Standards, stacking, and why carbon removal action is happening at every level at once.
Last month, Carbon Gap brought policymakers, developers, advocates, buyers, and researchers together in Brussels for its first ever Carbon Removal Policy Summit. Sessions on the day looked at carbon removal policy from four vantage points: the international, EU, national, and local levels.
Rather than summarise each session to conclude the day, we explored two themes that ran across these various governance levels.
Theme one: one tonne, many rulebooks
A recurring question kept popping up during the Summit: Should we use the same standards for carbon removals at every level, from the international stage down to a single city or company?
By ‘standard’ here, we are referring to the rulebook used to measure, check and certify that a tonne of CO₂ really has been removed. It covers how the removal is calculated, how long the carbon must stay stored, and who checks the numbers.
So, should one standard rule them all? Asked like that, most people would say yes. But the better question is: what is each tonne for, and what standard does that purpose need? A tonne bought by a company, one counted towards a national target and one traded between countries carry different weight and need different levels of assurance. Policymakers need to match the quality of a removal, including how long it lasts and how confidently it can be measured, to the job it is asked to do. They must also make sure that match holds over time rather than quietly drifting.
In practice, different rulebooks are already doing different jobs:
The EU's Carbon Removals and Carbon Farming Certification Framework (CRCF). The CRCF, EU's voluntary certification system, adopted its first methodologies in February 2026. It did so for direct air capture with storage (DACCS), capture and storage of biogenic CO₂ from sources such as biomass plants (BioCCS) and biochar. Today, it is mostly seen as a tool for the voluntary market, but the market is gearing up for its future application in the EU Emissions Trading System (ETS).
National targets. Member States are expected to start using CRCF-certified removals towards their own climate targets.
International credits. The EU's 2040 climate target of a 90% cut in net emissions allows international credits under Article 6 of the Paris Agreement to cover up to 5% of 1990 level emissions, with a pilot phase from 2031 to 2035 and use by Member States from 2036.
This leads to a practical policy question. How do we nest activities in order to ensure that a removal certified at project level, for example under a CRCF-approved scheme, lines up with the national greenhouse gas inventory (the official record each country keeps of its emissions and removals)? If we are not able to reliably make that link, the practical use of CRCF credits towards national targets remains wishful thinking. We struggle to do this cleanly at this point in time. Working out how is essential plumbing for the whole system.
Then, there is the international link. The EU has ten years before international credits count towards its 2040 target and must make the most of this time to prepare a well thought out standard (e.g. what kind of credits to allow in). Reaching anything close to the 5% codified in the Climate Law may be more hope than forecast.
Theme two: stacking the business model
The second theme was about how each governance level is contributing to a working business model for CDR. Few carbon removal projects are funded by a single source. Those moving forward in Europe tend to stack several funding streams on top of one another:
EU funding, such as the Innovation Fund, which is funded by selling ETS allowances. The Commission's July 2026 ETS review proposal would add a public purchasing programme for permanent removals such as DACCS and BioCCS.
National subsidies, such as Sweden's reverse auction for BioCCS or Denmark's support for carbon capture and storage, which we hope will spread to more countries.
Local action, with some cities investing directly in CDR projects.
Voluntary buyers, often large companies buying through the voluntary carbon market.
Stockholm Exergi's BioCCS project represents a good example here. It combines a €180 million Innovation Fund grant, Swedish state support won at auction, and long-term purchase agreements with Microsoft and the Frontier buyers' coalition. Remove any one piece and the project would likely never have reached a final investment decision.
The problem is that stacking gets more complicated as the policy "treadmill" churns out new instruments. Every so often, a funding stream comes with a rule saying that ‘if you take this money, you cannot take that money.’ Some exist for good reasons, such as stopping public money paying twice for the same tonne. Taken together, they can sometimes make projects unbankable.
Policymakers need to keep the larger picture in view: which funding streams may be combined and for what purposes? Answering this clearly and consistently will matter more as new options come on the scene: the EU CRCF Buyers' Coalition, which aims to pool private demand, the ETS purchasing programme, and more countries acting at home.
Carrying forward sector momentum
The most encouraging takeaway from the day: there is a lot of action, and it is happening everywhere. Some claim real progress happens only at their level, whether it be Brussels, a national capital, or a city hall. In practice, all four levels are moving, and each helps create demand for carbon removal.
The challenge now is to make those levels work together: agreeing what each tonne is for, accounting for it accurately, and letting good projects combine the support they need. Tools like Carbon Gap’s new Policy Levers Library, which guides governments, companies, and institutions through 160+ instruments that can be used at all governance levels, can help policymakers and those across the CDR space narrow what policy considerations are right for them. Only through the right combination of these levers can stakeholders build better conditions for CDR to scale.