MINIMUM CARBON-STORING CONTENT REQUIREMENTS

Governments can require manufacturers and importers to sell covered products only if they contain a minimum amount of carbon removed from the atmosphere and keep it stored for a specified period. The minimum could apply to each product or to all covered products a factory makes in a year. This creates direct demand for carbon-removal suppliers whose carbon becomes part of concrete or other durable materials. Unlike a carbon-intensity standard, it regulates what the product contains, not its total lifecycle emissions. Unlike a CDR purchase mandate, buying removal credits is not enough: the removed carbon must enter the product.

Covered products should be durable goods retaining atmospheric carbon. Candidates include aggregates and concrete made with removed CO₂, masonry and construction products containing biochar. Timber, bio-based insulation and durable polymers qualify only if they extend storage beyond what would otherwise happen. Fuels and short-lived products are unsuitable. Governments should choose whether to measure how much carbon-storing material a product contains or how much atmospheric carbon it stores. Factories can average carbon-storing and ordinary materials across output, but cannot claim more carbon-storing material than they used. Certificates alone should not count. Rules must cover production emissions, disposal, imports, enforcement and early release.

By making carbon-storing materials a condition of sale, the requirement can give removal suppliers a dependable market beyond voluntary credit purchases. That demand may justify new production, help manufacturers use the materials safely and reduce costs through larger production runs. A common minimum can also prevent early adopters being undercut by competitors using conventional materials. These are expected effects, not demonstrated CDR outcomes: recycled-content laws show that content requirements change sourcing, but not that a CDR version would deliver removals or lower prices.

Loose eligibility rules could let manufacturers count fossil CO₂ captured from industry. That may cut emissions but not remove atmospheric carbon, turning the requirement into a carbon-use subsidy. Removals would also be overstated if the product stored the carbon anyway, released it at disposal, or sold it separately as a credit. Limited supplies and costly testing could raise product prices and burden smaller firms. Percentage targets could encourage material use instead of repair, reuse or recycling.

Regulators should match claims to purchase records, output and lifecycle calculations to confirm that carbon came from the air and more was stored than emitted in production. Compliance, supply, prices, rejected imports and disposal releases show whether the requirement works. Shortages or price spikes may slow increases. Fraud, double claiming or early release should trigger tighter eligibility, audits or penalties.

Regulators, manufacturers and CDR suppliers should map products that can safely and durably retain atmospheric carbon, their scale and cost, and when supply can expand. Standards bodies and lifecycle experts should turn findings into measurement methods. Importers should test foreign-product evidence. Civil society and affected sectors should identify weak safeguards, burdens, misleading claims and conflicts with repair, reuse and recycling.

Supranational, national and regional or state governments can set binding product standards and stop non-compliant goods from being sold. Supranational rules suit shared markets, where one standard can cover domestic and imported products. National or regional governments can act where product, building-material or waste law sits at those levels. Product regulators would check manufacturers, while customs authorities would apply the same evidence requirements to imports. Cities can support the same objective through procurement or building codes, but those tools regulate local projects rather than whether manufacturers and importers may sell a product.