The European Parliament Environment Committee’s rapporteur has preserved most of the defects in her draft report reacting to the European Commission’s proposed Carbon Removal Certification Framework.

The draft report, composed by MEP Lídia Pereira of the European People’s Party,  contains many small improvements compared with the European Commission’s original proposal for a Carbon Removal Certification Framework (CRCF), but fails to correct fundamental flaws that could cause significant environmental damage, delay climate action, undermine the EU’s climate goals and provide a cover for greenwashing.

“While the draft report contains quite a few ‘nice-to-have’ improvements, it doesn’t fundamentally change the deeply flawed CRCF proposal. Climate action still risks being slowed down by low-quality removals and short-term sequestration,” says Wijnand Stoefs, CMW’s lead expert on carbon removals. “The CRCF needs a clearer vision in which permanent removals complement rather than offset emissions reductions. That vision is still absent.” 

Offsetting responsibility

Like the Commission’s original proposal, the rapporteur’s draft report views the utilisation of certified removals to offset emissions as a valid potential use, which flagrantly contradicts the scientific consensus that removals need to complement rather than substitute rapid and immediate emissions reductions. 

To make matters worse, the draft report, like the Commission’s proposal before it, does not concern itself with determining what the legitimate uses of carbon removals should be, simply leaving it to other legislative files to deal with this vital issue. This legislative cop out will lead to continuous struggles to keep removals and emissions separate. This omission means that the CRCF, which should be used to ensure that carbon removals are not used to compensate for emissions, could end up providing a fig leaf for offsetting, including in the Emissions Trading System (ETS) and the Effort Sharing Regulation (ESR).

When a removal is not a removal

While Pereira’s draft report improves the definition of carbon removals by deleting references to emission reductions, it is still too loose and allows for the certification of temporary storage (for example in soils, vegetation and products) as removals. 

“Carbon removals must last several centuries at the very least for them to play a meaningful role in tackling the climate crisis,” says Fabiola De Simone, CMW’s expert on carbon removals. “The European Commission and the ENVI draft report both place too much emphasis on short term storage, while the whole framework should focus solely on permanent removals.” 

In addition, the draft report would have removal units include metadata that shows their expected storage timeline; this is nowhere near enough to differentiate between short-term parking and long-term storage of carbon: they would still lead to the same unit being created, and whoever holds and uses those units can choose to completely ignore the metadata. 

Quick accounting fixes

Although short-term storage of carbon should be excluded from the CRCF, if policymakers insist on including it there should be clear differentiation between and different units for temporary and permanent storage. Moreover, only removal activities that lead to multi-century storage should be given the label carbon removal and lead to the generation of carbon removal units.

In combination, these two failures could prove disastrous. If they are not addressed, companies will be able to use carbon storage that lasts as little as a few years to offset emissions that affect the climate for a millennium. As it stands, the CRCF regulation could, for example, enable coal power plants and airlines using highly reversible (and likely cheap) soil carbon or mono-culture plantations to supposedly offset their emissions which would leave them off the hook for the damage they cause to the climate.

With respect to the sustainability of activities, the draft report also fails to correct major mistakes. Activities that are based on land-use and/or biomass must have positive environmental impacts rather than the current low bar of demanding that they at least be neutral. The sustainability requirements should also include impacts outside the European Union (for example indirect land use change or deforestation due to increased demand for biomass in the EU) and especially social impacts. MEP Pereira has rightfully included impacts on food security, but the CRCF needs to go further and ensure that land grabbing and/or speculation are not incentivised.

Minor improvements

The draft report does contain numerous improvements compared with the European Commission proposal. 

For instance, the carbon storage in products category has been cleaned up somewhat to clearly exclude very short-term storage (in chemicals, paper products, biofuels, etc). It also puts more emphasis on monitoring and liability for short-term storage but this does not go far enough: only storage that lasts several centuries should be included, whether in products or geologic formations.

Geologic storage outside the EU is raised as a viable storage medium, which it should be, provided that the key human rights, monitoring and liability requirements are also enforced. This might not be a major issue for countries which respect much of the European acquis (such as Norway) but could become more complex if CO2 starts being transported well beyond Europe in the future.

The draft report proposes the establishment of an EU registry of certificates and units, with more information to be made public. This will improve the transparency of the system significantly and allow for public oversight and research. It could also enable civil society to identify which removals are being used for greenwashing or to slow down emission reduction efforts.

Although the document fails to define what constitutes long-term storage, it does strengthen the weak obligation for operators to “aim” for long-term storage by stating they would need to demonstrate that they will “ensure” permanent or long-term storage. 

The quantification of removals would also respect the principle of conservative accounting, limiting somewhat the risk of overestimation of removals.

Finally, removal units no longer run the risk of being double counted under a new article on general principles on the use of removal units. However, this does not resolve all double claiming issues. If land-based sequestration is allowed for offsetting, units would be sold on the voluntary carbon market. But those same units would also be used by countries to reach their LULUCF targets.