New Carbon Removal Certification Framework in Europe
On November 27, 2024, the European Union ("EU") adopted Regulation (EU) 2024/3012 establishing a Union certification framework for permanent carbon removals, carbon farming, and carbon storage in products (the "Carbon Removal Certification Framework Regulation"). This voluntary framework aims to enhance the credibility and transparency of carbon removal activities within the EU to support its climate neutrality by 2050 objectives, in line with the EU's commitments under the Paris Agreement. It will supplement existing schemes under Regulation (EU) 2018/841 of May 30, 2018, on the inclusion of greenhouse gas emissions and removals from land use, land use change, and forestry.
The Carbon Removal Certification Framework Regulation targets three primary activities:
- Permanent carbon removals that sequester CO₂ for several centuries, such as geological storage or incorporation into durable products;
- Carbon farming through terrestrial or coastal management that increases carbon sequestration in soil, including soil emission reduction activities; and
- Carbon storage in products where CO₂ is trapped for at least 35 years.
The regulation's primary objectives are to facilitate and encourage high-quality carbon removal and soil emission reduction activities, ensure environmental integrity and transparency in carbon removal processes, and avoid greenwashing by providing a credible certification system.
The certification is voluntary and will not be a requisite for the operation of carbon removal, carbon farming, and carbon storage in product activities. Certification will be granted if the activities comply with quality criteria provided under the Regulation and in upcoming delegated acts which will define certification methodologies. Compliance will have to be verified by an independent third party.
Quality criteria require, in particular, an accurate measurement of the amount of CO₂ removed and calculation of the period during which the CO₂ will be stored to ensure that the above-mentioned long-term requirements are met. The carbon removal, farming or storage activities must also respect biodiversity and zero-pollution objectives, and in general "do no significant harm to the environment" as well as contribute to at least one sustainability objective defined by the Carbon Removal Certification Framework Regulation.
Finally, certification requires "additionality" of the activities, meaning that they should go beyond any statutory requirements applicable to them. The quality criteria will be revised or updated on a regular basis. Only activities taking place in the EU may qualify for certification.
Member States as well private operators will be able to file certification scheme approval by the European Commission. Certification schemes will have to track and control the carbon removal units certified under the framework through interoperable public registries. By the end of 2028, these registries should be replaced by a common, Union-wide registry to streamline the process.
Regulation (EU) 2024/3012 is meant to standardize carbon removal activities within the EU and incentivize the development of new carbon removal initiatives. A large number of activities, including geological storage of CO2, wetland restoration (which may be required, for instance, to compensate for large construction projects), and use of timber or agricultural fibers in buildings or infrastructure, are expected to benefit from the certification scheme.
