CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity

A coalition of NGOs, including Carbon Market Watch, warns that the European Commission's draft delegated act for permanent carbon removals—covering DACCS, BioCCS, and biochar—fails to meet the legal requirements of the CRCF regulation. The group argues the methodologies are of low quality, fail to address indirect land use change, assume automatic additionality, and lack sufficient MRV and liability rules for biochar. They call on the European Parliament and Council to object to the draft and urge the Commission to prevent the integration of these units into the EU ETS until quality is ensured.

• The draft delegated act for permanent removals, which includes direct air capture and storage (DACCS), biogenic emission capture and storage (BioCCS), and biochar, is described as not fit for purpose. An independent assessment by Öko-Institute characterized the proposed CRCF methodologies as being among the lowest quality they have reviewed.
• The proposal fails to meet CRCF legal requirements regarding the quantification of net carbon removal benefits, specifically by not adequately addressing indirect emissions and indirect land use change (ILUC). The NGOs warn that the current text could lead to the certification of unsustainable forest burning under the guise of climate mitigation.
• The draft assumes automatic additionality for DACCS, BioCCS, and biochar, omitting any regulatory or financial additionality testing despite the fact that these activities may already be receiving subsidies or be mandatory in some member states.
• Biochar lacks meaningful Measurement, Reporting and Verification (MRV) or liability rules, which contradicts the CRCF requirement that such rules be consistent with the CCS Directive. Additionally, the draft ignores overlaps between biochar and agricultural soil methodologies.
• The NGOs warn that if methodologies are not fundamentally improved, the majority of CRCF units will not represent actual emission reductions or removals, rendering them not credible for compensation claims.

APA

Carbon Market Watch (2025). CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity. https://carbonmarketwatch.org/wp-content/uploads/2025/07/Wijnand-CREG-CRCF-methodologies-1.pdf

Chicago

Carbon Market Watch. CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity. 2025. https://carbonmarketwatch.org/wp-content/uploads/2025/07/Wijnand-CREG-CRCF-methodologies-1.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity |date=10 July 2025 |url=https://carbonmarketwatch.org/wp-content/uploads/2025/07/Wijnand-CREG-CRCF-methodologies-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2025crcf, author = {{Carbon Market Watch}}, title = {{CRCF Draft on Permanent Carbon Removals Lacks Scientific and Environmental Integrity}}, publisher = {Carbon Market Watch}, year = {2025}, month = jul, url = {https://carbonmarketwatch.org/wp-content/uploads/2025/07/Wijnand-CREG-CRCF-methodologies-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }