Open letter to the European Commission on sustainable carbon cycles

A coalition of environmental organizations warns the European Commission that the Sustainable Carbon Cycles Communication risks undermining climate ambition if it allows carbon removals to be used as offsets for emissions. While supporting the Carbon Removal Certification Mechanism and improved climate accounting by 2028, the authors argue that removals should not be treated as tonne-for-tonne equivalents to emissions reductions. They specifically oppose the inclusion of removal offsets in the EU ETS, ESR, and LULUCF regulations, and call for a strict definition of storage permanence to distinguish real removals from short-term carbon stores.

• The authors support the prioritization of deep emission reductions over carbon removals to maintain the 1.5°C limit of the Paris Agreement, as well as the proposed Carbon Removal Certification Mechanism and the domestic scope of the Communication.
• The document welcomes the goal of improving climate accounting by 2028, which would require reporting the origin of captured CO2 as fossil, biogenic, or atmospheric.
• The authors argue that allowing the trading of emissions offsets in the EU Emissions Trading System (ETS), Effort Sharing Regulation (ESR), and Land Use, Land-use Change, and Forestry (LULUCF) Regulation after 2030 would be counter-productive and contradict the priority of emission reductions.
• Carbon removals should be regulated separately from GHG emissions reductions and not treated as interchangeable tonne-for-tonne equivalents; instead, demand for removals should be driven by a separate target.
• The Commission is urged to strictly define the permanence of storage to distinguish real removals (lasting centuries) from short-term stores like bio-plastics or building materials, and to clarify liability for reversals, particularly in nature-based removals such as carbon farming.

APA

Frank, S., Helseth, J., Mariani, B., Sharma, S., Martinelli, C., Mowat, H., Mattera, L., Stoczkiewicz, M., & Asin, E. (2021). Open letter to the European Commission on sustainable carbon cycles. Carbon Market Watch. https://carbonmarketwatch.org/publications/open-letter-to-the-european-commission-on-sustainable-carbon-cycles/

Chicago

Frank, Sabine, Jonas Helseth, Barbara Mariani, Shefali Sharma, Chiara Martinelli, Hannah Mowat, Lucie Mattera, Magda Stoczkiewicz, and Ester Asin. Open letter to the European Commission on sustainable carbon cycles. Carbon Market Watch, 2021. https://carbonmarketwatch.org/publications/open-letter-to-the-european-commission-on-sustainable-carbon-cycles/.

Wikipedia

{{cite press release |last1=Frank |first1=Sabine |last2=Helseth |first2=Jonas |last3=Mariani |first3=Barbara |last4=Sharma |first4=Shefali |last5=Martinelli |first5=Chiara |last6=Mowat |first6=Hannah |last7=Mattera |first7=Lucie |last8=Stoczkiewicz |first8=Magda |last9=Asin |first9=Ester |title=Open letter to the European Commission on sustainable carbon cycles |publisher=Carbon Market Watch |date=1 December 2021 |url=https://carbonmarketwatch.org/publications/open-letter-to-the-european-commission-on-sustainable-carbon-cycles/ |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{frank2021open, author = {Frank, Sabine and Helseth, Jonas and Mariani, Barbara and Sharma, Shefali and Martinelli, Chiara and Mowat, Hannah and Mattera, Lucie and Stoczkiewicz, Magda and Asin, Ester}, title = {{Open letter to the European Commission on sustainable carbon cycles}}, publisher = {Carbon Market Watch}, year = {2021}, month = dec, url = {https://carbonmarketwatch.org/publications/open-letter-to-the-european-commission-on-sustainable-carbon-cycles/}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }