Expert feedback on CRCF methodologies – Part II

In December 2024, the EU launched its certification framework for permanent carbon removals, carbon farming and carbon storage in products, commonly known as the Carbon Removals and Carbon Farming (CRCF) certification Framework.

As its name suggests, the CRCF aims to certify a variety of practices or processes, namely permanent carbon removals, carbon farming, and carbon storage in products. Each practice involves specific activities for which tailored methodologies are currently being developed. The methodologies will be published as Delegated Acts, taking on the force of law. 

Overall, the activities involve:

  1. Permanent removals: direct air capture and storage (DACCS), biomass with carbon capture and storage (BioCCS) and biochar. Biochar is currently classified as a permanent removal activity – yet uncertainty persists on its storage length. Therefore, a key aspect of the methodology is determining how much of a given biochar batch will be stored for at least several centuries. 
  2. Carbon farming (emissions reductions and carbon sequestration): peatland rewetting and restoration, agriculture and agroforestry on mineral soils, and planting of trees.
  3. Carbon storage in products, mainly wooden construction elements.

Note that the list of activities is likely to expand. 

As established in Articles 4 to 7 of the CRCF, the methodologies will follow the so-called QU.A.L.ITY criteria. These are the quantification of climate impact (against a baseline), the additionality of the activity, its long-term storage and liability for early release into the atmosphere, and sustainability. The methodologies should set out robust conditions, tests and safeguards that eligible activities need to comply with to be certified under the scheme. However, as a voluntary framework, the decision on whether to participate in the scheme or not rests with the operators and certification schemes. 

While the European Commission and its consultants are developing the methodologies, these are also being discussed within the EU Carbon Removals Expert Group (CREG,) of which CMW is a member. Note that, in addition to CREG meetings, numerous online workshops, discussing particular sections of (at times specific) methodologies, e.g. quantification in forestry, are held throughout the year.

Unfortunately, the CREG is largely dominated by industry lobbyists, which skews the balance during discussions and diminishes vital voices from independent experts, researchers, and civil society. As an active member of the CREG and the CRCF process in general, CMW has sought to rectify this imbalance by hiring its own consultants to thoroughly review the methodologies and flag pertinent issues. 

This document sets out the expert feedback received for the various CRCF draft methodologies (published in April 2025) by Öko-Institut, Greenhouse Gas Management Institute, and Carbon Plan. Carbon Market Watch submitted its written feedback to the European Commission through the CRCF EU survey. By sharing this information, we hope to contribute to the debate and shed further light on the numerous issues affecting the methodologies.

Peatlands

Planting of trees

Agriculture and agroforestry

Biochar

DACCS/BECCS

Related publications

Expert feedback on CRCF methodologies

In December 2024, the EU launched its certification framework for permanent carbon removals, carbon farming and carbon storage in products, commonly known as the Carbon

Manuel des émissions négatives

Ce manuel aborde une liste de concepts associés à la CDR et explore six NETP différentes : le biochar, la biomasse avec captage et stockage

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