Biodiversity and the Carbon Removals Carbon Farming Framework

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The briefing criticizes the EU's draft methodologies for the Carbon Removals and Carbon Farming Framework (CRCF), specifically regarding the 'mandatory biodiversity co-benefit' criterion. It argues that the results-based approach relies on circular and weak indicators, such as soil organic carbon (SOC), while the activity-based approach incorrectly presumes biodiversity gains without considering farm-specific contexts. The author calls for the adoption of more robust, science-based indicators, a delay in publishing methodologies to align with the Soil Monitoring Law, and the inclusion of a review clause to ensure environmental integrity.

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  • The draft methodologies for the CRCF favor carbon sequestration over biodiversity, treating the latter as 'co-benefits' or byproducts rather than a central priority.
  • The results-based approach for agricultural methodology is flawed because it uses soil organic carbon (SOC) as a biodiversity indicator, creating a circular logic where the activity being certified is also used to measure its own co-benefits.
  • The activity-based approach is insufficient because it presumes positive biodiversity outcomes based on a list of 33 restoration measures from the Nature Restoration Regulation (NRR) without accounting for the specific context of individual farms.
  • There is a significant discrepancy in rigor between carbon and biodiversity measurements; while carbon requires strict monitoring, reporting, and verification (MRV), biodiversity is subject to poor indicators or simple performance standards.
  • The briefing suggests that indicators from the Regen10 initiative or the proposed EU Soil Monitoring Law (SML)—such as metabarcoding of bacteria and fungi or the abundance of earthworms—would be more robust than those currently proposed.
  • The author recommends that the European Commission delay the publication of methodologies to allow for scientific developments and the conclusion of SML negotiations, and include a review clause for regular updates.

Cite the original document

APA
Hernández, M. R. (2025). Biodiversity and the Carbon Removals Carbon Farming Framework. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2025/03/Biodiversity-and-the-Carbon-Removals-Carbon-Farming-Framework-final.pdf
Chicago
Hernández, Marlène Ramón. Biodiversity and the Carbon Removals Carbon Farming Framework. Carbon Market Watch, 2025. https://carbonmarketwatch.org/wp-content/uploads/2025/03/Biodiversity-and-the-Carbon-Removals-Carbon-Farming-Framework-final.pdf.
Wikipedia
{{cite report |last1=Hernández |first1=Marlène Ramón |title=Biodiversity and the Carbon Removals Carbon Farming Framework |publisher=Carbon Market Watch |date=March 2025 |url=https://carbonmarketwatch.org/wp-content/uploads/2025/03/Biodiversity-and-the-Carbon-Removals-Carbon-Farming-Framework-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{hernndez2025biodiversity, author = {Hernández, Marlène Ramón}, title = {{Biodiversity and the Carbon Removals Carbon Farming Framework}}, institution = {Carbon Market Watch}, year = {2025}, month = mar, url = {https://carbonmarketwatch.org/wp-content/uploads/2025/03/Biodiversity-and-the-Carbon-Removals-Carbon-Farming-Framework-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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