New Comment in Communication Earth and Environment on the the EU’s Carbon Removals Certification Framework: https://www.nature.com/articles/s43247-023-01014-x. We argue that addressing three issues in the proposal is crucial to securing robust EU policies and informing UNFCCC processes. However, the current proposal contains 3 problems which, in our view, pose a risk to the credibility of the certification scheme and to the EU’s role as an as a facilitator and innovator in the CDR policy space.

1️⃣ Reductions are not ‘removal activities’ The removal definition in the COM proposal blurs the distinction between removals & emission reductions. A loss of this distinction risks, among other things, reducing incentives for more costly removal activities

2️⃣ Use cases for temporary & permanent removals not separated The integration of CRC-F certificates into the 3 key pillars of EU climate policy may pose problems if use cases are not specified. Key question: Can CO2 emissions be counterbalanced by non-permanent removals?

3️⃣ System boundaries are unclear When certifying removals based on CCU or CCS, the origin of the CO2 and the lifecycle emissions are key factors. A prime example of unclear system boundaries are the use of CO2 for EOR, or unsustainable biomass import for BECCS

The European Parliament and the EU Member States could use their influence to address these problems. One option would be to state that follow-up legislation for 2031–2040 should include specific provisions on which type of certificate can be used for what purpose.

CRC-F is a key process to legislate that ambiguities in CDR certification schemes should not be exploited to weaken decarbonization efforts. It also provides an opportunity to set standards for aligning CDR policies with sustainability goals (beyond counting CO2)

If the EU manages to adopt a credible certification scheme, it would send a strong signal to national and multilateral processes and serve as an example of best practice for future improvement of NDCs and long-term strategies (LT-LEDs).

▶ https://www.nature.com/articles/s43247-023-01014-x