At the end of 2022, the EU Commission developed a proposal for a framework to certify activities that remove CO2 from the atmosphere and store it in sinks, including soils. The Ecologic Institute and the Oeko-Institut have now critically reviewed this proposal on behalf of the Federal Environment Agency and found that it is not sufficient to ensure that certifiable activities on agricultural land and in forests will meet the high standards that would be necessary.
The experts conclude that the proposed framework does not ensure that the potential carbon removals are not overestimated (quantification). There is also a lack of binding rules to compensate for potential reversals after the certification of removal activities, for example through changed agricultural practices or extreme weather events. In addition, the requirements for ensuring additionality of removal activities under the proposed framework are too weak, i.e. they are not sufficient to ensure that measures to store carbon in the soil would not also have taken place without the new EU framework and its funding.
These aspects are particularly important because the Commission proposal does not clearly define the purpose for which the carbon removal certificates may be used. For example, it is not explicitly ruled out that temporary carbon storage in soils may be used to offset emissions already produced in other sectors.
Robust rules for climate protection
"If storage cannot be secured in the long run and if the carbon removal would have occurred anyway, or the amount of carbon stored is overestimated, the framework might ultimately undermine environmental integrity by increasing the amount of emissions released into the atmosphere if the certificates were usable for offsetting," explains Anne Siemons, an expert on international climate policy at the Oeko-Institut.
Offsetting greenhouse gas emissions with the help of the planned certificates should therefore be excluded. Certificates from removal activities could instead be used as a financial contribution to climate mitigation, without claiming to offset emissions elsewhere. Alternatively, public subsidies could be linked to the certification of climate protection measures that focus on soils.
Overall, the researchers recommend that the criteria of quantification, additionality, long-term storage and sustainability should be strengthened in the EU's regulatory framework. In particular, if certificates are to be used for offsetting, the required standards for removal activities must be high – a bar that climate-friendly soil management cannot reach.
Background: Potentials of climate-friendly soil management
The sustainable management of soils, for example through rewetting or organic farming, plays a special role in climate mitigation because soils can store significant amounts of CO2. Climate-friendly soil management can both avoid greenhouse gas emissions and store additional carbon in sinks. Experts estimate that the annual reduction potential of climate-friendly soil management is between 70 and 115 million tonnes of CO2 equivalents.
The EU Commission's proposal for a Carbon Removal Certification Framework, published on 30 November 2022, aims to create incentives for removing more CO2 from the atmosphere. In addition to geological storage and carbon stored in products, the proposal aims to promote so-called "carbon farming", including climate-friendly soil management activities to sequester carbon in soils and biomass. The new framework sets out rules for the certification of carbon removals. An important component of the proposal are the so-called four QU.A.L.ITY criteria, which formulate requirements for certification in terms of quantification, additionality, long-term storage and sustainability.