As the European Commission plans to present a second legislative package on the circular economy on Wednesday 30 November, EUROPE has obtained a draft version of the forthcoming proposal for a regulation on the certification of carbon removals, one of the package’s initiatives. According to the draft, the Commission’s objective is to introduce a voluntary framework for a carbon removal certification in the European Union. This framework would include, among other things, permanent carbon removals in geological reservoirs or other media, carbon storage in materials used to make sustainable circular products, and carbon removal related to land management (‘carbon farming’).
To be eligible for certification, carbon removals would have to be quantified according to a formula set out in the regulation - ensuring, among other things, that the activity of removing carbon from the atmosphere does not actually lead to an increase in greenhouse gases in the atmosphere due to direct and indirect emissions from its implementation - and be generated by a carbon removal activity that meets a set of criteria.
These criteria include a principle of additionality. It is about ensuring that removals are generated only by carbon removal activity that goes beyond EU and Member State regulatory requirements and takes place through the incentive effect of certification.
The draft also lists sustainability objectives (protection of water resources, transition to a circular economy, pollution prevention and reduction, protection and restoration of biodiversity and ecosystems...) on which the carbon removal activity should have a neutral or positive impact.
Furthermore, the risk of release of stored carbon will need to be mitigated, monitored and reported to the certification body where appropriate.
Certification
In addition to these criteria, the draft document sets out the procedure for obtaining the carbon removal certification.
The operator should submit an application to a ‘certification scheme', i.e. a private or public organisation competent to certify the compliance of operators with the requirements of the regulation. These organisations should be recognised by the Commission by means of a decision valid for a maximum period of 5 years.
When the application for certification is accepted, the operator would be required to provide a management plan including a full description of the carbon removal activity - with expected total carbon removals and net greenhouse gas removals - and a monitoring plan.
Based on this management plan, a certification body (an independent, accredited or recognised conformity assessment organisation designated by the certification scheme) would carry out a certification audit to validate the information submitted. It could then issue a certificate, under the control of the certification system.
In order to verify the correct implementation of the management plan, the certification body would be required to carry out periodic “recertification” audits of the carbon removal activity.
In addition, each certification scheme would be required to maintain a public register of carbon removal activities and certified carbon removal units, and to submit an annual report to the Commission by 30 April.
Revision clause
The preliminary draft also includes a clause requiring the Commission to assess the impact of the regulation and to present a possible legislative proposal on the basis of this assessment.
See the regulation proposal: https://aeur.eu/f/3wb (Original version in French by Damien Genicot)