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Open letter to the European Bodies on the proposed Carbon Removal Certification Framework (CRCF)

19.07.2024

The CRCF, a European framework project for certifying carbon removals, favors emerging technologies over forest projects.

The ATIBT, through its Carbon and Biodiversity Commission, joins the "NBS (Nature Based Solution) Coalition" to advocate for nature-based solutions, including forest projects, highlighting their co-benefits (biodiversity, social aspects, etc.).

The coalition recently sent an open letter to European authorities to warn about the CRCF's impact on NBS projects, especially in the Global South, and continues to engage with the European Commission.

The CRCF, a draft European regulation to provide a framework for carbon removal projects

The CRCF (Carbon Removal Certification Framework) draft regulation proposed by the European Union aims to establish a reliable certification framework for the removal of CO2 from the atmosphere. The main objectives are to promote sustainable solutions and innovative carbon capture and storage technologies. This certification system will validate carbon removal efforts and create revenue opportunities for industries by marketing carbon credits to European companies seeking to offset their emissions. The framework envisages various certification methodologies for activities as shown in the diagram below:

  • permanent carbon storage, carbon farming, which includes nature-based solutions projects linked to forest restoration/reforestation and soil carbon;
  • the storage of carbon in products (e.g. building with wood materials).
  • and the permanent carbon removal through new technologies.

Projects outside Europe may be eligible for CRCF if they meet strict European criteria. This allows international projects to participate in the European carbon offsetting market, ensuring real and sustainable CO2 removal and alignment with EU environmental and social standards. In this way, the CRCF can help Europe meet its climate objectives by integrating carbon removals from various regions of the world, while maintaining a high level of rigour in certification.

Hard to abate" emissions are those that are particularly difficult to reduce for technological, economic or practical reasons, often coming from sectors such as aviation, iron and steel, cement production and chemicals. Under the CRCF and European climate policies, offsetting them often requires carbon removal technologies such as Carbon Capture and Storage (CCS) or Bioenergy with Carbon Capture and Storage (BECCS).

In this configuration, the use of carbon credits from forestry projects raises questions

The CRCF aims to establish clear rules for the certification of carbon removals, differentiating between permanent and sustainable removals ("permanent carbon removals" in the diagram above) and other forms, such as "carbon farming" (which includes forestry projects) and carbon storage in products (pillars 1 and 2 of the diagram). Forestry projects, although important for sequestration, present risks of non-permanence (deforestation, fires, natural disturbances) and may not be preferred for offsetting emissions that are difficult to reduce, unless they demonstrate exceptional management and sustainability.

In fact, this regulation implies that carbon credits from sustainable forest management and reforestation are of lower quality than those generated by emerging technologies. The risk is that forest projects may be relegated to the background, despite the consideration of non-permanence by voluntary certification standards.

Furthermore, it is regrettable that this regulation only considers carbon, ignoring the social and biodiversity co-benefits provided by sustainable forest management and NBS (nature-based solutions) projects, which are absent from technological projects for permanent carbon storage.

ATIBT joins the NBS Coalition

The NBS (Nature Based Solution) Coalition brings together around twenty companies and organisations from all over the world involved in forest carbon projects at various levels.

The ATIBT, through its Carbon & Biodiversity Committee, is joining this coalition to call on Europe and the business world to understand that :

  • Technology must not be given priority over projects based on nature;
  • By committing ourselves to projects based on nature rather than technology, we are taking account of biodiversity and social aspects in the same way as climate, which are inseparable!

This coalition recently wrote an open letter to the European authorities to highlight the impacts of CRCF on NBS projects, particularly in southern countries. The letter has been sent to the European Commission and the French IUCN Committee. The coalition meets every week to monitor progress on its roadmap and has regular exchanges with the European Commission in Brussels. A memo explaining the challenges of the CRCF for tropical areas has also been produced.

Share this letter with the media, expert groups, ministries in third countries to advocate for forest projects !

 

Download the open letter

Download the tropical zone memo