POOR FRAMING

The report concludes that all analyzed policy frameworks are inadequate for the robust deployment of carbon dioxide removals (CDR). Most frameworks fail to establish a clear firewall between emissions reductions and removals, often treating them as interchangeable through offsetting mechanisms. Key deficiencies include the absence of legally binding, separate CDR targets, the lack of a robust definition of CDR that ensures long-term permanence, and insufficient monitoring, reporting, and verification (MRV) systems. The authors recommend that CDR be strictly defined as a secondary climate function to balance residual emissions, supported by dedicated legal targets and rigorous accounting to prevent 'mitigation deterrence'.

• All 20 analyzed policy frameworks are considered inadequate and require further development to achieve their climate goals, as most fail to recognize the climate function of removals as supplementary to emissions reduction.
• No analyzed framework has established comprehensive, separate, and legally binding targets for CDR, although nature-based removal targets exist in law for the EU's LULUCF regulation, the German climate law, and UK carbon budgets.
• There is a widespread trend of using CDR to offset emissions or reduce the pressure to cut emissions, specifically within CORSIA, the Clean Development Mechanism (CDM), and Article 6 of the Paris Agreement.
• The EU's proposed Carbon Removal Certification Framework (CRCF) is criticized for not defining the end use of certified units, potentially allowing them to be used for offsetting in voluntary and compliance markets.
• A robust definition of CDR is missing across all assessed frameworks; many include short-term or vulnerable sequestration methods, such as soil or vegetation, without distinguishing them from permanent storage.
• None of the assessed frameworks contain robust, comprehensive accounting and MRV methodologies, with existing rules often limited to LULUCF or specific offsetting certification aims.
• The UK is the only analyzed country that explicitly states the need for 'case-by-case scrutiny' of supply chain carbon intensity and long-term indirect emissions for removal projects.
• New Zealand's Emission Trading Scheme (NZ ETS) is criticized for treating forest carbon sequestration as equivalent to emissions reductions, which the authors argue creates a 'carbon debt'.

APA

De Simone, F., Laugesen, A., & Stoefs, W. (2023). POOR FRAMING. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2023/09/Poor-framing_-The-role-of-negative-emissions-technologies-in-climate-policy-frameworks-1.pdf

Chicago

De Simone, Fabiola, Adam Laugesen, and Wijnand Stoefs. POOR FRAMING. Carbon Market Watch, 2023. https://carbonmarketwatch.org/wp-content/uploads/2023/09/Poor-framing_-The-role-of-negative-emissions-technologies-in-climate-policy-frameworks-1.pdf.

Wikipedia

{{cite report |last1=De Simone |first1=Fabiola |last2=Laugesen |first2=Adam |last3=Stoefs |first3=Wijnand |title=POOR FRAMING |publisher=Carbon Market Watch |date=September 2023 |url=https://carbonmarketwatch.org/wp-content/uploads/2023/09/Poor-framing_-The-role-of-negative-emissions-technologies-in-climate-policy-frameworks-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{desimone2023poor, author = {De Simone, Fabiola and Laugesen, Adam and Stoefs, Wijnand}, title = {{POOR FRAMING}}, institution = {Carbon Market Watch}, year = {2023}, month = sep, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/09/Poor-framing_-The-role-of-negative-emissions-technologies-in-climate-policy-frameworks-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }