March 07, 2023

Open letter to EU policymakers on carbon removal certification

Carbon Gap and seven other organisations urge for clear and robust regulations to govern the use of carbon removals
Open letter website image

As part of the working group on the Carbon Removal Certification Framework (CRCF), experts on carbon removal are meeting today, 7 March 2023, to advise the European Commission on the proposal’s technical details. In this context, Carbon Gap and seven other organisations are publishing an Open Letter, which highlights the need for clear and robust regulations to govern the use of carbon removals. The European Commission has shown leadership with the CRCF and took the first and significant step toward developing a strong carbon removal capability in Europe that contributes to its climate goals. 

The letter is signed by Bellona Europa, Carbon Gap, Clean Air Task Force, CONCITO, ECOS, EPICO KlimaInnovation, Energy Policy Group, and Transport & Environment (T&E).

The letter highlights two critical shortcomings that the European institutions must address: 

  • Clearly distinguish carbon removal from emissions reductions. Currently, the CRCF includes activities that do not constitute removals as defined by the IPCC and would risk condoning the improper and unfair use of certificates that could undermine public trust in the framework. The CRCF must clearly distinguish carbon removal from emissions reductions. Providing clarity at the outset will avoid confusion later in the process and avoid the risk of divergence from definitions used in other jurisdictions, especially given the potential for the CRCF to set a global standard. 
  • Govern the use of carbon removal certificates. Individual actors can currently buy carbon removal credits and use them in whichever way they wish. This is untenable, and will lead to greenwashing, mitigation deterrence and a loss of public trust. The CRCF should set guardrails for how different types of carbon removal certificates or units may or may not be used. The various methods of removing and storing carbon should be labelled in different ways, according to the origin and fate, especially the character and duration of the carbon storage, including its reversal risk. 


Eliminating ambiguity as to what is and is not a removal, and setting out the ways in which certificates may be consistently used by buyers will allow the new EU framework to achieve its stated intent of advancing the EU climate goals. We look forward to further collaboration with policymakers towards the development of the CRCF and its aims of integrating carbon removals into the EU climate policy framework, ensuring the development of a strong carbon removal capability in Europe, and realising the potential for European leadership in carbon removal certification.