Submission to EU Call for Evidence: Certification of Carbon Removals

The Clean Air Task Force (CATF) argues that carbon dioxide removals (CDR) are essential for the EU to reach climate neutrality by 2050, as current emission reduction policies are insufficient. CATF proposes a certification mechanism based on a 'long-cycle' (geological storage) and 'short-cycle' (terrestrial sinks) categorisation rather than a binary 'natural' vs 'industrial' split. To ensure environmental integrity, CATF recommends seven minimum standards: real, measurable, permanent, additional, avoidance of leakage, avoidance of double counting, and sustainability. The submission emphasizes that credits from short-cycle and long-cycle removals should not be fungible, with long-cycle removals carrying higher value due to their permanence. CATF also suggests a three-step process for integrating innovative CDR methods and a governance structure involving a clear division of responsibilities between public authorities and private certification bodies, supported by a Union-wide registry.

• CATF argues that carbon dioxide removals (CDR) are necessary to achieve the European Union's goal of climate neutrality by 2050 because current emission reduction policies are inadequate.
• CATF proposes replacing the 'natural ecosystems' and 'industrial solutions' binary with a categorisation based on the carbon cycle length: 'short-cycle' for terrestrial sinks (decades to centuries) and 'long-cycle' for geological formations (millennia to millions of years).
• The proposed certification mechanism should adhere to seven minimum standards: removals must be real, measurable, permanent, additional, avoid leakage, avoid double counting, and be sustainable.
• CATF recommends that credits for short-cycle and long-cycle removals should not be fungible, and that short-cycle removals should have a lower market value due to their higher risk of reversal.
• To support innovation, CATF proposes a three-step process for new CDR methods: initial public recognition, a period of developing a recognised methodology with credits that are not fungible with established methods, and finally achieving fully-fledged status.
• The governance of the mechanism should include a clear division of responsibilities between public and private bodies, a Union-wide registry for transparency, and EU-level advisory boards including scientific and civil society stakeholders.

APA

Clean Air Task Force (2022). Submission to EU Call for Evidence: Certification of Carbon Removals. https://cdn.catf.us/wp-content/uploads/2022/05/11045110/CDR-Commission-response.pdf

Chicago

Clean Air Task Force. Submission to EU Call for Evidence: Certification of Carbon Removals. 2022. https://cdn.catf.us/wp-content/uploads/2022/05/11045110/CDR-Commission-response.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Submission to EU Call for Evidence: Certification of Carbon Removals |date=30 April 2022 |url=https://cdn.catf.us/wp-content/uploads/2022/05/11045110/CDR-Commission-response.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2022submission, author = {{Clean Air Task Force}}, title = {{Submission to EU Call for Evidence: Certification of Carbon Removals}}, publisher = {Clean Air Task Force}, year = {2022}, month = apr, url = {https://cdn.catf.us/wp-content/uploads/2022/05/11045110/CDR-Commission-response.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }