Position paper: Removals in the EUs post-2030 climate architecture

Carbon Market Watch advocates for a reinforced EU climate framework after 2030, proposing the introduction of separate permanent removal targets as an additional pillar alongside the Effort Sharing Regulation (ESR) and the LULUCF Regulation. The paper argues against the use of flexibilities that allow land-based sequestration to offset emission deficits, warns against the reliance on international carbon credits, and criticizes the quality and accounting alignment of the Carbon Removals and Carbon Farming (CRCF) certification framework. It suggests a bottom-up EU-wide target for permanent removals with binding national 'floor' and 'ceiling' targets to ensure accountability and fair distribution of effort.

• The current EU climate architecture allows for flexibilities where net removals from the land sector exceeding LULUCF targets can cover emission reduction deficits under the ESR, which Carbon Market Watch argues replaces more reliable emission reductions with temporary and vulnerable sequestration.
• The author recommends that the EU maintain binding national targets for the ESR and LULUCF while introducing a third, separate pillar for permanent removal targets to align with European Scientific Advisory Board on Climate Change (ESABCC) recommendations.
• There is a specific call for a binding, ambitious non-CO2 gross emissions reduction target for the agriculture sector, separate from LULUCF, noting that some projections suggest reductions of up to 60% by 2045 are possible.
• The document opposes the use of international carbon credits to meet the 2040 target, suggesting instead a domestic 90% net emissions reduction ambition where international credits are used only as a strongly disincentivised last resort.
• The Carbon Removals and Carbon Farming (CRCF) certification framework is criticized for poor quality methodologies and a fundamental misalignment with national inventory accounting systems, which follow TACC criteria (transparency, accuracy, completeness, comparability and consistency).
• The proposed design for permanent removal targets includes a 'ceiling' to respect planetary and social boundaries and a 'floor' for minimum delivery volumes, with floor targets becoming legally binding from 2035 onward.

APA

Carbon Market Watch (2026). Position paper: Removals in the EUs post-2030 climate architecture. https://carbonmarketwatch.org/wp-content/uploads/2026/05/Position-paper-on-removals-in-the-post-2030-target-climate-architecture-3.pdf

Chicago

Carbon Market Watch. Position paper: Removals in the EUs post-2030 climate architecture. 2026. https://carbonmarketwatch.org/wp-content/uploads/2026/05/Position-paper-on-removals-in-the-post-2030-target-climate-architecture-3.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Position paper: Removals in the EUs post-2030 climate architecture |date=4 May 2026 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/05/Position-paper-on-removals-in-the-post-2030-target-climate-architecture-3.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2026position, author = {{Carbon Market Watch}}, title = {{Position paper: Removals in the EUs post-2030 climate architecture}}, publisher = {Carbon Market Watch}, year = {2026}, month = may, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/05/Position-paper-on-removals-in-the-post-2030-target-climate-architecture-3.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }