IATP Europe submitted the following feedback on February 19, 2026, to the European Commission regarding the Commission's proposed methodologies for certifying carbon removals and soil emission reductions for the implementation of the Carbon Removal and Carbon Farming Regulation (CRCF), generating agricultural carbon credits.
The Institute for Agriculture and Trade Policy (IATP) Europe appreciates the opportunity to provide feedback on the European Commission’s delegated Regulation setting out methodologies for certifying carbon removals and soil emission reductions from carbon farming, as determined by the Union certification framework for permanent carbon removals, carbon farming and carbon storage in products (CRCF, Regulation (EU) 2024/3012).
We have long expressed our concerns that a crediting system will not deliver genuine and lasting reductions in greenhouse gas (GHG) emissions. Several methodological choices made in the proposal reinforce our concerns, including:
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Lack of defined use cases: In the absence of a clear definition of the use case for the carbon farming units, it is likely that the generated units will be used as land-based offsets for GHG emissions elsewhere, including from fossil origin. At best, an offsetting system will result in a zero-sum game, not the overall GHG emission reductions needed to address the climate crisis. However, due to the temporary nature of land-based carbon sequestration and the inability of buffer pools to adequately address the risk, the best case is an unlikely outcome.
Incentivizing practices that improve soil health and resilience is critical to enable the EU’s agrifood systems to adapt to a changing climate; however, this must not come at the expense of GHG emission reductions elsewhere. As the Green Claims Directive has stalled, this Regulation needs to specify how credits can be used for voluntary claims as well as their future applicability in compliance frameworks.
- Risk of lowering additionality criteria: The derogations to the additionality criteria in the proposed methodologies highlight the difficulty of ensuring additionality in the agriculture sector. Yet without robust additionality criteria, the integrity of the system and its ability to deliver genuine climate benefits is undermined. This example illustrates how a crediting framework is an inappropriate policy tool for the farming sector. Reforming the CAP to deliver more targeted support for undertaking and maintaining sustainable agricultural practices would likely yield more climate and nature benefits with less bureaucracy. In addition, the Commission, as well as stakeholders, appear to be considering lowering additionality criteria further, either in the carbon farming methodology or at the next review of the Regulation. Doing so would undermine any integrity of the resulting carbon credits.
- Lack of clarity about incentives for extending the activity period: Maintaining the resilience of agro-ecosystems requires that beneficial practices are continued over long periods of time. While the renewal of the activity period is permitted for soil-related activities, agroforestry and the rewetting of peatlands, there is no guidance on why project holders would choose renewal, including what type of financial incentives would be envisioned.
- Lack of ambitious sustainability criteria: The minimum sustainability criteria set out in the draft methodologies are unclear and lack ambition. Instead, it could require more ambitious criteria, for example a reduction or phasing out of pesticide use that would reflect a more holistic transition towards a resilient and less input-dependent agroecological system.
- Lack of social safeguards: Under Article 8(3)(c) of the Regulation, methodologies should not result in land speculation. Yet the presented methodologies do not address how such speculation will be avoided and thus do not fulfill this aspect of the Regulation.
The framework focuses on the results of individual practices on parts of the farm, instead of a whole-farm assessment. A benchmarking system that takes into account multiple indicators, beyond those solely focused on carbon, and addresses the impact of the entire farm system would be much more likely to yield genuine and robust outcomes for the climate and nature.
It is critical to reform the farm subsidy program to incentivize and support sustainable farm practices — including their continuation, as this would remove the added layer of complexity needed as soon as a crediting system is introduced.
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