Compensate recommendations on the development of the EU Carbon Removal Certificate

Tuesday, May 10, 2022

Compensate welcomes the ongoing work on the EU proposal for the legislation of the certification of carbon removals. While demand for carbon removals is booming, current standards are not enough to guarantee the quality of projects, resulting in the situation where one carbon credit is not equal to 1 tonne of carbon dioxide removed. 

The establishment of a robust and credible certification system for carbon removals will increase the transparency and level playing field of the voluntary carbon markets while providing better financial incentives for rewarding climate action and sustainable use of land and natural resources.


For a certified carbon removal project to serve its purpose as a climate change mitigation tool, it has to achieve additional climate impact in comparison to the situation without the project being implemented. Thus, only new activities beyond the business as usual baseline should be rewarded with carbon credits under the new EU carbon removal certificate. Projects in which carbon dioxide removal is a byproduct and not the main activity, for example, commercial forestry or long-lived storage products for which there is already a market demand should not be rewarded with additional revenue from carbon credits. The EU certification framework should allow for a variety of baselines and additionality criteria to cater for different types of removals.


The EU carbon removal certificate should support smart utilization of the natural resources because it is not just the climate crisis we are faced with, there is a biodiversity crisis and food security crisis too. The increased interest towards carbon removal has resulted in the notion that every activity removing carbon should be rewarded with carbon credits. Projects burying bio oil, biochar, or wood underground, just for the sake of claiming “additional” carbon removals, are wasting the potential of these valuable products to fight climate change in more ways than just removing carbon. Similarly, diverting land from food production to grow energy crops for biochar or bioenergy with carbon capture and storage (BECCS), as an example, is not sustainable.

Nature-based removals

With the urgency of the climate crisis, we need “all hands on deck” when it comes to nature-based solutions, as they have the potential to be deployed at a large scale and most have technical readiness. The EU certificate should focus on developing comprehensive standard requirements for carbon removals, including robust monitoring, reporting, and verification processes. In addition, developing a framework to incentivize parties to maintain the carbon removal practices in the long term is of vital importance to ensure high permanence. Degraded peatlands and agricultural fields can be transformed from a CO₂ source to a sink and have a huge scaling potential. The EU certification framework should allow different types or sub-categories of certificates to better reflect the diversity of carbon removal solutions and their characteristics, such as permanence.

Technological removals

Technological removals, on the other hand, provide high permanence assurance but are lacking technical readiness and economic feasibility, and their scaling potential in the short term is limited. Most direct air capture (DAC) companies are still operating small pilot facilities and focusing on expanding operations to capture several thousands of tonnes of CO₂ per year. Methodologies need to address the emissions associated with the full life-cycle assessment of the technological removals, as in some cases they have proven to emit more CO than they can capture . Direct air capture and enhanced weathering are currently associated with high emissions, hence efficiency and processes must be further developed before this can be scaled in a sustainable way.

Biochar, on the other hand, is more mature and is being rapidly scaled up, but to avoid doing more harm than good it has to be produced in a sustainable way, both in terms of feedstock and process sustainability. Converting a traditional source of energy to turn it into biochar could lead to indirect land use change because additional/alternative energy sources must be found when biochar production does not create enough usable energy itself. In addition, if not captured, high methane emissions during pyrolysis can offset any carbon removal at least in the first decades after the pyrolysis.

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