Fit for 2030 series: Commission takes first steps on carbon dioxide removal – clear accounting and permanence will be key

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Today, the European Commission has published its vision for Carbon Dioxide Removal (CDR) in the coming decades. Bellona welcomes the plan, which takes several important steps on accounting, transparency, verification and industrial decarbonisation, but cautions against the use of CDR as an offsetting tool, particularly in the context of carbon farming and the use of carbon in products.

The ‘Sustainable Carbon Cycles’ communication is a much-needed strategy to reduce dependence on fossil carbon and to increase the amount of carbon that is removed from the atmosphere. Much of Bellona’s input on tracking the origin and fate of CO2 seems to have been reflected in the final document.

Transparency and accounting as the vital cornerstone

Positives of the publication include the emphasis on transparent accounting and the role of the Carbon Removal Certification Mechanism as a pre-requisite to the trading of credits and other result-based incentives. The expectation is that by 2028 the tracking of carbon flows and verification of carbon removal should be well established and be fully implemented by 2030. This built-in learning period will be essential to maintain a ‘sanity-check’ on the deployment of incentives for CDR.

Furthermore, the ambition to develop a cross-country and open-access CO2 transport and storage network is a critical addition to the EU’s climate efforts. The communication also refers to the proposed change in the ETS that an emission reduction from CO2 use cannot be double-counted, a reminder to ensure that this change is upheld in the upcoming discussions.

Confusing handling of storage permanence

On the other hand, the role of so-called ‘Carbon Farming’ requires substantial clarification to ensure that such activities do not interfere with the overall aim of climate neutrality. The critical question of carbon storage in biological systems is only partially handled in the communication by unclearly earmarking those removals to balance out emissions in the bioeconomy, however with seemingly inferior expectations laid down for carbon farming than for geological removals. The storage of carbon within products is also given a substantial role, despite the significant concerns about storage permanence.

Carbon removal requires permanent storage and separate accounting

Bellona reminds the European institutions that for a process to qualify as CDR, four criteria (below) must be met. Critically, CO2 must be removed from the atmosphere and stored permanently away from it. There is a significant risk that the Commission’s approach to carbon farming and carbon storage in products will fall short of these criteria and will drag down the standards for carbon removal to such an extent that an activity which simply reduces or delays emissions will be re-labelled as an activity which removes carbon from the atmosphere. Such an outcome would formalise greenwashing.

CDR principles

On top of this, the emphasis on offsetting sets the debate on course for a zero-sum game, despite the increasingly clear need to reduce emissions in addition to removing CO2. While CDR is needed to balance out residual emissions in future, the short- and medium- term priority should remain to develop both types of activities in parallel, to maximise climate mitigation efforts. As such, it is vital to keep the targets for emission reductions and carbon removal separate.

“The Commission’s short-term ambitions for carbon removal have started off on the right foot, with a strong emphasis on accounting, transparency and CO2 storage networks. The success of this strategy will hinge on the standards for storage permanence which risk being undermined by the focus on products and carbon farming.”, said Mark Preston Aragonès, Policy Advisor at Bellona Europa.

For more on CDR’s role in the Fit for 2030 package:

The principles for CDR are drawn from Tanzer and Ramirez (2019)