Brussels, 24 October, 2023 – With 59 votes in favor, 17 votes against and 9 abstentions, the European Parliament’s Committee on the Environment, Public Health and Food Safety (‘ENVI’) adopted their report on the Carbon Removal Certification Framework (‘CRC-F’). The ENVI Committee’s intention is to strengthen the European Commission’s proposal, particularly when it comes to countering greenwashing and boosting the uptake of carbon dioxide removal (‘CDR’) to help achieve EU climate neutrality by 2050.
What are the strengths of the ENVI Committee report?
CDR certification represents a necessary and significant step toward integrating carbon removal into EU climate policies, ensuring the development of a strong carbon removal capability in Europe, and achieving the potential for EU leadership in this space. The CRC-F has the potential to become a standard setter at an international level and will shape the CDR industry in Europe. Carbon Gap, therefore, welcomes the ENVI Committee amendments that help ensure that activities certified under the CRC-F are high-quality and genuinely contribute to EU’s climate goals; most notably the ones that:
- Clarify the confusion between carbon removal and emissions reductions by introducing four distinct units for certified activities (carbon removal, carbon farming sequestration, carbon farming emissions reduction and carbon storage in products). This addition ensures much-needed clarity on what carbon removal is and is not, and a delineation between fundamentally different forms of climate benefit.
- Increase transparency and accountability through an EU comprehensive registry requiring the disclosure of essential information, such as the expected duration of carbon storage, the storage method, the physical or legal holder of a certified unit, the purpose for which that certified unit is held etc. This transparency would enable stakeholders to police units from cradle to grave.
- Strengthen liability requirements by requiring that a liable party be present to address possible reversals for all activities certified under the framework. This level of accountability provides essential security.
- Reinforce minimum sustainability standards, now requiring all carbon farming and carbon storage in products activities to demonstrate a positive impact on sustainability criteria.
What are the issues that remain to be addressed?
While the ENVI Committee made numerous enhancements it is important that the EU institutions acknowledge, rectify and address a few remaining shortcomings during the forthcoming trilogue negotiations.
Some of the definitions developed by the ENVI Committee are overly narrow and too specific, potentially impeding the inclusion of established and promising CDR methods under the framework. For instance, limiting “permanent carbon storage” only to geological storage and carbon mineralisation excludes CDR methods that can achieve the required durability of storage and offer credible mechanisms to address potential reversals. A similar constrictive approach appears to apply to the products category.
“All reliable and efficient carbon removal methods should be eligible for inclusion in the CRC-F. Furthermore, since new CDR methods continue to emerge and evolve, it is essential to ensure that the CRC-F definitions remain adaptable to future technological developments. The CRC-F simply needs to establish an open-door policy and a transparent process for new methods to seek consideration, with strong monitoring, reporting, verification and liability standards in place”, said Rodica Avornic, Carbon Gap Associate Policy Director.
The framework must be inclusive and future-proof, providing a pathway for all safe and effective removal methods to be certified. This means crafting definitions for permanent removals, carbon farming and carbon storage in products that are clear, and based on criteria rather than mentioning specific approaches. This would ensure the CRC-F is inclusive and open to the latest technological developments, while strengthening requirements around liability to ensure carbon remains stored.
Furthermore, while the ENVI Committee calls for distinguishing between the uses of the four different types of carbon removal units certified under the CRCF and makes a reference to the rules under the Empowering Consumers Directive, it ultimately leaves room for ambiguity on the end-uses of certificates.
Removal units are currently used by various entities to claim to compensate for emissions, or for other purposes (e.g., results-based finance, contribution claims, demonstration of alignment with a policy or requirement). When carbon removal is used for compensation claims, specific rules must be established in the CRC-F and associated legislation, to ensure that carbon removal certificates are only used to balance emissions that cannot be reduced through other means (i.e., only residual emissions). Moreover, only highly-durable, permanent carbon removal should be used to compensate for fossil emissions, so that the long-term storage of carbon matches the long-term impacts of emissions (i.e., the like-for-like principle).
What are the next steps?
The European Parliament is expected to vote on the ENVI Committee report during its 20 November plenary session. Once adopted, the report will form the Parliament’s position on this file, which will represent its mandate for the forthcoming trialogue negotiations with the Council and the European Commission. The Council’s position (i.e., the general approach) is expected to be adopted in November, with trilogue negotiations possibly starting before the end of the year.