Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals
Summary
The policy brief by Carbon Market Watch and Oeko-Institut criticizes the draft CRCF methodologies for permanent carbon removals, citing critical failures in additionality, biomass accounting, and long-term monitoring. It argues that the current framework risks certifying low-quality units that do not represent actual emission reductions, potentially undermining EU climate action.
Key insights
- The draft CRCF methodologies lack rigorous additionality criteria, assuming activities are additional without evidence and ignoring existing national subsidies in countries like Sweden and Denmark or potential future EU policies.
- The framework incorrectly treats all biomass as carbon-neutral based on the Renewable Energy Directive (RED), which may lead to ecosystem degradation and an overestimation of removals by ignoring indirect land use change (ILUC) and harvesting impacts.
- Biochar methodologies are specifically criticized for lacking long-term monitoring and liability rules required by the CRCF legal text and the CCS Directive, relying instead on lab-based experiments rather than real-world testing.
- There is a critical absence of defined use cases for the certified removal units, making it impossible to determine if the methodologies are 'fit for purpose' beyond a focus on voluntary carbon market (VCM) offsetting.
- The DACCS methodology is identified as having weaker electricity matching rules (annual matching until 2029) compared to the more stringent monthly matching required by the RFNBO delegated act.
- The methodologies for BioCCS and DACCS are flawed in their quantification of net removals because they subtract estimated losses from capture totals rather than measuring the actual amount of CO2 injected at the injection point.
- The draft framework fails to provide clear procedures or timelines for reviewing and updating methodologies as new scientific findings emerge, risking the lock-in of weak rules.
Cite the original document
- APA
- Stoefs, W., & Pavia, E. (2025). Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2025/08/Policy-briefing-on-core-issues-with-the-CRCF-methodologies-final.pdf
- Chicago
- Stoefs, Wijnand, and Edoardo Pavia. Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals. Carbon Market Watch, 2025. https://carbonmarketwatch.org/wp-content/uploads/2025/08/Policy-briefing-on-core-issues-with-the-CRCF-methodologies-final.pdf.
- Wikipedia
- {{cite report |last1=Stoefs |first1=Wijnand |last2=Pavia |first2=Edoardo |title=Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals |publisher=Carbon Market Watch |date=August 2025 |url=https://carbonmarketwatch.org/wp-content/uploads/2025/08/Policy-briefing-on-core-issues-with-the-CRCF-methodologies-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{stoefs2025analysing, author = {Stoefs, Wijnand and Pavia, Edoardo}, title = {{Analysing the Carbon Removal and Carbon Farming (CRCF) methodologies for permanent removals}}, institution = {Carbon Market Watch}, year = {2025}, month = aug, url = {https://carbonmarketwatch.org/wp-content/uploads/2025/08/Policy-briefing-on-core-issues-with-the-CRCF-methodologies-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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