The European Commission has just released a long-anticipated proposal for the Carbon Removals Certification (CRC) framework, offering a potentially game-changing opportunity to remove carbon emissions from the atmosphere.

Europe’s land sink is shrinking and projected to decrease significantly by 2030, due to ageing forests, intensive wood harvesting, and degradation of peatlands and agricultural soils. A recently adopted EU target foresees an increase in its land sink by 20% by 2030 (to -310Mt CO2e). Biodiversity too is in a dire state across Europe. The EU’s newly proposed Nature Restoration Law aims to restore at least 20% of the EU land and sea area by 2030, including many carbon-rich habitats.

It is clear that the biodiversity and climate crises are deeply connected and there is a growing recognition amongst experts that real solutions must address both simultaneously.

Regrettably, this proposal falls woefully short of what is needed. The EEB is particularly concerned about the following:

1. The proposal is immature and simplistic. Many questions remain unanswered, particularly on the issue of liability in the instance that a carbon storage is re-released back into the atmosphere, as well as on monitoring and reporting requirements.
2. It does not position or integrate the CRC within the EU’s wider green agenda. In order to be effective, the CRC must align with and support national and European targets of relevant Green Deal components, e.g. the Nature Restoration Law, the Biodiversity and Forestry Strategies and the Land Use, Land Use Change and Forestry (LULUCF) Regulation.
3. The proposal implies that the certificates are aimed at supporting the sale of carbon credits as offsets on voluntary carbon markets. Offsetting is likely to disincentivise actual emissions reductions and invite greenwashing, while voluntary carbon markets will not benefit most land managers due to high uncertainty, low prices, and long-term liability for reversals.
4. The definition of carbon farming specifies that emissions reductions can also be certified as removals. This is deceiving, and only actual physical removals should be certified as such.

Jurij Krajcic, Policy Officer for Land and Climate at the EEB, comments:

“The proposal completely ignores the social dimension, containing no provisions on protections against unjust practices such as land-grabbing, nor ensuring support for all farmers. That should be an integral part of the just transition.”

Célia Nyssens, Senior Policy Officer for Agriculture and Food Systems at the EEB, notes:

“The Commission has just published a framework to certify greenwashing. We do need to boost carbon removals in the land sector, but relying on big polluters to pay for it through carbon markets undermines this initiative from day one. This is highly disappointing and could have disastrous consequences for our climate, nature, and rural communities.”

ENDS