How to make carbon removals work for climate action in the EU

Carbon Market Watch argues that the EU's proposed Carbon Removal Certification Framework (CRCF) must be strictly limited to permanent carbon removals to avoid 'mitigation deterrence'. The organization recommends prohibiting the use of certified removals for offsetting emissions in the EU ETS or ESR, excluding carbon farming and carbon storage in products due to their lack of permanence, and implementing stricter quality criteria for quantification and liability. It suggests that nature-based solutions should be funded via activity-based finance for biodiversity and soil health rather than through carbon removal metrics.

• Carbon removals must be legally established as a supplement to deep emission reductions and should contribute to a separate EU removal target to prevent 'mitigation deterrence', where removals slow down emission reduction efforts.
• The CRCF should explicitly prohibit the use of certified removals for offsetting purposes, specifically ruling out their use within the EU Emission Trading System (ETS), the Effort Sharing Regulation (ESR), or voluntary carbon markets.
• To ensure environmental integrity, the framework should only certify 'real' removals that store carbon permanently—defined as at least two centuries—and exclude carbon farming and carbon storage in products.
• Carbon farming is deemed unsuitable for the CRCF because biogenic carbon pools are vulnerable to disturbances, can reach saturation within decades, and often involve short-term storage with uncertain mitigation benefits.
• The document recommends strengthening quality criteria by using 'conservative' rather than 'accurate' estimates in quantification to limit overestimation, and requiring a breakdown of both direct and indirect emissions.
• Liability for carbon reversals should be placed on the actors who benefited financially from the activity, rather than the general public or countries, potentially linking liability to the CCS Directive.
• Nature-based solutions should be shifted away from carbon metrics and instead be supported through activity-based finance focused on biodiversity, soil quality, and water retention.
• Transparency should be increased by making the Expert Group on Carbon Removals' meetings public, requiring operators to disclose complete activity information, and maintaining a public central registry of all certified projects.

APA

Carbon Market Watch (2023). How to make carbon removals work for climate action in the EU. https://carbonmarketwatch.org/wp-content/uploads/2023/02/CMW-position-paper-on-the-CRCF-LR.pdf

Chicago

Carbon Market Watch. How to make carbon removals work for climate action in the EU. 2023. https://carbonmarketwatch.org/wp-content/uploads/2023/02/CMW-position-paper-on-the-CRCF-LR.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=How to make carbon removals work for climate action in the EU |date=February 2023 |url=https://carbonmarketwatch.org/wp-content/uploads/2023/02/CMW-position-paper-on-the-CRCF-LR.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2023how, author = {{Carbon Market Watch}}, title = {{How to make carbon removals work for climate action in the EU}}, publisher = {Carbon Market Watch}, year = {2023}, month = feb, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/02/CMW-position-paper-on-the-CRCF-LR.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }