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European Union (EU) is on its way to pass a first-of-its kind carbon removal legislation. In November, the EU institutions (the European Commission, the European Parliament and the European Council) issued their positions on the Carbon Removal Certification Framework (CRCF) and are looking to finalize negotiations (known as trilogues) at the end of February 2024. The current proposals set the EU on a dangerous path to undermine EU climate action, building on the “net-zero” framework as a smokescreen to hide the lack of real emissions reductions. Considering the urgent call for a fossil fuel phase out at COP28 and scientists’ warning we are on a dangerous trajectory to reach non-reversible climate tipping points, a pathway to “Real Zero” — a positive, transformative vision and action plan — is needed in Europe and globally. Yet, the CRCF seems likely to allow polluters to continue business-as-usual by paving the way for EU-approved carbon emission offsets and a cornucopia of false solutions.

IATP is part of the Real Zero Europe (RZE) campaign. In a series of new campaign briefs, RZE explains why the CRCF undermines climate action on real emission reductions in Europe.

Campaign brief titles

The CRCF creates a certification scheme mainly to pay different actors to take carbon out of the atmosphere and store it (so-called carbon removal). Farmer and foresters will likely be able to get paid for sequestering carbon in soils and trees (or reducing their emissions, for example from fertiliser or livestock operations.) Polluters and governments could purchase those certificates to offset their pollution, thus enabling a net-zero smokescreen, hiding actual emissions.

Three chances missed to prevent offsetting

In the European Union’s legislative process, the European Commission, the European Parliament and the European Council first agree on their individual positions before entering the joint negotiation process, the trilogue. Yet, none of the three used their individual opportunities to keep the EU on track for ambitious climate action.  

The European Commission’s proposal for a CRCF, published in November 2022, has been criticized heavily as “a sure way to torch the planet” by a wide array of networks, movements and organisations in the EU and beyond, coming together as the RZE campaign. The campaign’s statement, published just before the publication of the Commission’s proposal, argued that the European Commission’s plan to allow the use of the certificates as climate pollution offsets “relies on a dangerous and false justification for continuing emissions: that someone, somewhere, might at some time in the future remove a ton of carbon from the atmosphere.” In an in-depth analysis of the Commission’s proposal, IATP identified 12 major concerns with the draft legislation.

The Council’s position, similar to the Commission’s, does not address how certificates originating from the CRCF could be used. By refusing to address this central question, it also leaves the door wide open for offsetting in the voluntary carbon markets, as well as for future integration into compliance markets, such as the EU Emissions Trading System.

While setting some boundaries on offsetting, the European Parliament failed to operationalize its own affirmation that carbon removals should be “a complement to the irreversible and gradual reduction of anthropogenic greenhouse gas emissions across all sectors.” The only restriction of the use of the certificates as offsets is the proposed link of the CRCF to an updated consumer protection legislation, the Directive to Empower Consumers for the Green Transition. The revision of that legislation in September resulted in a ban of “claims based on emissions offsetting schemes that a product has neutral, reduced or positive impact on the environment;” however, the ban could only be limited to offsets originating from “unverified offsetting programmes.” In addition, the yet-to-be-decided Green Claims Directive could declare that CRCF methodologies are “verified” and thus could be used to substantiate offsetting claims. 

Addressing how the certificates of the CRCF can and cannot be used and what limited role carbon removals can play in overall climate policy must be a central pillar of any framework that deals with carbon removals. It should be a critical point of discussion in the negotiations moving forward.

Certifying false “carbon farming” solutions

The CRCF not only risks undermining real climate action by allowing offsets, but also by certifying a wide array of false solutions, including agriculture techno-fixes under the name “carbon farming.” What started as a framework to address carbon removals (and emission reductions from rewetting peatlands) could end up as a framework generating carbon certificates from any activity that promises to reduce emissions or sequester carbon for an undetermined period of time in the agriculture sector.

Both the European Parliament and the Council extended the framework to include any soil emissions reductions, including reducing nitrous oxide emissions from fertiliser use. The European Parliament also included a possible certificate for reducing methane emissions from livestock. Allowing such certification could steer food value chain actors towards applying corporate driven technological fixes to agriculture emissions, such as feed additives, nitrogen inhibitors or biogas digesters, rather than needed systemic changes toward agroecology, which focuses on farmer empowerment, requires fewer outside inputs and can integrate animals within planetary boundaries.

It will largely depend on the development of the emission calculation methodologies to determine which activities will be certified and how emission reductions will be measured. It would be fatal if the CRCF allows the generation of carbon credit based on emission reductions per cow or per kilogram of produce. This is a metric often used by agribusiness to hide their absolute climate impact. While the so-called “emissions intensity” is being reduced, a company can keep increasing production and absolute emissions — and still receive carbon credits.

Emissions Intensity


Tackling the biodiversity and climate crises jointly

Biodiversity and ecosystem restoration should be at the heart of the farming activities supported by the EU to ensure a stable and resilient land sink. Restoring soil health must be at the centre of the funded activities in the agriculture sector. It is critical to ensure food security in the future. As such, it is a significant improvement that the European Parliament required biodiversity benefits for any carbon farming activity. Both the European Commission and the Council abstained from making this requirement obligatory and left biodiversity to be a voluntary co-benefit. However, without such a requirement, the CRCF is open to certify a wide range of techno-fixes that do little to support biodiversity and the transformation of the agriculture system.

The obligatory biodiversity benefits should be applicable for all land-based activities, including biochar and so-called bioenergy carbon capture and storage (BECCS). Without this requirement, the CRCF primes the EU for large-scale biomass burning and monoculture afforestation that will have tremendous adverse effects on biodiversity and the land sink.

Setting the scene for 2040 and beyond

The CRCF is a first and critical step towards integrating the concept of carbon removals into EU climate policy and paving the way for climate action in the agriculture sector. The result of the CRCF will have rippling effects on the integrity and significance of the EU’s 2040 climate targets and the subsequent review of the EU climate architecture, including discussions about a system to price agricultural emissions. How agriculture features in the CRCF will also impact how the next iteration of the Common Agricultural Policy will address climate action. EU institutions should not make premature decisions to set up carbon trading mechanisms in the search for finance, accepting the harmful consequences. In the face of the ever-escalating impacts of the climate crisis, the focus must be on real action, “real reductions in carbon emissions and real solutions to the climate crisis, instead of corporate greenwashed 'net zero.'”

Read the complete series of the Real Zero Europe campaign briefings on the CRCF here:

  1. Direct Air Carbon Capture and Storage & Bioenergy with Carbon Capture and Storage: The proposed EU Carbon Removal Certification Framework promotes risky, unproven technofixes
  2. Carbon Farming: A dangerous gamble the proposed EU Carbon Removal Certification Framework
  3. Carbon Offsetting: EU Carbon Removal Certification Framework proposal lends legitimacy to a discredited carbon offsetting approach



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