I. Introduction
Carbon dioxide removal (CDR) has evolved from a peripheral climate policy concept into a central component of global decarbonisation strategies. The Intergovernmental Panel on Climate Change (IPCC) considers deployment of CDR essential to achieving the Paris Agreement’s temperature goals, particularly where residual emissions cannot be fully eliminated. Yet current levels of removal remain far below projected needs: In 2026, only 2.2 gigatonnes of carbon dioxide (GtCO2) were removed per year,[1] while scientific assessments indicate that around 5-10 GtCO₂ per year will be needed to remain within a 1.5°C pathway.[2]
Established that higher levels of CDR deployment need significant policy interventions, policy design must also recognise the great variance among CDR methods.[3] CDR methods vary enormously in many ways, and the divergences raise fundamental questions regarding the integrity of carbon accounting: can a given quantity of CO₂ removal be measured, verified, and treated as genuinely equivalent to an emission reduction?
The European Union (EU) has begun establishing a regulatory framework designed to ensure the credibility and comparability of CDR methods. This article examines the question of carbon accounting integrity, analyses the EU’s emerging approach to the certification of CDR, and considers the implications of these developments for compliance carbon markets both within and beyond the European Union. As the EU refines its CDR framework, questions around measurement, permanence, additionality and sustainability are increasingly coming to the forefront. How these issues are addressed could have implications for both the growth of CDR technologies and the future direction of carbon markets.
II. Defining Carbon Dioxide Removal (CDR) and the Question of Carbon Accounting Integrity
A. CDR and Its Methods
The IPCC defines CDR as “anthropogenic activities that remove CO₂ from the atmosphere and store it durably in geological, terrestrial, or ocean reservoirs, or in products.”[4] Effectively, in order to classify an activity as CDR, the following criteria must be satisfied: Carbon dioxide (CO₂) must come from the atmosphere, removal must take place via anthropogenic activities and not natural causes such as the natural growth of forests, and finally, CO₂ must remain sequestered from the atmosphere for a sufficiently long period to have a meaningful impact.
The IPCC categorises CDR methods based on factors such as their maturity, removal process, time scale of carbon storage, storage medium, mitigation potential, cost, co-benefits, impacts and risks, and governance requirements. These methods range from nature-based solutions, such as reforestation, to engineered approaches, including Direct Air Carbon Capture and Storage (DACCS). For example, the method of reforestation has the net potential to store between 0.5 and 3.6 billion tons of CO₂ annually, with a cost of USD 5- 50 per tonne of CO₂ sequestered.[5] On the other hand, DACCS has a potential to store between 0.5 and 5 billion tonnes of CO2 annually,[6] representing a substantial share of the carbon removals required to meet global climate targets.[7] According to the IPCC 6th Assessment Report (6th AR), such a process amounts to USD 100-300 per tonne of CO₂ sequestered,[8] while some commentators, such as Dr. Herzog, have suggested substantially higher figures.[9] Herzog’s analysis gives a range of USD 600-1000 per tonne of CO2.[10]
While the IPCC emphasises that large-scale deployment of CDR will be necessary to achieve global net-zero emissions targets,[11] the diverse characteristics of removal methods raise important policy and governance considerations. According to the IPCC 6th AR, methods such as reforestation, improved forest management, soil carbon sequestration, peatland restoration and blue carbon management may generate significant co-benefits for biodiversity, ecosystem health, employment opportunities, and local livelihoods when implemented under appropriate conditions.[12] Conversely, poorly planned afforestation projects or the production of biomass crops for bioenergy with carbon capture and storage (BECCS) or biochar may result in negative environmental and socio-economic consequences, including impacts on biodiversity, food and water security, local livelihoods, and the rights of Indigenous Peoples.[13] Ocean fertilization could potentially alter nutrient distribution patterns, disrupt ecosystem structures, increase oxygen depletion, and intensify acidification in deeper ocean layers if deployed.[14]
| CDR Method[15] | Cost (USD/tCO₂) | Mitigation Potential (GtCO₂/yr) | Key Risks | Key Co-benefits | Trade-offs and Spillover Effects |
| Afforestation/Reforestation | 0–240 | 0.5–10 | Reversal via wildfire, disease, pests; reduced water yield. | Employment, biodiversity, wood products. | Large-scale deployment can compete for land with biodiversity conservation and food production. |
| Soil Carbon Sequestration | −45–100 | 0.6–9.3 | Increased nitrous oxide (N₂O) emissions; reversal risk. | Improved soil quality and productivity. | Increases sequestration potential at the expense of production; net addition per hectare is small and hard to monitor. |
| Biochar | 10–345 | 0.3–6.6 | Particulate emissions; biodiversity/carbon stock loss from unsustainable biomass harvest. | Increased crop yields, reduced non-CO₂ soil emissions. | Environmental impacts from particulate matter; competition for biomass resources. |
| DACCS | 100–300 (84–386) | 5–40 | Increased energy and water use. | Water production (solid sorbent designs). | Potentially increased emissions from water supply and energy generation. |
B. The Question of Carbon Accounting Integrity
These divergences in cost, technological maturity, and environmental trade-offs are not merely technical distinctions; they raise a more fundamental legal and regulatory question: can the quantity of CO₂ actually removed by a given method be measured, verified, and guaranteed to remain sequestered with sufficient accuracy to be treated as fungible with an emission reduction? To date, CDR credits have been transacted almost exclusively within the voluntary carbon market, where quality standards and verification practices vary considerably across registries.[16] Indeed, more than 125 distinct methodologies currently exist for certifying carbon removals.[17] This is now changing, as regulators have been exploring pathways to bring CDR within the scope of compliance-based carbon markets.[18] This question of carbon accounting integrity, encompassing measurement precision, permanence risk, additionality, and the treatment of ancillary environmental impacts, will become especially consequential once CDR is integrated into compliance-based carbon markets such as the EU Emissions Trading System (EU ETS). Within a compliance market, a verified tonne of removed CO₂ is more than a scientific assessment; it becomes a tradable unit. Its acceptance implies that it is fungible with, and therefore capable of substituting for, an equivalent emission reduction elsewhere in the economy. Consequently, any imprecision in measurement, any risk of reversal, any failure of additionality, or any unaccounted environmental cost is not confined to the removal site itself. It is effectively imported into the market, potentially undermining the credibility of the allowances in circulation and the broader integrity of the trading system.
1. Measurement Precision
One of the key challenges in accounting for CDR methods is the ability to measure and verify net CO₂ removals with sufficient accuracy.[19] Effectively, the International Energy Agency categorizes CDR methods into four categories, based on their “MRV-ability”.[20] Category 1 represents the core, proven CDR activities that are easy to account such as DACCS and BECCS.[21] On the other hand, methods such as soil organic carbon (SOC) carbon removal in Category 3[22] and enhanced weathering (EW) in Category 4 demonstrate challenges in their measurement and monitoring.[23]
Where net removal cannot be measured with sufficient accuracy, accounting inevitably comes to rely on a combination of the project developer’s own MRV methodology and the independent assessment carried out by a third-party verifier, rather than on a direct, instrument-based measurement of CO₂ drawdown itself. This creates uncertainty, especially across Category 3 and 4 methods, and arguably undermines the reliability of verified carbon credits once such credits are used within a compliance market.
2. Permanence Risk
What makes a carbon capturing activity classify as “CDR” depends on whether it can be stored in the receiving media for a meaningful amount of time. Discussions in the scientific community remain with regards to what constitutes “high durability” or “permanent” within the definition of CDR.[24] This also includes the risk of carbon reversal,[25] which refers to the risk of stored carbon being released back into the atmosphere.[26] For example, biochar carbon removal, which refers to the method of converting biomass into biochar through pyrolysis, carries a higher risk of carbon reversal when not handled properly or burned.[27] Similarly, due to the global increase in wildfires[28], afforestation and reforestation as CDR methods are associated with a high risk of carbon reversal.
A carbon accounting-related outcome of this permanence risk concerns carbon certification, and especially the question of what would happen to the carbon certificate if the specific removal project it is attached to becomes subject to reversal. One policy response proposed for this question is to sell carbon certificates with an obligation to replace reversals, therefore, holding the credit holder responsible to ensure additional removals in case of reversals.[29] This approach, however, risks penalizing CDR methods that, despite carrying a comparatively higher reversal risk, offer substantially lower environmental impact, capital expenditure, and energy costs, reforestation being a prime example.
3. Additionality
Within the context of CDR, additionality refers to the requirement that the removal achieved by an activity exceed what would have occurred under a business-as-usual scenario.[30] In other words, the removal must be attributable to the incentivised activity itself rather than to processes that would have taken place regardless of carbon crediting. Determining correct variables in establishing “additionality” for the purposes of carbon accounting is important, since certifiable and creditable removals must be additional.[31] Failure to demonstrate genuine additionality risks creating credits that do not correspond to real net removals,[32] undermining the environmental credibility of the individual project, as well as the broader carbon market.
4. Environmental Costs of Removal
As outlined in the above table, the IPCC 6th AR, Working Group III exposes the environmental risks as well as co-benefits of certain CDR methods. Accordingly, a carbon accounting framework that focuses solely on the quantity of CO₂ removed risks treating fundamentally different removal activities as interchangeable. Ensuring environmental and social integrity therefore requires regulatory frameworks capable of assessing not only the volume of removals generated, but also their wider sustainability impacts.
III. The EU’s Emerging Approach
The two main texts outlining the EU’s emerging approach to the accounting and certification of carbon removals are the Carbon Removals and Carbon Farming (CRCF) Regulation adopted in 2024,[33] and the European Commission’s (EC, Commission) revision proposal for Phase 5 of the EU Emissions Trading System (EU ETS) published in July 2026.[34]
The CRCF Regulation essentially provides for a voluntary, EU-wide certification framework for CDR, carbon storage and carbon farming activities.[35] Although at the time of its enactment, CDR was not accounted within the compliance market as an activity granting additional allowance for the emitting operators, the CRCF Regulation was significant in responding to some of the carbon accounting integrity questions raised above.
The EC’s proposal marks a potentially significant next step. By creating a pathway for certain CRCF-certified removals to be recognised within the EU ETS, the proposal aims to connect a framework originally developed for voluntary markets with the EU’s compliance carbon market architecture.[36]
A. The CRCF Regulation
The CRCF Regulation adopts a definition of CDR that largely mirrors the IPCC’s definition, being “the anthropogenic removal of carbon from the atmosphere and its durable storage in geological, terrestrial or ocean reservoirs, or in long-lasting products”.[37]
As set out in its Article 1, the Regulation establishes quality criteria for CDR activities within the EU, rules for the verification and certification of carbon removals, the functioning and recognition of certification schemes by the EC, and the rules on the issuance and use of certified units.[38] The CRCF Regulation establishes overarching criteria for the certification of CDR, while also bringing rules for certification steps, period verification of compliance with the quality criteria, and governance structure for implementing the certification framework.[39] Effectively, the EC recognizes the certification bodies[40] if they meet transparency requirements and procedures, and manage public registries.[41]
Under Article 3, a CDR activity is eligible for certification if 1) it fulfils the quality criteria under Chapter 2, and 2) if it is independently verified in accordance with Article 9.[42]
1. Quality Criteria
The quality criteria as set out in Chapter 2 of the CRCF Regulation directly correspond to the carbon accounting integrity questions raised above (measurement precision, additionality, permanence risk, environmental cost of removal). Effectively, the four principles under the CRCF are quantification, additionality, permanence, and sustainability. What this article refers to as “the environmental cost of removal” corresponds, under the CRCF Regulation, to the “sustainability” criterion.
First, Article 4 establishes the quantification criterion. The provision requires the calculation of a net carbon removal benefit by deducting baseline carbon removals and greenhouse gas emissions associated with the activity from the total carbon removals achieved.[43] To qualify as a permanent carbon removal, the resulting balance must be positive (>0).[44] The baseline carbon removal, represented as (CRbaseline) under Article 4, is set by the European Commission (Commission) to accurately reflect the efforts of land managers and industries that have already engaged in CDR activities in the past.[45]
Second, Article 5 incorporates the principle of additionality. Accordingly, a removal activity must go beyond applicable legal requirements and must benefit from the incentive effect created by certification.[46]
Third, Articles 6 and 8 seek to address permanence and reversal risks. According to Article 6, to guarantee that carbon remains stored over a meaningful period of time, operators must monitor storage and are liable for carbon reversal during that monitoring period.[47] Article 6 does not specify a precise durability threshold in the Regulation itself, instead defining CDR as storage occurring over “several centuries”.[48] Article 8 provides that the liability mechanisms for the occurrence of carbon reversal during the monitoring period would be established through delegated acts, and would include collective buffers, up-front insurance mechanisms, and direct cancellation of units as a last resort.[49]
Finally, Article 7 designates that the CDR activities need to meet minimum sustainability requirements, building where appropriate on the “Do No Significant Harm” (DNSH) criteria established under the Taxonomy Regulation.[50]
Although the CRCF Regulation responds to the main integrity issues by setting standard definitions and calculations under the quality criteria, some argue that these methodologies are bound to produce low-quality units.[51] For example, an analysis made by Carbon Market Watch and Öko-Institut argues that the fact that the CRCF allows units to be issued based on past efforts weakens the additionality principle, since those past actions were taken regardless of the initiatives under the CRCF Regulation.[52] Another argument could be that continuing scientific and methodological uncertainties surround the long-term permanence of certain removal pathways, particularly biological and land-based approaches.
2. Independent Verification
The Commission adopted the first delegated act on methodologies for the voluntary certification of permanent carbon removal methods (Delegated Act) in February 2026, covering DACCS, biogenic emissions capture with carbon storage (BioCCS), and biochar carbon removal (BCR). [53] This constitutes an EU-wide standard for permanent carbon removals.
The Delegated Act operationalises the quality criteria established under the CRCF Regulation by introducing detailed certification methodologies for DACCS, BioCCS and BCR. In doing so, it establishes the EU’s first harmonised standard for permanent carbon removals and enables certification schemes to seek Commission recognition for applying these methodologies within the CRCF framework. For example, its Article 2 sets out the methodology for DACCS activities and specifies where the detailed rules can be found in the Annex.[54] It defines the eligibility criteria, activity and monitoring periods, rules for identifying carbon removal sinks and emission sources, baseline calculation, quantification of total carbon removals and associated GHG emissions, long-term storage and liability provisions, sustainability requirements, and monitoring and reporting obligations.[55] In addition, it requires that the facility capturing the CO₂ be located within the European Union.[56]
B. Phase 5 of the EU ETS
On 17 July 2026, the Commission proposed a revision to the ETS Directive,[57] a plan that aims to create a compliance market for EU-based CDR activities.[58]
The proposal incorporates domestic permanent carbon removals into the EU ETS through a corresponding increase in the emissions cap. Under the proposed Article 9c, additional allowances would be created only where the Commission purchases CRCF-certified BioCCS and DACCS removal units.[59] The increase in the ETS cap would therefore be strictly linked to verified removals and limited to those technologies that the Commission considers capable of delivering a sufficiently high level of permanence and monitoring reliability.[60] At this stage, no carbon removal methodologies other than CRCF -certified BioCCS and DACCS removal units are eligible for inclusion.[61] Under the proposed Article 9c, the Commission will issue 250 million additional allowances and auction them between 2031-2040.[62] The revenues from those auctions will be used to purchase 48 million tonnes of CO2 removal credits by 2040.[63]
Notably, the proposal excludes BCR, notwithstanding the fact that the CRCF Regulation provides certification methodologies for such activities. Although the Commission does not entirely reject it as a stable CDR method, it believes there is no long-term stability evidence to include it in a compliance market, yet.[64]
C. Implications of the EU’s CDR Strategy
By admitting only BioCCS and DACCS into the compliance market’s central procurement programme, the proposal concentrates guaranteed, EU-backed demand on two removal methods to the exclusion of all others. This includes biochar, which, as discussed above, already possesses an operative CRCF certification methodology. Compliance-market status tends to offer greater demand visibility and durability than voluntary market participation,[65] and this asymmetry risks channelling investment and research and development disproportionately toward the two included methods, at the expense of the broader CDR landscape. This runs counter to the prevailing scientific consensus. The IPCC’s 6th AR advocates for the deployment of a balanced, diversified portfolio of CDR methods, rather than concentrated reliance on any single approach.[66]
A further policy question emerges once the CRCF framework is considered alongside the EU’s Carbon Border Adjustment Mechanism (CBAM). CBAM, under its Article 9, regulates that carbon price effectively paid in a third-country market can be deduced from the number of CBAM certificates that need to be surrendered.[67] The wording of Article 9 is critical, as it provides for a reduction “only if the carbon has been effectively paid in the country of origin”. It does not appear to recognise non-EU CDR activities as a basis for reducing CBAM liability. Similarly, the CRCF Regulation and its quality criteria apply only to activities carried out within the EU.[68] Therefore, even in cases where a third country may have adopted even more ambitious integrity criteria for CDR certification, which is a possibility given the criticism towards the CRCF Regulation,[69] it would not be deducted under CBAM.
This creates a regulatory asymmetry. Within the EU, carbon removals intended to generate compliance value are increasingly subject to detailed requirements. No analogous extension is proposed for CBAM. Far from encouraging removal-based compliance abroad, the mechanism’s own price logic penalises it. Indeed, if an importer undertakes a CDR activity and, as a result, pays a reduced amount for carbon credits in its own jurisdiction, this does not necessarily translate into a lower CBAM obligation. Since CBAM takes into account only the carbon price actually paid in the country of origin, the importer would still be required to surrender the corresponding amount in CBAM certificates, thereby paying the difference to the competent EU authority.
As carbon removals become more closely integrated into compliance markets, this distinction may prompt further discussion regarding the extent to which integrity standards should play a role in the EU’s external climate policy framework.
IV. Conclusion
The EU’s emerging CDR framework indicates that carbon removals are moving from a largely voluntary-market instrument towards a more regulated compliance-market asset. This shift is likely to increase scrutiny of quantification, additionality, permanence, and sustainability standards, while creating differentiated regulatory value among removal technologies. For companies, the key issue will not only be whether carbon removals are available, but whether the relevant credits are sufficiently robust, certifiable and commercially reliable under developing EU rules.
Yet this framework remains a work in progress. The narrow admission of only two removal methods, and the disjunction between the CRCF’s rigorous domestic quality criteria and CBAM’s acceptance of third-country carbon prices remain two gaps that would need to be addressed as the EU ETS proposal proceeds through the legislative process.
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[1] Carbon Brief, “Q&A: The current state of ‘carbon dioxide removal’ around the world”, 2 June 2026, https://www.carbonbrief.org/qa-the-current-state-of-carbon-dioxide-removal-around-the-world, accessed 1 September 2026.
[2] It is estimated that by 2050, global sequestration has to amount to 10 billion tons of CO2 per year in order to reach 1,5 degrees Celsius warming goals set in the Paris Agreement. See Dr. Roger Aines’ commentary, Climate Now, “Carbon Dioxide Removal with Roger Aines”, 9 August 2021, https://climatenow.com/podcast/carbon-dioxide-removal-with-roger-aines/, (Aines Commentary) accessed 1 September 2026.
[3] Luka Štrubelj et al., “The new EU carbon removal certification: Landmark legislation or an empty promise?”, One Earth, Vol. 6, No. 9, 2023, p.1094.
[4] Intergovernmental Panel on Climate Change, 6th Assessment Report, Working Group III, (“IPCC 6th AR”) para. C.11.1.
[5] Sabine Fuss et al., “Negative emissions – Part 2 : Costs, potentials and side effects”, Environmental Research Letters, Vol. 13, No. 6, 2018, p. 32.
[6] Id.
[7] It is estimated that by 2050, global sequestration has to amount to 10 billion tons of CO2 per year in order to reach 1,5 degrees Celsius warming goals set in the Paris Agreement. See Aines Commentary.
[8] IPCC 6th AR, para. C.11.1
[9] Climate Now, “Carbon Dioxide Removal”, 10 August 2021, https://climatenow.com/video/carbon-dioxide-removal-cdr/?utm_source=CN_YouTube&utm_medium=CDR_Transcript&utm_campaign=CN_YouTube_CDR_Transcript, accessed 1 September 2026.
[10] Id.
[11] IPCC 6th AR, para. C.11.1
[12] Id., para. C.11.2.
[13] Id.
[14] Id.
[15] Adapted and shortened from IPCC 6th AR, Table TS.7 (Summary of status, costs, potentials, risk and impacts, co-benefits, trade-offs and spillover effects and the role in mitigation pathways for CDR methods), based on {12.3.2, 7.4}.
[16] World Resources Institute, “High-Quality Carbon Removal Requires Credible and Consistent MRV – Government Oversight Can Help”, 13 June 2024, https://www.wri.org/technical-perspectives/measurement-reporting-verification-of-carbon-removal, accessed 1 September 2026.
[17] Štrubelj, p.1093.
[18] Carbon Gap, “2026-27 Review of the EU Emissions Trading System 1”, https://carbongap.org/review-of-the-eu-emissions-trading-system, accessed 1 September 2026.
[19] Brookings Institute, “What is carbon dioxide removal and capture in the context of climate change?”, 14 July 2026, https://www.brookings.edu/articles/what-is-carbon-dioxide-removal-and-capture-in-the-context-of-climate-change/, accessed 18 August 2026; International Energy Agency Greenhouse Gas R&D Programme, “Measurement, reporting and verification and accounting for carbon dioxide removal in the context of both project-based approaches and national greenhouse gas inventories”, 15 October 2024, available at https://ieaghg.org/publications/measurement-reporting-and-verification-and-accounting-for-carbon-dioxide-removal/, accessed 18 August 2026, (“IEAGHG Report”) p. 19 para. 2.4.1, p.54 para. 4.2.4.
[20] IEAGHG Report, p. 81-82, para. 4.4.
[21] Id., p. 81-83, para. 4.4.
[22] Id., p. 59, para. 4.2.4.
[23] Id., p. 83.
[24] Id., p. 5.
[25] Id., p. 9.
[26] Beyond Alliance, “New Approach Could Help Solve One of Carbon Markets’ Biggest Problems”, 16 June 2026, https://beyond-alliance.org/new-approach-could-help-solve-one-of-carbon-markets-biggest-problems/, accessed 10 August 2026.
[27] Carbon Better, “An Intro to Carbon Dioxide Removal (CDR)”, 21 February 2025, https://carbonbetter.com/story/cdr-intro/, accessed 18 August 2026.
[28] Our World in Data, “Wildfires, Burned Area by Year”, https://ourworldindata.org/wildfires, accessed 18 August 2026.
[29] Bellona, “Bellona Briefing: Addressing differences in permanence of Carbon Dioxide Removal”, April 2022, https://network.bellona.org/content/uploads/sites/3/2022/04/Addressing-differences-in-permanence-of-Carbon-Dioxide-Removal.pdf, accessed 19 August 2026, p. 12.
[30] The World Bank defines “emissions additionality” as such: Under this concept, an action is deemed additional if it leads to lower levels of emissions than would have otherwise occurred under business as usual; this concept is perhaps the most simplified form of additionality. Under such a concept, the question is not raised regarding whether other factors would have resulted in that action occurring. For example, an action may indeed be profitable and yet lead to emissions reductions, on the assumption that not all profitable options will take place. See World Bank, “Carbon credits and additionality: past, present and future”, 19 May 2016, https://documents.worldbank.org/en/publication/documents-reports/documentdetail/407021467995626915, accessed 19 August 2026, p.7.
[31] IEAGHG Report, p. 48, para. 4.2.3.
[32] Gold Standard, “What does ‘additionality’ mean and why is it important?”, 11 March 2026, https://goldstandardhelp.freshdesk.com/support/solutions/articles/44001989691-what-does-additionality-mean-and-why-is-it-important-, accessed 21 August 2026.
[33] Regulation (EU) 2024/3012 of the European Parliament and of the Council of 27 November 2024 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products.
[34] Carbon Gap, “Reaction to the legislative proposal on carbon removals in the EU Emissions Trading System”, 31 July 2026, https://carbongap.org/insights/reaction-to-the-legislative-proposal-on-carbon-removals-in-the-eu-emissions-trading-system, accessed 20 August 2026.
[35] Regulation (EU) 2024/3012 of the European Parliament and of the Council of 27 November 2024 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products, (“CRCF Regulation”) Introductory Clause 3.
[36] International Carbon Action Partnership, “EU Commission publishes EU ETS review proposal”, 17 July 2026, https://icapcarbonaction.com/en/news/eu-commission-publishes-eu-ets-review-proposal, accessed 28 August 2026.
[37] CRCF Regulation, Art. 2.
[38] Id., Art. 1.
[39] Štrubelj, p.1094.
[40] Under Article 2 of the CRCF Regulation, a certification body refers to a “recognised independent conformity assessment body that has concluded an agreement with a certification scheme to carry out certification audits and issue certificates of compliance.”
[41] Štrubelj, p.1094.
[42] CRCF Regulation, Art. 3.
[43] Id., Art. 4.
[44] Id., Art. 4.
[45] European Commission, “Q&A on the provisional agreement on the Regulation establishing an EU-wide voluntary framework for certifying permanent carbon removals, carbon farming and carbon storage in products (CRCF Regulation)”, 5 April 2024, https://climate.ec.europa.eu/document/download/a8abe1c4-a3c6-4c94-be0e-4b76f7fd0308_en?filename=policy_carbon_faq_crcf_regulation_en.pdf, (“Commission Commentary on CRCF”) accessed 8 September 2026.
[46] CRCF Regulation, Art. 5.
[47] Id., Art. 6.
[48] Id., Art. 2(g).
[49] Id., Art. 8.
[50] Commission Commentary on CRCF.
[51] Carbon Market Watch, “Carbon Certification Removal Framework (CRCF) methodologies among lowest quality – analysis”, 2 June 2025, https://carbonmarketwatch.org/2025/06/02/carbon-certification-removal-framework-crcf-methodologies-among-lowest-quality-analysis/, accessed 27 August 2026.
[52] Id.
[53] European Commission Directorate General for Climate Action, “EU sets world’s first voluntary standard for permanent carbon removals”, 3 February 2026, https://climate.ec.europa.eu/news-other-reads/news/eu-sets-worlds-first-voluntary-standard-permanent-carbon-removals-2026-02-03_en, accessed 27 August 2026.
[54] Commission Delegated Regulation (EU) of 3.2.2026 supplementing Regulation (EU) 2024/3012 of the European Parliament and of the Council by establishing the certification methodologies for permanent carbon removals activities, (“CRCF Delegated Act”) Article 2.
[55] Id.
[56] Id.
[57] Proposal for a Directive of the European Parliament and of the Council amending Directive 2003/87/EC and Decision (EU) 2015/1814 as regards driving competitiveness and cost-effective decarbonisation (“ETS Proposal”).
[58] Carbon Herald, “EU Proposes Historic €50B ETS Carbon Removal Compliance Market”, 20 July 2026, https://carbonherald.com/eu-proposes-historic-e50b-ets-carbon-removal-compliance-market/, accessed 28 August 2026.
[59] ETS Proposal, Art. 9c.
[60] Id., Part 1.
[61] Id.
[62] Id., Art. 9c (4).
[63] Id.
[64] CDR.fyi, “The EU ETS Proposal Explained”, 22 July 2026, https://www.cdr.fyi/blog/the-eu-ets-proposal-explained, accessed 30 August 2026.
[65] Fast Markets, “Corporate carbon demand shifts toward offtakes as traded market stays muted, survey finds”, 12 January 2026, https://www.fastmarkets.com/insights/corporate-carbon-demand-shifts-toward-offtakes-as-traded-market-stays-muted-survey-finds/, accessed 30 August 2026.
[66] IPCC 6th AR, Chapter 12, para. 12.3, p. 1265.
[67] Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism, Art. 9.
[68] See, as an example, CRCF Delegated Act, Art. 2.
[69] Carbon Market Watch, “EU carbon farming methodologies weaker than the Paris standard”, 7 May 2026, https://carbonmarketwatch.org/2026/05/07/eu-carbon-farming-methodologies-weaker-than-the-paris-standard/, accessed 7 September 2026.
