ETS: By 2026, the integration of carbon removal technologies (CRTs) into the Emissions Trading Scheme (ETS) will be a central issue for the EU. Thanks to the standardization provided by the CRCF, AFEN will be at the forefront of discussions on direct or indirect integration into the ETS.
In the years to come, CDR debates will require strong, credible voices. AFEN can mobilize its expertise and that of its members to influence discussions within the new European Commission and other European institutions.
written by Raphaël Cario
