The certification of Carbon Dioxide Removal risks undermining real climate action

Posted on November, 30 2022

Today’s Commission proposals on the certification of Carbon Dioxide Removal (CDR) amount to little more than an empty shell, leaving the door wide open to uncertain carbon credits in the land use sector being traded in future under the EU Emission Trading System. The draft regulation is intended to provide a framework for defining what constitutes the removal of carbon from the atmosphere and its storage, and how such activities can be incentivised. Instead, there is a risk for the framework to be turned into a greenwashing exercise and provide another excuse for big polluters to avoid cutting their emissions.
Emissions removals will be necessary to achieve net zero emissions by 2050 according to the Intergovernmental Panel on Climate Change (IPCC), but this should not come at the expense of very rapid emissions cuts and instead only compensate for residual and unavoidable emissions. The current proposal of the European Commission merely represents a basic framework and fails to answer key questions and define important concepts.

Juliette Lunel, Climate and Land Use Policy Officer at the WWF European Policy Office said: “With this skeleton proposal the Commission is taking a real leap of faith, leaving all the critical details to be filled in later - including what counts as a removal and what uses any ‘carbon credits’ could be put to. Instead of going for a science-based approach, and recognising that removals by forests and other landscapes can’t simply be treated as tonne-for-tonne equivalent to fossil fuel emissions, the Commission proposals seem to pave the way for uncertain carbon offsets to be used to delay climate action elsewhere”.

In addition, with this proposal, the European Commission missed the opportunity to establish appropriate methodologies and include safeguards. Different types of carbon removal activities have very different storage durations and carry widely varying risks of reversal. The Commission leaves all this to be decided at a later stage through delegated acts or implementing regulations it will devise, thereby circumventing the European Parliament and Council in the decision-making.

“The Commission is playing a very risky game by not explicitly excluding the trading of removal certificates under the Emission Trading System (ETS) or the Effort Sharing Regulation (ESR). This means companies could be able to use the Carbon Removal Certificates as an excuse to pollute more and a way of not having to decarbonise their production and lower their emissions,” added Juliette Lunel.

In addition, the proposal sweeps aside the central question of responsibility, or liability, if carbon that is removed is subsequently released back into the atmosphere, by simply referring to ‘appropriate liability mechanisms’ without defining them in any way. This is extremely problematic given that some carbon removal methods have a high risk of reversal.

The proposals now go into the co-decision process between the Parliament and the Council, during which it is essential that details and safeguards be added to ensure that this provides a robust mechanism for supporting climate action and biodiversity protection.


Florian Cassier
Climate Communications Officer
+32 479 33 92 11
Wetland in Finland.
© Sabrina Bqain / WWF