In December 2021, the European Commission (EC) released its plan for EU-wide legislation that aims to certify carbon credits for CO2 removals, also referred to as the Carbon Removal Certification Framework (CRCF). It is intended to integrate carbon removals as a cornerstone of the EU’s climate framework to achieve the EU’s 2050 climate neutrality target. The idea of carbon removals is that CO2 can be proactively taken out of the atmosphere to mitigate climate change. The EC’s approach to removals relies on creating carbon credits traded at first on voluntary carbon markets with the intention to bring them into the European Emissions Trading Scheme by 2030. It would open the floodgates to carbon offsets that polluters and governments could buy, stalling efforts for real emissions reductions. The proposal also includes a concept called “carbon farming” that would problematically enable the certification of carbon credits for sequestering carbon in forests and soils.
In its 6th Assessment Report, the IPCC emphasizes the urgent necessity for deep cuts in greenhouse gas emissions (GHGs). It also states that “CDR [carbon dioxide removal] cannot serve as a substitute for deep emissions reductions.” Rather, CDR can play a role in “counterbalanc[ing] hard-to-abate residual emissions.” This means removals have a limited role in mitigation and that anything short of a laser focus on cutting emissions is likely to lead to an overshoot of global temperatures, making the planet uninhabitable for humanity. While the EC acknowledges the “need to drastically reduce our reliance on carbon,” it fails to set a minimum threshold for emissions reductions before removals should even be considered. The EC also stipulates that carbon farming credits should be deployed to offset GHGs that cannot be reduced “at reasonable socio-economic costs” without clarifying the threshold for what is “reasonable.”
Flawed public consultation
On May 2, the EC closed its public consultation on EU rules for the certification of carbon removals. As part of the process, the Commission solicited responses to a questionnaire that problematically presupposed that the certification of Measurement, Reporting and Verification (MRV) protocols for carbon removals financed by carbon markets is a given. Rather than an open inquiry about the best approach toward carbon removals, the questions limited participants to multiple-choice responses on how best to create tradeable carbon credits. The biased questionnaire will now be used to tally the majority opinion from industry, interested parties and civil society organizations — essentially stifling opposition to carbon markets. The Commission also allowed for written explanations in the survey, but those findings cannot be aggregated and, therefore, tend to be less communicated. IATP submitted its own response to the EC’s consultation. The European Coordination of Via Campesina also issued an open letter to the European Commission, calling out the “disingenuous” nature of the public consultation and outlining the threats posed to farmers by the EC’s carbon market approach to removals. The letter, endorsed by five organizations including IATP, stressed that “the economic cost of the announced certification is enormous, and its impacts seem not only useless but directly detrimental.” Instead, public policy approaches exist that could holistically tackle the interconnected environmental, climate and rural crises in agriculture while taking farmers’ concerns and needs for a just transition into account.
In our submission, IATP stressed that carbon farming offsets block both climate action and a just transition in agriculture.
They prevent and delay emissions reduction. The false notion that atmospheric emissions minus CO2 removals can equate to “net zero” creates a sense that emissions reductions can be replaced by carbon removals. This assumption diverts critical attention and resources from emissions cuts badly needed to avert climate catastrophe.
Land-based sequestration cannot neutralize ongoing and rising emissions. Biogenic and fossil carbon are fundamentally different in terms of timescales. Fossil emissions remain in the atmosphere for millennia. In contrast, land-based sequestration is vulnerable to reversal from human action, natural catastrophes and global warming itself. At best, carbon farming has the potential to restore some of the carbon lost in the past from industrial agricultural practices. It can in no way make up for current and future emissions in the atmosphere.
Measurement of soil organic carbon (SOC) cannot be simple and robust at the same time. SOC measurement is extremely complex and uncertain. The most robust form of estimating SOC requires costly soil sampling. For carbon credits to be economically feasible, they must be affordable to generate. For them to be credible, they require precise measurement. Robust measurement is both expensive and cannot be guaranteed for soil carbon.
Avoided emissions, emissions reductions and emissions intensity reductions are not removals. The EC’s proposal to conflate different terms and concepts undermines the integrity of the whole carbon removals framework.
2. Carbon markets are unfit as a financing mechanism for farmers. They hinder a just transition of the agricultural sector towards agroecology because:
Carbon markets do not provide fair, stable and predictable finance for farmers. Carbon markets are extremelyvolatile and speculative. Their unpredictable payments do not create the reliable income needed for sustained green investments.
Additionality criteria are hard to fulfil. The complexity of farming decisions and fluctuations of soil organic carbon makes it unfeasible to prove that the sequestration is additional to what farmers would already be doing. Additionality is a key criterion for carbon credits.
Liability risks for farmers are large. Farmers would be burdened with a disproportionate risk for the liability of reversals during the project period. Long-term projects of 100 years are both too long in terms of liability for farmers and too short in terms of genuine carbon removal.
A carbon market approach incentivizes large-scale industrial agriculture. Large-scale farms with soils dependent on chemical inputs and industrial practices provide carbon consultants with an opportunity to aggregate and MRV on a large reservoir of soil carbon. Small-scale farmers already sequestering carbon wouldn’t likely benefit from these carbon credits.
Carbon farming credits increase the cost of land and land speculation. Pressure on European land prices is already immense. Carbon credits increase the possibility of investors profiting from and owning land. Foreign or corporate land grabbing could increase even more.
What needs to happen
If the European Commission is serious about climate action, then the task at hand is deep emissions cuts. Farmers must be supported to mitigate and adapt to climate change with public finance. Climate policy on agriculture must support a holistic approach to ecosystem restoration and a just transition to agroecology. The EC’s initiative on removals should not become a distraction from these urgent tasks. The European Commission still has the chance to get this right. Read our detailed critique on carbon farming submitted to the European Commission here.
Download a PDF of IATP's response to the EC's call for evidence for the "certification of carbon removals — EU rules" initative here.