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Accounting for carbon removals in the EU: Highlights from the 4th meeting of the Carbon Removals Expert Group

May 2, 2024 Work Area: Carbon Capture, Land Systems

Europe’s Carbon Removal Certification Framework (CRCF) aims to establish carbon removal regulation for the region – ensuring that removal activities are real, verifiable, and meaningfully contribute to the EU’s climate objectives. If designed and implemented effectively, this pioneering framework could set the global benchmark on carbon removal regulation and is a much-needed step towards proper governance of the fast-emerging negative emissions sector. 

On 15-17 April 2024, the EU Expert Group on Carbon Removals held its fourth meeting as a part of the continuing process of developing the Carbon Removal Certification Framework. The three-day meeting focused on exchanging views and discussing the certification process, best practices for verification and registries, and the prioritisation and development of the upcoming certification methodologies. Once developed, these methodologies will outline technical criteria for specific technologies within each category (i.e. carbon farming, permanent carbon removals, and carbon storage in products) for certification under the CRCF framework. 

As a member of the European Commission’s Expert Group on Carbon Removals, CATF assists and oversees the work of the Expert Group and provides inputs to the future delegated acts that will operationalise the certification methodologies. CATF experts, Codie Rossi, Senior Policy Associate, and Rebecca Sanders-DeMott, Land Systems Research Fellow, were in attendance during the group’s fourth meeting to learn more about the process and offer CATF’s policy and technical expertise.  

Key Takeaways

Accounting and certification are key. The CRCF marks the most ambitious effort yet by a public body to account for a wide variety of carbon removal approaches, aiming to address the currently fragmented and disparate standards and certification that exist in the Voluntary Carbon Market (VCM). As has been recognised in the EU’s 2040 target and Industrial Carbon Management Strategy, removals from both permanent means, such as Direct Air Capture and Storage (DACS), and Bioenergy and Carbon Capture and Storage (BECCS), as well as increasing the removal potential of the land sink will be required to deliver some 300 million tonnes of carbon removals by 2040 in the EU. Correctly accounting for and certifying these carbon removals will be crucial to ensure that they contribute to the EU’s climate goals of climate neutrality and net-negativity thereafter.  

Lacking clarity on intended uses for distinct types of units. Greater focus on use cases of different units is needed as this framework is developed. This dimension is pivotal for establishing the credibility of the entire CRCF framework and some important open questions will be difficult to answer without more clarity. In order to put in place appropriate methodological guidelines, especially for carbon farming activities, around monitoring periods, liability structures, the scales of baseline setting, and numerous other elements, decisions are needed about the intended application of carbon credits, which has been left unresolved in the text of the CRCF and is claimed to be outside the remit of the Expert Group. This issue continued to come up throughout the proceedings however, and it demonstrates how providing use case distinctions is imperative for the framework’s effectiveness and acceptance within broader applications beyond the voluntary carbon market. 

Resolving fundamental accounting questions about carbon farming activities. Separating carbon farming reductions from carbon farming removals helped to ease some concerns about integrating activities like peatland rewetting into the CRCF but raises additional questions about how to delineate between reductions and removals appropriately and consistently. For example, improved forest management activities can lead to both avoided carbon emissions from business-as-usual forestry activities and, in some cases, lead to increased removals. Usually, forest management activities do both. Distinguishing between emissions reductions and carbon removals is inherently complicated for carbon farming activities as ecosystems like forests, peatlands, and agricultural systems both emit and take up carbon at the same time. Now that the structure is in place to credit these kinds of climate benefits separately, there must be careful consideration of how to do so within a given activity.  

Open questions on technical aspects of methodologies. The Technical Assessment papers synthesising the findings of the focus groups on agriculture on mineral soils, forestry, peatlands, permanent carbon removals, and carbon storage in buildings were presented with clarity to members of the Expert Group. These papers reflect a tremendous amount of thoughtful engagement with expert stakeholders representing diverse perspectives. We commend the approach and the meaningful attention to detail demonstrated by this body of work. However, many key questions remain open as there was lack of consensus around many technical aspects of methodologies, reflecting the wide variety of approaches in, and the dynamic nature of existing global carbon markets. Resolving important details and being clear and open as to how certain approaches will be chosen, such as the length of monitoring period, baseline setting, defining eligible activities, and identifying appropriate data sources, will be foundational to moving forward with developing robust methodologies. As the CRCF is likely to set a global standard, getting these elements right will be crucial for building trust in carbon removals across categories. 

Structure and inclusivity of the meetings and the process. In contrast to previous expert groups, this meeting offered ample time for attendees to raise questions. Given the enormity of the task at hand, we hope that the additional upcoming meetings dig deeper into the technical details of methodologies and allow for even more active discussion. We also hope that the Commission will consider providing more realistic deadlines for stakeholders to offer feedback, allowing sufficient time to thoroughly review the technical papers and provide meaningful input. 

Many questions remain. The challenge that lies ahead is enormous with numerous open questions related both to the highest levels of how the initiative will be operationalised to key technical details, such as the duration of the monitoring period for removals and the appointment and training of certification bodies, which are all critical underpinnings to a robust certification program. 

What’s next?  

Members of the expert group have the chance to submit feedback from the Technical Assessment papers shared by the Commission by 10 May, 2024. This feedback will be considered in the next step of the development of the certification methodologies. The Commission will prioritise the selection of approaches which are most mature, have significant co-benefits, and where the EU has existing legislation (i.e. DACCS, BECCS, rewetting peatlands, etc.). The intention is to discuss the first draft methodologies on these carbon removal activities at the next Expert Group meeting in October 2024. On top of this, the first delegated acts on certification methodologies and implementing acts on the verification and registry rules are expected in 2025. 

In the best-case scenario, the certification will be up and running at the end of 2026, but realistically speaking, the Commission mentioned that 2027 will be most likely.  

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