The potential of certifying carbon removals in the EU : A feedback examination regarding the proposed regulation on a Union certification framework for carbon removals

Abstract: The EU has set out a goal to become climate neutral by 2050. The IPCC has recognized carbon dioxide removal (CDR) as being an essential technology in order to achieve net zero CO2 emissions. Since CDR can account for emissions from sectors that are hard to mitigate, the European Commission has proposed a regulation that will be the first EU-wide voluntary certification framework for high-quality carbon removals. During 1 December 2023 - 23 March 2023, the proposal received feedback from different actors in order to develop methodologies that will enable stakeholders to implement this certification framework. Therefore, since relevant actors' participation in designing the framework is important, the aim of this study is to analyse the feedback and identify potential strengths, weaknesses, areas of agreement, and conflicts of interest in the proposal. Out of the 210 submitted feedback documents that the EU Commission received, 165 documents were analysed in this study. From the feedback, the results of this study show that many actors from different sectors welcome the proposal and believe that it could bring further transparency and trustworthiness to CDR activities which could increase investments in carbon removal solutions. However, a common weakness among the respondents was the lack of clarity in the framework regarding the terminology and the alignment to other regulations and policies. Some conflicts of interest were also identified, surrounding the level of permanence in the included CDR activities, co-benefits, and the representation of actors within the expert groups.