Reject the CRCF Delegated Act for permanent removals - it remains unsatisfactory

Carbon Market Watch and Fern call for the rejection of the CRCF Delegated Act for permanent removals, citing four primary flaws in BioCCS and biochar methodologies: insufficient consideration of biomass extraction's climate effects on land, lack of minimum capture rates for BioCCS, the use of zero baselines that ignore regulatory progress, and the failure to evaluate biomass feedstocks by carbon payback times. The authors warn that these deficiencies risk certifying projects that add emissions rather than removing them, potentially compromising the integrity of the EU ETS if these credits are integrated. They further criticize the vague rules and the potential for a 'race to the bottom' among certification bodies and auditors paid by operators.

• The document identifies four critical flaws in the BioCCS and biochar methodologies: they fail to adequately address the climate effects of biomass extraction on the land sector, lack minimum capture rates for BioCCS, utilize zero baselines that ignore current subsidy schemes and future regulatory progress, and do not evaluate biomass feedstocks based on carbon payback times.
• There is a risk that the CRCF will transition from a voluntary scheme to a compliance instrument by including Direct Air Carbon Capture and Storage (DACCS) and Bio-CCS credits in the EU Emissions Trading System (EU ETS), which could delay the decarbonisation of the EU economy if low-quality removals are used to offset fossil emissions.
• The methodology is criticized for being too vague, granting excessive leeway to operators and certification bodies, and creating a risk of a 'race to the bottom' because auditors and certification bodies are paid by the operators they oversee.
• Referencing the Oko-Institut, the document states that the proposed CRCF methodology sets a lower standard than PACM requirements and existing carbon crediting best practices, leading to risks of over-crediting and non-additionality.

APA

Hernández, M. R. (2025). Reject the CRCF Delegated Act for permanent removals - it remains unsatisfactory. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2025/11/CRCF-Delegated-Act-10-Nov-25-3.pdf

Chicago

Hernández, Marlène Ramón. Reject the CRCF Delegated Act for permanent removals - it remains unsatisfactory. Carbon Market Watch, 2025. https://carbonmarketwatch.org/wp-content/uploads/2025/11/CRCF-Delegated-Act-10-Nov-25-3.pdf.

Wikipedia

{{cite press release |last1=Hernández |first1=Marlène Ramón |title=Reject the CRCF Delegated Act for permanent removals - it remains unsatisfactory |publisher=Carbon Market Watch |date=10 November 2025 |url=https://carbonmarketwatch.org/wp-content/uploads/2025/11/CRCF-Delegated-Act-10-Nov-25-3.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{hernndez2025reject, author = {Hernández, Marlène Ramón}, title = {{Reject the CRCF Delegated Act for permanent removals - it remains unsatisfactory}}, publisher = {Carbon Market Watch}, year = {2025}, month = nov, url = {https://carbonmarketwatch.org/wp-content/uploads/2025/11/CRCF-Delegated-Act-10-Nov-25-3.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }