2022/0394(COD) · In Force
370 submissions from 313 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 441 submissions on this file. Shown here: the 370 from organizations. Not shown: 67 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 4 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
239 submissions from industry — companies and their trade associations — against 84 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.8 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 2 submissions here repeat 2 texts word for word and are folded into them.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 23 Mar 2023 — it ran from 1 Dec 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 370 submissions.
· · filed 23 Mar 2023 · source
The Proposal presents the overall goal of staying below a global average temperature increase of 1.5 o C, which must be achieved using, on the one hand, efficiencies, circular economy and renewable energy, and on the other hand, by recirculating carbon from burning waste, biomass and from direct CO2 capture from the atmosphere (DAC), where the captured carbon can be recycled into products and into synthetic fuels.
Verra welcomes the opportunity to provide feedback on the European Commission's EU carbon removal certification framework proposal. Carbon removals will form a crucial element in EU and global climate action and the achievement of net zero emissions. The proposed framework is critical in establishing a regulatory underpinning for implementing and measuring removals.
International Emissions Trading Association (IETA) welcomes an opportunity to provide feedback on Commission proposal for EU Carbon Removals Certification Framework (CRCF). The CRCF proposal is a first steps towards EU policy on carbon removals, albeit it is lacking details on the actual use of carbon removals. Under the recent review the EU ETS the cap will reach 0 by 2039.
23 mars 2023 Contribution à la consultation sur le projet de cadre de certification des retraits de carbone La CEPM, Confédération Européenne de la Production de maïs, souhaite faire les commentaires suivants sur le projet de cadre de certification des retraits de carbone (CFCR) : La CEPM considère que l’agriculture est une solution pour le climat qui doit être mobilisée à la fois sur les leviers de réduction…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The General Sociation of Maïs Producers (AGPM) considers that the draft Framework for the Certification of Carbon Removal (CFCR) should take account in particular of the following points: to allow further development of the arable crops method Label Bas Carbone.
Filed in French · English published by the European Commission
We (BIO AUSTRIA, Association of Austrian organic farmers) would like to thank us for the opportunity to comment on the proposal for an EU framework for the certification of carbon removals/storage, and would like to see the following points taken into account: 1.
Filed in German · English published by the European Commission
Overall, we support the proposal. The development of a robust certification system across the EU is an indispensable first step in achieving a net contribution from carbon removals in support of the EU climate-neutrality objective. We also share the Commissions view that strong action to reduce emissions should not be undermined by shifting focus to carbon removals.
The CNPF (National Center for Forest Ownership) is a public body responsible for the development of forest management in private forests. From 2015 to 2018, with its partner I4CE (Institute for Climate Economics), the CNPF participated to the creation of the label Bas-Carbone (low-carbon label), the French standard for carbon offset projects.
The European Commission recognises carbon removal from the atmosphere as a crucial element in the fight against climate change and includes it in the climate law to achieve climate neutrality by 2050. From the Forests and Climate Change Forum we support this initiative in the process of creating a robust voluntary carbon removal market, based on existing systems, which could bring benefits to landowners, mainly for…
Filed in Spanish · English published by the European Commission
The EU-CRCF has the potential to significantly contribute to delivering the reductions required for the EU and its member states to achieve their climate targets. By establishing clear and precise legislative frameworks, the EU-CRCF could create the framework required to unlock the potential of industrial and technology-based carbon removal.
Stuttgart, 23.03.2023 Feedback on the Certification of carbon removals - EU rules About TREEO TREEO, a climate-tech startup in the Carbon Dioxide Removal (CDR) sector, serves and connects a two-sided market: tree growers (e.g. farmers) and balancers (our clients). The TREEO carbon product captures CO2 from our atmosphere through tree planting, and stores carbon in the long term in timber construction and biochar.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The LIFE CarbonFarmingScheme project (EU LIFE Preparatory project, LIFE19 PRE FI001-SI2.828588), implemented in 2020-2022 by a consortium lead by St1 Oy produced stakeholder-validated information and guidance on the governance and practical implementation of carbon farming measures and incentives in arable agriculture and forestry across different pedo-climatic regions in Europe.
Filed in Finnish · English published by the European Commission
In addition to emission avoidance and reduction, carbon removal remains the last chance to reach net zero within the timeframe envisaged by the EU. It is mandatory to compensate for hard-to-abate emissions and reduce the greenhouse gas concentration in the atmosphere to a level that preserves human habitats. The EU is leading the way by laying the groundwork for a carbon removal framework.
· · filed 23 Mar 2023 · source
The latest IPCC AR6 report that came out in March now made it very clear. We are far away from being on track to solving the accelerating climate crisis. Emissions need to go down as fast as possible. Climate finance need to increase to at least 3-6 times more. The era of fossil fuels and fossil fuels subsidies must end.
· · filed 23 Mar 2023 · source
From SÈLVANS we encourage the EU to facilitate the promotion of a certification of carbon removal (or a carbon credit) based on primary forest and old-growth forest structures (see definitions in Commission Guidelines for Defining, Mapping, Monitoring and Strictly Protecting EU Primary and Old-Growth Forests" from March 21st), given that such a model concentrates enormous advantages over other forest management…
As identified in the Proposals, the experience from the development and implementation of the EU RED legislation had been taken into account in the development of this regulation. However, it is not evident this when considering the accreditation requirements propsoed in this regulation.
Microsoft’s comments on the European Commission’s proposal for a Carbon Removals Certification Framework (EU CRCF) March 2023 There is growing international recognition that meeting net zero by 2050 will first and foremost require dramatic changes in order to cut emissions, but also a significant amount of carbon removal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Mar 2023 · source
Thank you very much for the opportunity to submit an opinion on the Proposal for a Union certification framework for carbon removals (CRCF). Unfortunately, many important questions of the legislation are moved to the future, postponed to Delegated Acts or outsourced to a closed expert group.
· · filed 23 Mar 2023 · source
TIC Council, the global association representing the independent testing, inspection, and certification (TIC) sector, views the Commissions initiative to establish the first EU-wide framework for the certification of carbon removals as a crucial step in achieving EU aims of reduced greenhouse gas emissions and climate neutrality by 2050.
BirdLife welcomes this regulation which is a first attempt to create a financial system to enhance the carbon removals, although we consider that this should be done mainly by enhancing the natural ecosystems which are precious carbon sinks.
Cefic welcomes the Commissions initiative to develop a regulatory framework for the certification of carbon removals. Cefic hopes this initiative will pave the way for recognizing the contribution of technological solutions to carbon removals: the Commissions long-term strategy which underpins the EU Climate Law clearly emphasizes the role of industrial removals solutions for the achievement of the…
Airbus comments on the Proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework for carbon removal In line with the IPCC special report on 1.5°C, IPCC AR6 and ATAG Waypoint 2050 on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, Airbus considers that carbon removals will be important…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
TO.23.01 TomatoEurope Position Paper on the proposal for a Regulation establishing a Union certification framework for carbon removals The tomato processing sector is seriously committed to sustainability and decarbonization and continuously works to apply the best available techniques to improve its energy efficiency and reduce its carbon footprint.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Mar 2023 · source
The Confederation of Norwegian Enterprise welcomes the opportunity to comment on the proposed EU rules on the certification of carbon removals. We support the development of such a scheme and would like to offer some input considering the forthcoming legislative process.
Response to the Commission proposal for a Certification of Carbon Removals Brussels, 23 March 2023 The European Insulation Manufacturers Association (Eurima) supports the development of ambitious policies fostering the achievement of a sustainable built environment based on significant emissions reduction targets for buildings and the broader construction ecosystem.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEAD welcomes the development of EU rules for the certification of carbon removals to support the achievement of the EU climate targets. To reach climate neutrality by 2050, carbon capture, utilisation and storage (CCUS) and carbon recycling solutions are needed.
The TechEthos project welcomes the opportunity to provide feedback on the European Commissions proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework for carbon removals.
Issues to be improved: 1) Use of adequate terminology: Overall, it is important to differentiate between carbon (C) & CO2-removal activities. These terms are frequently not adequately used. Especially as regards CCS, this is usually explained as carbon capture and sequestration (long-term storage), instead it should be explained as CO2 capture & sequestration to better describe the technological procedure.
CCSA response to the call for feedback on the adopted proposal for a regulation establishing a Union certification framework for carbon removals 23rd March 2023 The Carbon Capture and Storage Association (CCSA) represent members across the CCUS value chain, and represent members interested in deploying projects which can achieve the at scale, permanent removal of carbon dioxide through engineered solutions such as…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECVC does not welcome positively the current CRCF proposal as it ignores serious concerns it addressed to the EC: https://lstu.fr/letter-cf-ecvc Here ECVC will focus on elements related to land and agriculture. The recent release of the IPCC report was an alarming reminder of the climate change crises we face.
· · filed 23 Mar 2023 · source
The European Consortium of the Organic-Based Fertilizer Industry (ECOFI) welcomes the intention of the Commission to expand sustainable carbon removals and encourage the use of innovative solutions to capture, recycle and store CO2 by farmers, foresters and industries with this proposal for a regulation.
Waste-to-Energy (WtE), waste incineration with energy recovery, provides a sanitary service to communities by treating residual waste that cannot be prevented or recycled. There are ca. 500 plants in Europe treating around 100 million tonnes of residual, non-recyclable waste every year, from municipal but also commercial and industrial activities.
· · filed 23 Mar 2023 · source
Farmers, foresters and land managers have high expectations about the development of a new economic model linked to carbon carbon in soils. This is because the sustainable management of agricultural and forestry systems is the only productive activity capable of removing carbon dioxide from the atmosphere by permanently incorporating it into soils and plants, thus compensating for residual CO2 emissions from other…
Filed in Italian · English published by the European Commission
Our first general impression is that this proposal answers the need of a European certification framework for carbon, in order to accelerate the implementation of low carbon practices and to capture, recycle and store CO2 by farmers, forests and industries so as to achieve by 2050 the carbon neutrality. Positive aspects are for us the robustness of this certification.
Synthèse en réponse à la consultation « Carbon Farming » – Interbev L’enjeu climatique est une priorité au niveau européen et français. Il constitue également un axe fort des stratégies mises en œuvre pour assurer la transition des systèmes agricoles.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Puro.earth is a carbon removal crediting platform and through the Puro Standard, we create and verify robust science-based methodologies for removal of CO2 from the atmosphere. Puro issues CO2 Removal Certificates, CORCs, per ton of CO2 removed and durably stored. CORCs are issued and retired in the public Puro Registry, adding transparency to carbon markets.
The Zero Emissions Platform (ZEP) welcomes the initiative to establish a certification framework for carbon removal activities, seeing it as a first step towards the establishment of a flourishing market that instils trust in carbon credits. We are pleased to provide our input, which can be found in the attached document.
Please find a more detailed version in German in the attachment. German Environmental Aid recognises the opportunity to comment on the EU Commission’s CRCF proposal and welcomes in the idea to create a mechanism to financially reward carbon removals through sustainable land management.
Filed in German · English published by the European Commission
Hafslund Oslo Celsio (hereafter Celsio) welcomes the EUs ambition to develop a high-quality certification for carbon removals. Achieving climate neutrality by 2050 and negative emissions thereafter will require both carbon reductions and removals at unprecedented scale across Europe; and the Commissions proposal is a crucial first step towards a much-needed pan-European market for high-quality carbon removal…
Fertilizers Europe welcomes the European Commissions ambition to promote sustainable farming practices and to define a framework to verify, report and monitor carbon removals. The proposal represents a promising step toward the development of a regulated market for carbon farming.
· · filed 23 Mar 2023 · source
Friends of the Earth International and Friends of the Earth Europe’s joint response to the European Commission’s consultation on its proposed Carbon Removals Certification Framework At the outset, Friends of the Earth International and Friends of the Earth Europe reiterate their full opposition to large scale carbon removals, offsets and carbon markets for the demonstrated harm to the rights of Indigenous Peoples…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
While climate mitigation has to clearly prioritize absolute emissions reductions, the trend of declining carbon stocks in EU soils should be reversed and carbon sequestration should be incentivized. The organic movement believes that a certification framework for carbon removals should contribute to transition farming systems towards sustainability and prevent greenwashing.
The Swedish Forest Industries Federation welcomes a certification of carbon removals to further incentivice forest based climate solutions, and proposes recommendations for how to improve the framework to make it more implementable and focused on the core objective of removing carbon.
DUDECHEM GmbH | www.dudechem.com | Köpenicker Str. 325 Haus 11-12 | 12555 Berlin | Germany Ref. Ares(2023)2121089 - 23/03/2023 Feedback on Certification of Carbon Removals – EU Rules Integrity of the Regulation and Voluntary Carbon Markets Effective carbon removal schemes will be essential in order to meet the targets laid out in the Paris Accords and avoid even worse impacts from climate change.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
What science says is clear: we need to remove carbon from the atmosphere in this century to keep global warming below 1.5 °C. The role of carbon removals in pursuing the goals of the Paris Agreement is undeniable, but the burden of climate action remains in a deep and comprehensive emission reduction for all sectors, not least because removals should be complementary and not substitute for emission reductions at…
Filed in Portuguese · English published by the European Commission
Thank you for the opportunity to respond to the European Union Carbon Removal Certification Framework, and to discuss the role the European Union can play in the fight against climate change. Running Tide's full feedback is attached below, and includes several key points summarized below: 1) On the definition of carbon removal - We suggest removing activities that lead to the reduction of carbon release from the…
SUEZ welcomes the European Commissions proposal on the Carbon Removal Certification and the will of the European Commission to create an efficient and voluntary European market on Carbon removal certification. In this position paper SUEZ wants to highlight three major carbon removals methods that should be better promoted considering their positive impact: Bioenergy Carbon Capture and Storage (BECCS), biochar and…
We welcome the thorough and comprehensive process of stakeholders and the ongoing research and dialogue on the key elements of the future European framework aimed at increasing carbon dioxide removal. This will impact the project area, and it is expected that farmers will be able to start practicing nature-based carbon sequestration-supported farming practices under more favorable conditions from the perspective of…
As Coldiretti, we welcomed with interest the European Commission’s new proposal on carbon capture, which for the first time proposes a certification of carbon that is captured and stored thanks to various activities carried out by the agricultural sector. Loccasion is therefore important and you cannot be allowed to waste it.
Filed in Italian · English published by the European Commission
EuLA, the European Lime Association, represents European non-captive lime production through its 20 covered Member States (companies & national associations). Lime is one of the essential building blocks of modern industry.
Carbo Culture welcomes the European Commission's proposal for a European Carbon Removal Certification Framework. High-quality carbon removals play a crucial role to avoid overshooting climate targets and reaching net zero emissions.
AREV supports the EU’s climate commitments, namely: a -55 % reduction in emissions by 2030 and a climate neutral impact in the land use sector for forestry and agriculture by 2035. In this context, AREV welcomes the proposed EU certification framework for carbon removal.
Filed in French · English published by the European Commission
Perspectives Climate Research welcomes and supports the European Commission's initiative to develop a certification for carbon removal technologies with the overall aim of achieving the goals of the Paris Agreement and the European Union's own climate neutrality ambition.
AssoFertilisers – Federchimica welcomes the Commission’s ambitions to promote sustainable farming practices and the adoption of measures that can verify, document and monitor carbon sequestration from the atmosphere. The legislative proposal represents a promising step forward in developing a regulated market for carbon farming.
Filed in Italian · English published by the European Commission
Perstorp welcomes the European Commissions proposal COM(2022) 672 final with an aim of establishing a Union Certification Framework for Carbon Removals. To support and harmonize the methodology of carbon removals will be essential for the EU to reach its climate objectives.
Repsol welcomes the Commissions initiative to develop a regulatory framework for the certification of carbon removals to deploy a harmonized EU certification system to ensure the role of carbon removal solutions, both nature-based and technology-based, necessary to contribute to achieve the EUs climate targets.
IBERDROLA welcomes the Proposal for a Regulation on a Union certification for carbon removals as a unique opportunity to set a proper regulatory framework for an EU-wide robust system to complement mitigation efforts and reach the net-zero ambitions.
Cibola Partners welcomes and supports the initiative on the certification of carbon removal solutions, as a milestone in achieving climate neutrality by 2050. As a carbon finance advisory firm aiming to connect both sides of the regulated carbon market to cut greenhouse gas emissions, Cibola Partners upholds the scope and reach of this proposal which sets a clear and reliable standard for carbon removal projects.
ICL Group welcomes the European Commission proposal for a Regulation establishing a Union certification framework for carbon removals (COM(2022) 672). The proposal represents a positive starting point for an EU harmonised voluntary and regulated market for carbon removals and especially carbon farming. ICL Group believes carbon removals are useful to mitigate climate change and to reach net zero emission.
In 2019, France set up a certification system to promote projects aimed at reducing emissions and sequestering carbon: the Low Carbon Label. The proposal for a European regulation, in which the methods will be developed by the Commission, therefore raises the question of what will happen to the methods of the French Label, or even the Label itself.
Cogeca welcomes the Commissions efforts to create a unified and harmonized system across the EU, capable of providing a reliable and trustworthy system to promote a further uptake of carbon farming activities. Agri-cooperatives are part of the solution to fight climate change through storing carbon in the soil and biomass.
· · filed 23 Mar 2023 · source
Vantaa Energy thanks the Commission for the opportunity to provide feedback on its proposal for a Regulation establishing a Union certification framework for carbon removals COM(2022) 672 final. The proposal is a welcome tool for incentivizing investments in carbon removals, which will be vital for achieving the Unions climate targets.
Bellona Europa is an independent, non-profit organisation that meets environmental and climate challenges head on. We are solutions-oriented and have a comprehensive and cross-sectoral approach to assess the economics, climate impacts and technical feasibility of necessary climate actions. To do this, we work with civil society, academia, governments, institutions, and industries.
Copa welcomes the Commissions efforts to create a unified and harmonized system across the EU, capable of providing a reliable and trustworthy system to promote a further uptake of carbon farming activities. European farmers and foresters are part of the solution to fight climate change through storing carbon in the soil and biomass.
Carbon Gap welcomes the European Commissions proposal for a carbon removal certification framework as a first and significant step toward robust certification, and ultimately, for the necessary upscaling of carbon removals (CDR) to meet EU and global climate change mitigation targets.
ECOERA's Response to the Carbon Removal Certification Framework (CRCF) Proposal - March 23, 2023. ECOERA is encouraging and supports the European Commission's initiative for a Carbon Removal Certification Framework. High-quality and durable carbon removals are vital for climate neutrality, and it's essential to set ambitious goals and standards.
· · filed 23 Mar 2023 · source
WWF Germany is very critical about the proposal for a Union certification framework for carbon removals. WWF Germany fears that the proposal gives opportunities for companies to simply clean-balance their continued emissions with allowances from carbon removals. The regulation must not undermine the necessary mitigation efforts in such a way.
· · filed 23 Mar 2023 · source
Aker Carbon Capture welcomes the European Commission initiative to establish the Carbon Removal Certificate Framework (CRCF), a framework for ensuring high quality carbon removals in the EU, and shape an EU governance certification system, which will adhere to the EU quality framework criteria in a reliable way.
Shell response: Certification of carbon removals – EU rules EU Transparency Register: 05032108616-26 23 March 2023 Shelli welcomes the proposal for an EU Carbon Removals Certification Framework (CRCF), as an important first step to support the development of carbon removal projects in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The International Climate Change Solutions Ltd. welcomes the opportunity to contribute to the proposed EU legislation on carbon dioxide removal certification. We believe it is important to establish high-quality, EU-wide standards for carbon dioxide removal. The attached document contains our comments on the key factors that should be taken into account in the legislation.
The Bundesdruckerei Group welcomes the proposal for a regulation establishing a Union certification framework for carbon removals and gladly provides feedback to the European Commission. The Bundesdruckerei Group has identified a number of differences between the requirements formulated in the explanatory memorandum to the act and the proposed method of implementation.
Statement of the Association of the Austrian Wood Industries on the Proposal for a Regulation establishing a Union certification framework for carbon removals General information: The Association of the Austrian Wood Industries welcomes in principle the Union framework for the certification of CO2 removals, in which quality criteria and rules for verification and certification as well as for the operation of…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Aluminium production is identified as a hard-to-abate sector. The aluminium process is already fully electrified and European producers are amongst the most energy efficient in the world. Hydro is committed to achieving net-zero CO2e emissions by 2050 or earlier.
ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. Their primary purpose is the hygienic treatment of non-recyclable waste from which we recover partially renewable heat and electricity.
The proposal to set up a European Union certification framework for carbon removals represents a unique opportunity to add value to products and activities which systemically promote decarbonisation and the protection of natural resources from pollution and depletion.
The IKEA brand represented here by Inter IKEA Group and Ingka Group is driven by our vision to create a better everyday life for the many people and the IKEA Sustainability Strategy. We at IKEA are committed to become climate positive by 2030, by reducing more greenhouse gas emissions than the IKEA value chain emits, while growing the IKEA business and without the use of carbon offsets.
Vattenfall welcomes the European Commissions legislative proposal on anEU-wide certification framework for carbon removals. A centralised and robust certificate framework governed by the European Commission, will increase regulatory clarity, confidence among investors and the public, and will have the best prospects of becoming a recognised and trusted instrument, thereby attracting more financing.
Feedback on the proposal for a regulation establishing a Union certification framework for carbon removals Bioenergy ry - the Bioenergy Association of Finland welcomes the Commission’s proposal for a carbon removal certification framework. There is a wide consensus globally that the emissions reductions alone will not be sufficient for us to reach our climate goals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Mar 2023 · source
Green Transition Denmark welcomes the opportunity to provide feedback on the Commissions proposal for CRCF. CARBON FARMING IS ILL-SUITED FOR CERTIFICATION The definition of carbon farming needs to be clarified. Emission reductions from the land sector can be certified as removals under the current definition of carbon farming, which is counterfactual and goes against the findings of the Impact Assessment.
ba sss ssssss s Position paper Proposal on an EU Carbon Removal Regulation VDZ (Verein Deutscher Zementwerke) as the representation of the German cement industry welcomes the EU Commission's proposal on a Carbon Removal Regulation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The numbers below refer to the paragraph in the proposal (not the article): (7) A baseline is not always needed. To use long-lived wooden construction products as a carbon uptake measure, Continuous Cover Forestry certificates can serve as the quality guarantee. The CCF certificate ensures that a certain amount (tons) of primary woody biomass is produced using Continuous Cover Forestry.
Feedback on the EU Commission's’ Proposal for a Carbon Removal Certification Framework, March 2023 The Negative Emissions Platform welcomes the Commission’s proposal for a Carbon Removal Certification - Framework (CRC-F) to develop high-quality carbon removals in Europe and enable climate neutrality. The proposal makes for a much-needed certification framework.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Read needs a strategy to support the implementation and deployment of carbon mitigation solutions commensurate with its climate ambitions. The challenges for Europe are considerable: make it possible to achieve a climate neutral balance in the land use sector for forestry and agriculture by 2035.
Filed in French · English published by the European Commission
We are deeply concerned about the proposal for a certification framework for carbon removals. Its primary purpose is to facilitate carbon offsets which will inevitably legitimise additional fossil fuel burning, at a time fossil fuel burning and other sources of carbon emissions must be rapidly reduced.
Carbon Engineering’s response to the Carbon Removal Certification Framework Why Carbon Dioxide Removal - CDR? The IPCC’s summary for policy makers on climate change mitigation states that “The deployment of CDR to counterbalance hard-to-abate residual emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved”.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome the European Unions aim to reach climate neutrality by 2050 by the latest and the proposal of the European Commission to establish a certification framework for carbon removals that is in line with the sustainability goals and existing policy provisions. We especially welcome the QU.A.L.ITY (quantification, additionality, long-term storage, and sustainability) concept as starting point of the framework.
The Bundesverband Bioenergie e.V. (BBE) welcomes the initiative to establish a certification framework for CO2 removals. The storage of biogenic carbon in long-lived wood products, vegetable carbon or captured liquid or gaseous CO2 is an indispensable enabler for the EU’s plans to achieve net-zero greenhouse gas emissions by 2050 and subsequently to deliver negative emissions.
Filed in German · English published by the European Commission
· · filed 23 Mar 2023 · source
The TÜV Association welcomes the EU Commissions proposal for a Regulation establishing a Union certification framework for carbon removals. Carbon removal is crucial for achieving the EUs climate targets. Both carbon removal options, nature-based (NBS) and technology-based solutions (TBS), need to be massively scaled up.
The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to give feedback to the European Commissions proposal for a Carbon Removal Certification Framework. We would like to highlight twelve major concerns about the proposal and urge the European Commission to consider those moving forward: 1.
Wetlands International Europe would like to share its feedback on the proposal for EU rules on the certification of carbon removals. Wetlands International Europe welcomes the Commission's initiative to propose harmonised rules at EU level.
We welcome the proposal of the European Commission to establish a certification framework for carbon removals and the possibility to give feedback to it. The certification framework proposal of the European Commission introduces the QU.A.L.ITY criteria which relate to quantification, additionality, long-term storage, and sustainability, which we welcome as a starting point.
The Dutch Dairy Association (NZO), representing the Dutch Dairy Industry, supports the contribution of the European Dairy Association on the consultation of the proposal EU-rules for the certification of carbon removals.
The EU is pursuing a number of approaches to achieving its ambitious climate targets, with CO2 sequestering in particular as a means of achieving targets, in addition to avoiding greenhouse gas emissions. In order to compensate for residual emissions that are difficult to reduce, CO2 removals from the atmosphere and permanent storage in geological reservoirs, ecosystems or products are necessary.
Filed in German · English published by the European Commission
We welcome the Commissions proposal for establishing a certification framework for carbon removals and the possibility to give feedback on the topic. As a forest industry company we support the European Unions ambition to combat the climate change as well as maintain and ensure the recovery path of Europes biodiversity. As a part of these targets carbon sequestration plays a significant role.
ENGIEs POSITION ENGIE's full position in the attached file. 1. Introduction : ENGIE welcomes the European Commissions initiative to deploy a harmonised, robust and reliable EU certification system of carbon removals, both nature-based and technology-based, which are both needed to reach the EU carbon neutrality target, ENGIE believes that the Regulation should be put it in place rapidly, at least for BECCS and…
Eurogas welcomes the European Commissions (EC) ambition to deploy a harmonised EU certification system to ensure the role of carbon removals solutions, both nature-based and technology-based, necessary to contribute to achieving the EU climate targets. Eurogas firmly believes that the Regulation on the certification of carbon removals (the Regulation) should provide legal and financial certainty to the industry.
FEP the European Parquet Federation is warmly welcoming the European Commission proposal for a Regulation establishing a Union certification framework for carbon removals, and the possibility to comment it. We also welcome the recognition of the carbon stored in long-life wood products such as parquet - although we would welcome more detailed delegated and implementing acts as well.
To Whom It May Concern Carbon removals in the cement and concrete value chain offer significant potential to support the EUs transition to carbon neutrality. In OFICEMENs view, it is essential that the EU carbon removal framework is based on a science-based approach and clear definitions.
Ørsted warmly welcomes the EU Commission's initiative to develop a common EU certification scheme for projects that deliver carbon removals. The company views this as a significant step towards enhancing market credibility by establishing a common and ambitious regulation, which is crucial for carbon removals to become an integral part of the solution to climate change.
Conservation International (CI) welcomes the initiative of the European Commission to propose EU rules on certifying carbon removals. As the most recent IPCC report has reiterated, removing CO2 is a requirement in addition to immediate emissions reductions in order for climate targets to be reached.
Bioenergy Europe welcomes the EC's proposal for a Carbon Removal Certification Framework put forward in November last year with the aim to develop a trustworthy system to quantify and valorize removals and achieve climate neutrality by 2050. The proposal outlines the start of a process, and we support a sound and harmonized governance framework that is much needed for this essential sector.
Reykjavík - March 22, 2023 Feedback from the Algae Association of Iceland on the EU Commission’s proposal on regulation on Certification of Carbon Removals The Algae Association of Iceland (AAI) is an non-governmental organization focused on supporting the growth of a sustainable algae industry in Iceland, knowledge sharing between industry and institutions, and creating public awareness of the possibilities of…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In 2050, Europe will have to be the first carbon-neutral continent and France must be the nation, through its agriculture and massive biomass production, that will enable it to meet this challenge. Agriculture can address the three pillars of carbon neutrality (mitigation, decarbonisation and sequestration) provided that it strengthens the resilience of farming systems to the effects of climate change and increases…
Filed in French · English published by the European Commission
E.ON feedback on the EU Commission’s proposal for carbon removals certification E.ON welcomes the European Commission’s proposal for a Regulation establishing a certification framework for carbon removals. As confirmed by the IPCC, carbon emissions reduction alone will not be sufficient to limit global temperature increase to 1,5°C. Thus carbon removals will play an indispensable part to reach global climate goals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ATLA supports the initiative aimed at establishing common EU standards for carbon removals. Such a business model could be beneficial to speed up carbon removals in agriculture. Carbon sinks such as dairy pasturelands are, amongst others, crucial in the transition towards a carbon neutral EU by 2050, and such contribution should be recognised.
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2023 ERCST’s response to the Commission’s proposal for a Regulation establishing a Union certification framework for carbon removals Andrei Marcu, Elena Bonfiglio European Roundtable on Climate Change and Sustainable Transition ERCST ERCST’s response to the Commission’s proposal for a Regulation establishing a Union certification framework for carbon removals The European Roundtable on Climate Change and Sustainable…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
VKS represents the German Potash and Salt producing companies. VKS welcomes the EU proposal for a Certification Framework for Carbon Removals published by the European Commission on 30 November 2020. To ensure a successful implementation of the proposed framework VKS asks the European institutions to take the attached comments into account.
Almost all scenarios demonstrate: negative emissions are needed to achieve the objectives of the Paris Agreement to limit the global temperature increase to well below 2 degrees Celsius while pursuing efforts to limit the increase to 1.5 degrees. Also for the EU's goal of becoming climate-neutral by 2050, negative emissions are essential.
CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 85 members along the CCU value chain, from CO2 producers, converters and users of CCU products to researchers and project developers.
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Finnish Landowners' Association considers Proposal for a regulation for certification of carbon removals to be generally acceptable and considers that, if implemented, it will promote the functioning of the European voluntary carbon market. The Association emphasizes the utmost importance of resolving double counting. 1. The Proposal for a Regulation is acceptable and can be supported.
FEFAC represents the European compound feed & premixes production industry. We have been putting a lot of efforts in tool creation to measure the carbon footprint of compound feed sourcing & production, which represents the majority share of the carbon footprint of in particular pig, poultry and fish farming.
The Federal Association of Energy and Water Management (Bundesverband der Energie- und Wasserwirtschaft BDEW e.V.) represents the interests of a large number of undertakings which, independently or in cooperation with other market participants, are able to carry out CO2 abstraction projects, can supply electricity, hydrogen or other energy carriers for carrying out such projects, or which wish to use the carbon…
Filed in German · English published by the European Commission
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Statement by Hiilensidonta ry (Carbon Sink Federation Finland) Hiilensidonta ry association represents 12 companies specializing in carbon sequestration for the voluntary market in Finnish forestry and agriculture.
This initiative will propose EU rules on certifying carbon removals. It will develop the necessary rules to monitor, report and verify the authenticity of these removals. The aim is to expand sustainable carbon removals and encourage the use of innovative solutions to capture, recycle and store CO2 by farmers, foresters, and industries.
The Austrian Raiffeisen Association welcomes the Commission’s initiative to create uniform standards in the area of carbon removals. In order to meet the climate targets, reducing emissions is always a priority and first, but it also needs rules on how to deal with offsets. This increases transparency and certainty for companies.
Filed in German · English published by the European Commission
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The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the ECs proposal for the EU Certification of Carbon Removals Framework. There is a clear need for the framework, and the lack of EU-level framework is holding the development at the member state level. We support the scope of the proposal.
Comments on the European Commission's proposal: certification of carbon removal Sylvestris has the following comments: Sylvestris welcomes the Commission's initiative and welcomes the regulatory development that is being proposed for a new common framework at European level for the certification of carbon sequestration.
EJPSOIL Comments on the proposal for a regulation of the European Parliament and of the Council establishing a Union certification framework for carbon removals COM(2022) 672 final Irene Criscuoli, Francesco Galioto, Francesca Varia, Giovanni Dara Guccione, Ilaria Falconi, Andrea Martelli, Maria Valentina Lasorella, Martin Hvarregaard Thorsøe, Claire Chenu on behalf of EJP SOIL Programme and Road4Schemes project EJP…
CERTIFYING EU ACTIVITIES TO INCREASE CARBON REMOVALS FROM LAND M A R C H 2 0 2 3 - N G O P O L I C Y PA P E R F or agricultural and forested land, the KEY RECOMMENDATIONS aims of the European Commission’s proposed voluntary EU Carbon Removal • Ban carbon offsetting and only allow the Certification Framework (CRCF) include: certification of land-use activities (activity- − Increasing carbon removals by establishing…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Japan Business Council in Europe (JBCE) appreciates the opportunity to provide comments on the Commission proposal for the regulation of Carbon Removal Certification. JBCE believes the proposed regulation is an important step in stimulating the markets for carbon removals and achieving the goal of carbon neutrality. Nevertheless, we would like to feedback as detailed in the two points below.
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The Danish Dairy Board Brussels s.a. welcomes the consultation on certification of carbon EU rules. We refer to our consultation reply in the Commission public consultation Call for evidence for an impact assessment of 2022.
DNV welcomes the Commissions effort to develop a reliable, transparent and high-quality certification system for carbon removal technologies within the EU in addition to the significant mitigation work already in place and in the making.
Member of European Chemical Industry Council CEFIC Warsaw, 21.03.2023 PIPC/15/2023 Certification of carbon removals – EU rules Project: Certification of carbon removals – EU rules Regarding ongoing public consultations, Certification of carbon removals – EU rules, the Polish Chamber of Chemical Industry, on behalf of associated entities, submits its comments in the attached table of comments.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
For the production of mineral building materials such as cement/concrete or lime, limestone is converted to calcium oxide at very high temperatures up to 1.450 °C. Parts of the CO2 released during production are re-absorbed by the built environment. The same process of ‘carbonisation’ takes place in virtually all applications of lime (lime as a slag-former, drinking water treatment, lime plaster).
Filed in German · English published by the European Commission
EARSC Statement Proposal for a Regulation for a certification framework for carbon removals The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, representing the European downstream services sector. EARSC counts more than 135 members across 25 countries of Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Horisont Energi welcomes the European Commissions proposal for carbon removal certification. As confirmed by the IPCC, carbon emissions reduction alone will not be sufficient to limit global temperature increase to 1,5°C. Thus carbon removals will play an indispensable part to reach global climate goals.
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PUBLIC CONSULTATION ON DRAFT PROPOSAL (by several stakeholders of a consortium: K+S, Agravis, Novihum, Klima Humus, CO2-Land, DLG, Klim, BayWa, Food Roots, BAT Agrar) "Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a Union certification framework for carbon removals." REGARDING CARBON FARMING AS POINT OF INTEREST Preamble: Based on the concerns expressed in the proposal (e. g.
Indigo welcomes the European Commission`s legislative proposal for a regulatory framework for the certification of high integrity carbon removals. We believe that certified carbon removals can make a meaningful contribution to climate change mitigation and enable agriculture to be part of the climate solution, but certification must be backed by science, high-quality standards, and rigorous methodologies.
Carbonfutures statement on the European Commission's proposal - March 14, 2023 / / / We welcome the Commission's proposal for a European Carbon Removal Certification Framework. High-quality carbon removals will play a crucial role to enable climate neutrality and it is therefore important to ensure the right level of ambition and high standards are set from the beginning.
France has the experience of the Low Carbon Label: since 2018, this label has certified about 1650 ha of forest projects for nearly 0.73 million tons of CO2. The National Forest Office welcomes the proposal for a European certification framework that can bring this experience more widely and allow funding for sustainable forest management, in the difficult context of climate change.
We welcome the European Commissions proposal for a Carbon Removal Certification Framework (CRCF) put forward in November last year with the aim to develop a trustworthy system to quantify and valorise removals and achieve climate neutrality by 2050. The proposal outlines the start of a process that is much needed for this essential sector.
Carbon removals in the cement and concrete value chain offer significant potential to support the EUs transition to carbon neutrality. In CEMBUREAUs view, it is essential that the EU carbon removal framework is based on a science-based approach and clear definitions.
EDA supports the initiative aimed at establishing common EU standards for carbon removals. Such a business model could be beneficial to speed up carbon removals in agriculture. Carbon sinks such as dairy pasturelands are, amongst others, crucial in the transition towards a carbon neutral EU by 2050, and such contribution should be recognised.
Thank you to the European Commission and European Parliament of the Council for advancing critical climate action and for proposing rules on certifying carbon removals. We agree that the introduction of a regulatory framework for the certification of carbon removals is a significant step forward and commend the European Commission for scaling the carbon dioxide removal industry.
1 PUBLIC CONSULTATION ON DRAFT PROPOSAL IN GENERAL Today sufficiently transparent, valid and reliable methodologies and standards are still lacking to determine the efficiency of carbon removal and carbon farming measures. Therefore, the European Commission published a proposal for a certification framework for carbon removals as part of the Circular Economy Action Plan of the EU Green Deal.
The Commission's reason for this proposal is comparable to the reason in 2017 for starting a Green Deal Pilot National Carbon Market in the Netherlands and later, in 2019, establishing Stichting Nationale Koolstofmarkt (SNK): the risk of fragmentation of calculation rules for determining emission reduction or carbon sequestration.
Finnish Forest Industries Federation (FFIF) welcomes the possibility to provide feedback on the proposal for establishing a certification framework for carbon removals. Why our industry is in the sweet spot of carbon removals? 1. Technological sinks: Our industry manufacturers various wood-based products, but we also produce bioenergy from low quality wood (so called side streams).
The European Carbon Farmers is fully supportive of the EU Certification of Carbon Removals Framework yet highly concerned with the lack of leadership at the EU Commission level in creating a bridge between the Common Agricultural Policy of the EU and its climate ambitions. We believe - and present - there is a specific way to address this concern.
· · filed 20 Mar 2023 · source
Arla Foods welcomes the opportunity to provide input to the European Unions certification of carbon removals and supports the Commissions overarching initiative to develop a common certification framework to incentivize farmers to increase the level of carbon removals.
The European Commission recognises carbon removals as a crucial element in the fight against climate change and includes it in the climate law to achieve climate neutrality by 2050. The European Landowners Organization (ELO) supports this important first step in the process of creating a robust voluntary market for carbon removals, built on existing schemes, which could bring various benefits for landowners.
FoodDrinkEurope welcomes and provides the attached feedback to the European Commissions proposal for a regulation establishing a Union certification framework for carbon removals. 1. The proposal must clarify the intended use of certificates and prioritise the agri-food chain decarbonisation for removals generated by carbon farming.
ECOLOG welcomes the European Commissions new regulatory proposal establishing a Union certification framework for carbon removals. Pragmatic and fit-for-purpose regulation coupled with financial support for carbon removal technologies and practices, including Carbon Capture and Storage (CCS), is vital to ensure the European Union and its Member States can achieve the Unions ambitious net-zero climate goals by 2050.
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The European Starch Industry Association, Starch Europe, represents the EU starch industry both at European and international level. Its membership comprises 30 EU starch producing companies, together representing more than 95% of the EU starch industry, as well as 6 national starch industry associations in associate membership.
The Confederation of European Paper Industries (Cepi) welcomes the possibility to provide feedback on the proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework for carbon removals. Cepi welcomes the proposal as a first crucial step towards the recognition of biogenic carbon cycles and of their role for climate change mitigation.
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In general, we believe that this proposal should be rejected if not strongly strengthened, as: The proposal has too many shortcomings and a potential risk of carbon storage and removals standing in place of reductions, which is deeply worrying. Reductions in carbon emissions cannot be equated with carbon removals and storage. BECCS based on wood-based biomass should not be certified.
Filed in Danish · English published by the European Commission
Having assessed the Proposal for establishing a Union certification framework for carbon removals (CRCF), ECOS would like to highlight some fundamental features we consider highly problematic and that need to be taken into account to ensure the proposed framework is trustworthy and avoids greenwashing. 1. Prioritisation and definitions: a.
Drax welcomes the European Commission initiative to set up an EU-wide and robust certification system for carbon removals. Subject to appropriate methodologies, this framework will provide greater certainty, transparency and clarity for the industry and investors.
Carbon removals are welcome and necessary We need to urgently address climate change and live within the planetary boundaries. Stora Enso, therefore, supports the EUs plans to develop a voluntary Union certification framework for carbon removals. It is important to incentivise the uptake of carbon storage and ensure that when doing so, removals are quantified in an accurate and robust manner.
[Please see attachment for full response] Equinor welcomes the EUs ambition to develop a high-quality certification for carbon removals. Achieving climate neutrality by 2050 and negative emissions thereafter will require both carbon reductions and removals at unprecedented scale across Europe; and the Commissions proposal is a crucial first step towards a much-needed pan-European market for high-quality carbon…
European Commission DG CLIMA.C3 Brussels, 20 March 2023 EPF feedback on the Proposal for a Regulation establishing a Union certification framework for carbon removals COM(2022) 672 The European Panel Federation (EPF) welcomes the possibility to provide feedback on following the publication of the Proposal for a Regulation of the European Parliament and of the Council establishing a Union certification framework for…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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European Forum NORTHERN SWEDEN The four northernmost counties in Sweden are working together to influence EU policy through the political network European Forum Northern Sweden (EFNS). The work in EFNS is based on common interest and commitments from regional and local politicians and officials.
Filed in Swedish · English published by the European Commission
Carbon Direct applauds the EU for its recognition of the role of carbon dioxide removal (CDR) in achieving climate neutrality across the EU by 2050. In particular, we support the EU Sustainable Carbon Cycles (SCC) initiative and welcome the proposed regulation for the EU CRC-M certification mechanism.
Assomela, the Italian Association of Apple Producers, welcomes the possibility to comment on the proposal for a regulation on carbon removal certifications. The Italian apple sector works actively on monitoring the carbon footprint of the productions with the goal to apply agronomic techniques and measures that increase the sustainable performance of the cultivations, either by increasing the capacity to store…
The German Chemical Industry Association (VCI) welcomes the efforts of the European Commission to create a market for certificates for carbon removal. German chemical industry supports the European target to become climate neutral in 2050.
Komentář Hospodářské komory České republiky k Návrhu NAŘÍZENÍ EVROPSKÉHO PARLAMENTU A RADY, kterým se zřizuje rámec Unie pro certifikaci pohlcování uhlíku Konkrétní připomínky k Návrhu Nařízení: Bod 6, strana 2 Použitý termín „long-term storage“ není v návrhu specifikován. V návrhu je definován pouze termín“ Permanent carbon storage“.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Bayer welcomes the European Commission proposal for a Regulation on the certification of carbon removals (COM(2022) 672). The proposal provides a solid starting point for an EU harmonised voluntary framework. In time, it could function as a basis for a compliance system. It addresses the most relevant quality criteria in general provisions.
Proposal for a Regulation establishing a Union certification framework for carbon removals Avril Position - March 2023 Avril welcomes the Commission's desire to define a harmonised framework for carbon certification. Carbon removals and emission reductions are expected to jointly play a key role in the fight against climate change.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The CRCF proposal shares many advantages and shortcomings with the French initiative "Label Bas Carbone", which was designed to encourage private companies to finance carbon removal, and which has proven to certify inefficient projects and support corporate greenwashing. Below are some suggestions to avoid such negative outcomes.
On behalf of Eurelectric, the association representing the European electricity industry, I would like to submit for your consideration our views with regards to carbon removals: Eurelectric welcomes and supports the European Commission initiative to prepare a robust, EU-wide certification system for carbon removals to complement mitigation efforts and reach the net-zero ambition.
EU carbon removals certification should incentivize long-term climate benefits over short term carbon offsets: EUSTAFOR calls for an extra careful approach while setting up a carbon removals certificate system through EU legislation. Such a system cannot serve solely as a tool to offset the emissions of the emitting sectors by natural ecosystems, i.e. forests.
From the viewpoint of the VKU, the proposal for a certification framework for carbon removals is an important step towards achieving the objective of climate neutrality by 2050. Uniform standards are appropriate to objectively ensure the accounting of greenhouse gases in the EU. However, its success from the perspective of the VKU requires an ambitious balancing act.
Filed in German · English published by the European Commission
EEB is the largest network of environmental citizens organisations in Europe. It consists of 180 member organisations in 38 countries, representing some 30 million individual supporters. OFFSETTING DETERS REAL CLIMATE ACTION The recitals imply that the certificates are aimed at voluntary carbon markets to be used as offsets. Offsetting would greatly deter the EU from reducing its actual emissions.
KWS embraces the idea to support activities that lead to a reduction of harmful GHG emissions. The agricultural sector, in particular, has a great potential not only for carbon sequestration, but also for dedicated carbon avoidance measures.
The Confederation of European Forest Owners (CEPF) thanks for the opportunity to give feedback on the proposal for a Regulation establishing a voluntary framework for the certification of carbon removals in the European Union.
CEFS, the European Association of Sugar Manufacturers, takes note of the European Commissions proposal for a regulation on the Certification of Carbon Removals (CCR). Decarbonising the beet sugar supply chain is a priority for our sector. In the field, sugar manufacturers work closely with beet growers to increase sustainability and reduce emissions, including within voluntary certification schemes.
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1. CONTEXT OF THE PROPOSAL Activities storing CO2 from an ETS installation in a storage site permitted under the CCS Directive are explicitly included in the EU ETS Directive and EU ETS allowances must be surrendered in the event of CO2 leakages.
Valmet welcomes the Commissions proposal on the voluntary Certification of Carbon Removals . The Union needs a common framework for the removals; emission reductions only will not keep the EU on path with its Paris Climate commitments, and basic definitions and rules are needed before any larger take off of the removals can take place.
Stockholm Exergi welcomes and endorses the proposal of the EU Commission for a regulation on an EU-wide framework for the certification of negative emissions ("carbon removals"). Stockholm Exergi believes that the proposal and the subsequent work constitute a very important step in promoting the emergence of a voluntary market for trade in negative emissions, which in turn constitutes an essential element of the…
The science is clear that we will need to remove carbon from the atmosphere this century in order to keep global heating below 1.5°C. However, removals must be supplementary to and not a substitute for emission reductions, while differentiating between real and false removal solutions remains crucial.
aESTI welcomes the EU effort to create the conditions for optimum performance of the voluntary carbon market. Two key elements are essential: (1) reliability for each individual transaction on this market and (2) farmer profitability.
FEEDBACK PAPER Date 2023-02-28 Swedenergy feedback on the proposal for a regulation establishing a Union certification framework for carbon removals Swedenergy collects and gives voice to around 400 companies that produce, distribute, sell and store energy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Ragn-Sells and scientists in Estonia have developed an innovative and patented technology to produce precipitated calcium carbonate (PCC) from oil shale ash and carbon dioxide two large waste streams. PCC made from oil shale ash can then be used to produce new products (flooring, paints, and other construction materials), reducing the demand for mining several virgin materials.
In its attachment you can find Value Maritime's full response. The most important takeaways can be found in these three points: Support innovative technologies We would like to suggest you consider including carbon capture utilization technology in the relevant regulatory framework as soon as possible.
European Living Lakes Association (ELLA) Position on the Proposal of the European Commission for the regulation on Carbon Removal Certification Framework. ELLA welcomes the proposal of the European Commission to regulate Carbon Removal via an EU-level certification scheme in order to significantly improve the EU's capacity to quantify, monitor and verify carbon removals.
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This draft Regulation lacks important details that could have a significant impact on the proper application of these rules within the Single Market. The draft Regulation gives the impression that important details will be defined by secondary legislation which will have less public visibility and thus less opportunities for interested parties to provide views or comments on the impacts of this secondary…
Filed in French · English published by the European Commission
Position paper attached. Summary below Introduction Every year, Europeans generate nearly 100 million tonnes of unrecycled waste that is turned into energy. Incineration is an important part of the current waste management system. We at Fortum believe that all carbon belongs in circulation. This means that also emissions are turned into new raw materials. To do this at scale, we need to rethink CO2 in recycling.
FGN welcomes the Commissions initiative to regulate Carbon Removal via an EU-level certification scheme recognising that its necessary to establish a framework for the certification of carbon removals as an essential steppingstone towards achieving a net contribution from carbon removals in line with the EU climate-neutrality objective. But further guarantees are needed to effectively protect and restore nature.
DEPARTMENT CARBON SOLUTIONS Date: 06.02.2023 Feedback to COM on certification of carbon removals – EU rules The Timber Finance Initiative supports the development of a voluntary market for carbon removal solutions. We believe that incentives to implement carbon removal solutions are lacking and that the projects are not economically viable.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Central Union of Agricultural Producers and Forest Owners MTK ry Anssi Kainulainen Ref. Ares(2023)771673 - 02/02/2023 2.2.2023 European Commission Feedback to COM on Certification of Carbon Removals – EU rules Central Union of Agricultural Producers and Forest Owner’s (MTK) considers, that It is a good that the legislative initiative that has been taken is voluntary for operators to participate.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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When describing in European carbon certification framework the additionality principle, e.g. actions that are not business as usual (BAU), Estonian Forest Owners Association emphasizes the need to agree on "business as usual" on European level for land based carbon credits (growing carbon stock, avoided forest conversion to development purposes, re-and afforestation, wetlands restoration, agricultural crop…
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1. On Quantification : Reduction in greenhouse gas emissions resulting from the implementation of the carbon removal activity not in scope of net removals but can be counted as a co-benefit to increase the value of the certificate.
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First and foremost, I would like to congratulate you on the initiative and the regulatory development that is being carried out in this regard. From my position as a researcher, I see that aspects that have been of concern to us for years, related to carbon markets and their accounting and reliability, have yet to be addressed.
Following the First EU Certification of Carbon Removals announcement on the 30th of November 2022, I would like to congratulate the Commission's proposal for what seems a fair and easy-to-implement CDR opportunity for high-quality soil-based carbon credits.
The proposal does not answer key questions when it comes to CDR. This proposal merely establishes a basic framework, leaving key questions unanswered and concepts undefined. The proposal lacks clarity on the role of removals in the EU climate framework which is particularly worrying.
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The French Pyro-gasification Club, part of the Technical Association for Energy and Environment (ATEE) gathers and represents the main stakeholders from the French pyrosis and gasification sectors, throughout their entire value chain (waste managers, process developpers, laboratories, energy companies such as gas network operators).
Climate Foundation Ref. Ares(2022)3382133 - 02/05/2022 3 Little Harbor Road Woods Hole, Massachusetts, 02543 www.climatefoundation.org 2nd May, 2022 To Whom It May Concern: Introduction The Climate Foundation is a US registered 501(C)(3) non-profit organization investigating scaleable nature based solutions to the key challenges of food security, ecosystem regeneration and carbon balance.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Wetlands International European Association and Rewilding Europe urge the EC to value that healthy wetlands, including peatlands, store vast amounts of carbon in their soils and biomass, but they can become a huge source of emissions upon degradation.
CONCITO’s response to the public consultation on the upcoming proposal for a regulation on certification of carbon removals - COM(2021) 800/ Ref. Ares(2022)869812 To reach climate neutrality in the EU by 2050 and to reserve the decreasing carbon sinks, carbon removal solutions together with rapid emissions reduction must be a focus point of EU’s climate policy.
www.bauernverband.de Kurzstellungnahme des Deutschen Bauernverbandes zur Initiative „Certification of carbon removals – EU rules“ Berlin, 05/2022 Der Deutsche Bauernverband dankt für die Möglichkeit zur Stellungnahme bezüglich der Zertifizierung von Kohlenstoffsenken.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Agroecology Europe, the European association promoting agroecology as a set of practices, a science and a movement across Europe, welcomes the opportunity to give feedback on the Commission’s legislative revision on the carbon removal certification framework. Soil is one of the largest reservoirs of carbon, along with the ocean.
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Climeworks encourages the EU to provide a certification framework that is setting both, common minimum standards on MRV and to provide comprehensive rules on the certification of each type of carbon removals. The former is important, since CRC-M projects should be assessed in line with other European policies (e.g.
Date: May 02, 2022 Ref: Ares(2022)869812 Subject: Call for Evidence-Certification of Carbon Removals. The Almond Board of California (ABC) welcomes the opportunity to provide input on the ongoing call for evidence regarding certifying carbon removals. The ABC works to provide regulators with a better understanding of how specific issues impact the California almond industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Climate Farmers UG and the European Carbon Farmers Sp. z o.o. – two European organizations founded on the shared pain of seeing farmers’ livelihoods and natural capital deteriorate working in a partnership with a singular objective of supporting farmers’ alignment with nature in a profitable way for the farmers – are grateful for the opportunity to provide feedback in the public consultation conducted by the…
Climate Farmers UG and the European Carbon Farmers Sp. z o.o. – two European organizations founded on the shared pain of seeing farmers’ livelihoods and natural capital deteriorate working in a partnership with a singular objective of supporting farmers’ alignment with nature in a profitable way for the farmers – are grateful for the opportunity to provide feedback in the public consultation conducted by the…
Silicate supports the European Commission’s efforts to develop a robust certification scheme for carbon removal in Europe. The importance of high quality, durable carbon removal and storage to limit warming to 1.5˚C was clearly outlined in the IPCC AR6 WG III report.
Corbion welcomes the recommendation in the Communication on Sustainable Carbon Cycles (Communication) that: "at least 20% of the carbon used in the chemical and plastic products should be from sustainable non-fossil sources by 2030". • Evidence put forward in the annex proofs that this percentage could and should be much higher than 20%!
As nature (not just carbon) related reporting standards become a market norm, it can be expected that mitigation will seek to cover biodiversity and nature related mitigation measures together with carbon and climate targets. This will be critical to demonstrating and achieving commitments to improving impacts on nature and/or reducing exposure to nature loss.
Position paper on certification of carbon removals This position paper makes recommendations for the EU’s carbon removals certification framework. These recommendations are informed directly by some of the EU’s top innovative SMEs specialised in software and hardware-based decarbonisation technologies for enhanced measurement and more effective natural and industrial carbon removals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Both technological and nature based solutions for CO2 removals are crucial to keep within 1,5 degree warming, and need to be scaled up. While technological CO2 removals are permanent and need strong financial instruments, nature based solutions have uncertainties in permanence, but potentially significant co benefits.
We welcome a thorough and comprehensive stakeholder process and continued research and dialogue on the key elements of the future European framework to increase carbon removals and provide financial incentives for more sustainable and climate positive production and land management leading to increased nature-based carbon sinks.
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UPM Kymmene welcomes the initiative of the European Commission for the certification of carbon removal and looks forward having commonly accepted rules for verifying carbon removals. We support to unfold the full potential of the bioeconomy including industrial and nature-based carbon removals as a part of it.
INITIATIVE ON CARBON REMOVAL CERTIFICATION – ERON SYSTEMS ERON FORESTRY LTD. is a for profit company that’s goal is to establish the link between public and independent private stakeholders. We strive to utilize the carbon removal potential in the LULUCF sector in a win-win position.
We welcome the EU's aim to reach climate neutrality by 2050 by the latest and related research on an implementation of carbon dioxide removal on EU scale that is in line with the sustainability goals. The signatories of this feedback are participants of the Carbon Dioxide Removal funding line of the German Federal Ministry of Education and Research (BMBF).
Reply to the European Commission call for evidence for an impact assessment prior to a proposal for a regulation; EU rules on certification of carbon removals The Confederation of Norwegian Enterprise (NHO) and its affiliates welcomes the opportunity to comment on a forthcoming certification scheme for carbon removals and share our experiences with carbon management.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Publieke consultatie Certificering van koolstofverwijdering EU-regels De glastuinbouw levert een belangrijke bijdrage aan een duurzame, gezonde en gelukkige maatschappij. Wij staan garant voor voedselzekerheid en een rijk gevarieerd aanbod aan groenten, fruit, bloemen en planten. Die producten zijn van grote betekenis voor vele miljoenen consumenten in Europa, elke dag.
Filed in Dutch · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The Carbon Capture Company AB in Sweden has a science-based standard for the pricing of the carbon sink. To support and fulfill the Paris Agreement Article 5, it is important that the carbon removal certificate has an economic value to motivate forest owners to increase the forestry carbon sink. The certificate is currently priced at 10 EUR per tonne of sequestrated CO2 in Sweden, and we trade them over the counter.
We welcome the EU's aim to reach climate neutrality by 2050 and this public consultation on how to upscale carbon removal solutions “while ensuring no negative impact on biodiversity or ecosystem deterioration in line with the precautionary and Do No Significant Harm principles” (SCC communication) and recognizing potential co-benefits, as per council conclusions (7728/22).
VLIZ Wandelaarkaai 7 8400 Ostend Tel. [phone removed] www.vliz.be Note Title Response of the Flanders Marine Institute (VLIZ) to the call for evidence for an impact assessment on the certification for carbon removals Authors Steven Dauwe Questioner European Commission – DG CLIMA.C3 Date 2 May 2022 About On 7 February 2022 the European Commission (EC) launched a public consultation to support a proposal for EU rules…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Berlin, 02 May 2022 Call for evidence: EU Carbon Removals Certification Framework The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to give feedback on the planned carbon removal certification framework. We urge the European Commission (EC) to fundamentally rethink its approach on integrating carbon removals into the EU climate framework.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Atmosphere and Climate Competence Center (ACCC, www.acccflagship.fi) is a Finnish Flagship constituted by the University of Helsinki, Tampere University, University of Eastern Finland and the Finnish Meteorological Institute. We are working to address two of the most urgent global Grand Challenges: climate change and deteriorating air quality.
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Carbon removal technologies are necessary to reach ambitious EU climate targets with carbon neutrality by 2050. Most climate models that can reach the target in the Paris agreement to limit global warming to 1.5°C above pre-industrial levels include deployment of negative emissions technologies. Among these technologies, BECCS (bio-CCS) is of utmost importance.
Eni welcomes and strongly supports the initiative of the EU Commissions regarding the certification of carbon removals solutions. Indeed, to achieve the net zero by mid-century and to accomplish a condition of negative emissions beyond 2050 requires an important deployment of carbon dioxide removal (CDR) solutions.
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Eurima recognizes the contribution of carbon removals as a complementary solution to carbon emissions reduction in order to achieve EU Carbon Neutrality by 2050.The dimension of carbon removals needs to be accounted for in a separate manner, in order to not distract from the priority to reduce carbon emissions.
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Provide data that compares GHG release/sequestration for various agricultural processes: Feeding ruminants using rotational grazing Feeding ruminants using feedlots Feeding ruminants using pasturing Corn for human consumption Corn for animal consumption Corn for ethanol production Row crops with tillage practices Row crops with no-till practices Row crops with no-till and cover crops
Founded in 2017, the Fachverband Pflanzenkohle e.V. (FVPK) has a particular focus on charcoal as a negative emission technology and advocates the safe production and environmentally friendly use of charcoal. With over 190 members from academia, nature conservation, agriculture, industry and society, the Association of Plant charcoal represents a wide range of interests in the German-speaking countries of Europe.
Filed in German · English published by the European Commission
The case for permanent carbon removal has been made: - In the Communication on "A Clean Planet for all", the EU Commission outlined the importance of negative emissions within the EU as they shall contribute to the achievement of climate neutrality targets and prepare for a net-negative GHG emission balance thereafter.
Bundesverband Beruflicher Naturschutz e.V. GUT & BÖSEL B E Y O N D F A R M I N G Position statement on soil carbon sequestration and its possible remuneration through CO2 certificates We, the undersigning institutions and individuals, support structural and income-generating efforts to preserve, recover and increase the humus content of agricultural soils.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Response to the EU consultation on the certification of carbon removals The law has been set in the European Union (EU) for economy-wide climate neutrality by 2050. Climate neutrality is essentially emitting the least amount of CO 2 as possible, while compensating for any remaining emissions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Biochar Industry Consortium (EBI) welcomes the Commission’s initiative to elaborate a common European Carbon Removal Certification Mechanism. According to the IPCC, the world and the EU must implement large-scale permanent carbon removal to keep global warming within the targets set by the Paris Agreement.
Public Consultation Response: Agreena ApS Call for Evidence: Certification of Carbon Removals - EU Rules Agreena welcomes the Commission’s proposal on certifying carbon removals as a crucial part of the current EU policy landscape to accelerate the transition to reach climate neutrality by 2050.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Syngenta welcomes the possibility to contribute to the call for evidence launched by the European Commission in the perspective of the preparation of the legislative proposal on a certification for carbon removals. The world needs large scale permanent removal fast and the scientific credibility must be strong to drive investment in the right solution.
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Air Liquide very much welcomes the European Commission’s proposals to make the EU's climate, energy, land use, transport and taxation policies fit for reducing net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels. We firmly believe that all available emission reduction technologies need to be supported in order to reach the EU Green Deal targets.
Carbuna AG welcomes developments on carbon sinks and their certification in the EU. Carbuna AG is a production and trading company founded in 2015 with a focus on charcoal and negative emissions from PyCCS (Pyrogenic Carbon Capture and Storage). Charcoal (biochar) and PyCCS are the most developed negative emission technology (NET) with a Technology Readiness Level (TRL) of 8+.
Filed in German · English published by the European Commission
Lenné Academy for Horticulture and Horticulture e.V. Peter-Lenné-Weg 1 D-14797 Greatberries Bigberries, 02.05.2022 Subject: TGO Agri Carbon Storage 2030 Dear representatives of the European Union, We support the identified standard ACS2030 for determining carbon sinks in agriculture from the TGO feedback (Feedback ref. F3251922).
Filed in German · English published by the European Commission
Introduction Deutsche Säge- und Holzindustrie Bundesverband e.V. (DeSH) welcomes the initiative to certify measures to remove CO2. The raw and wood materials have enormous potential to contribute to climate change mitigation. These potentials need to be fully exploited and rewarded.
Filed in German · English published by the European Commission
Brussels, 2 May 2022 CEI-Bois and EOS feedback as part of the call for evidence on the certification of carbon removals CEI-Bois and EOS support the efforts of the European Commission to produce a ‘Proposal for a regulation’ in the context of the certification of carbon removals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EU carbon removal framework should enable the market value recognition of sustainable farming practices and of the storage and long-term use of biogenic CO2. The European Biogas Association (EBA) supports the initiative of an EU framework for carbon removal certification . The EBA welcomes the plan of the Commission to make a legislative proposal before 2023.
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TomatoEurope Processors Association welcomes the opportunity to provide feedback on the initiatives for the creation of EU rules on certifying carbon removals. The Commission has recently published its Communication on sustainable carbon cycles, which includes proposals that could significantly impact ETS.
Carbon removal solutions are necessary for the EU’s 2050 target. The recent IPCC findings are consistent with this assumption. Key observation on AR6WG3 report is that CDR-methods are valuable and even crucial in the 2030s’to prevent overshoot. Research also points out that postponing CDR beyond mid-century would substantially reduce the removal potential to almost half by end of the century.
EUSTAFOR welcomes the Commission's initiative to discuss the main opportunities and challenges of different solutions for the capture, storage or use of carbon, necessary for reaching the goal of climate neutrality. Before proceeding with identifying the types of carbon removals, the following must be taken into account: 1.
Michael Succow Foundation, partner in Greifswald Mire Centre is welcoming the initiative of the European Commission to set up a Europe-wide Certification sheme of carbon removals. This should also include avaoided emissions eg. from rewetting and restoration of peatlands as the largest terrestial carbon store in the EU, linking to many Member States' climate policies and connected goals.
Neste has replied to the detailed questionnaire in the public consultation. Below we restate some of our high level messages included already in the feedback to the public consultation: Considering the expected scope of carbon removals certification where it would cover only additional removals: the framework should clarify how to link the new scheme to existing regulated certification schemes (e.g.
If done well the CRC-M can determine what is actually CDR or not, and keep false solutions out of this field. Time and resources are scarce and must be invested in real removals, and not in CCU and temporary storage. These may have climate benefits, but that does not make them equal to CDR.
The LIFE Carbon Farming project is a European multi-stakeholder project aiming at reducing by 15% the carbon footprint of mixed crop livestock farms thanks to a result-based system. Fifty partners take part in this project, among them, national leaders are: Idele for France and coordinator of the whole project, Teagasc for Ireland, University of Liège for Belgium, CREA for Italy, ATB for Germany and Asoprovac for…
The Bio-based Industries Consortium (BIC) welcomes the inclusion of sustainably sourced bio-based carbon to replace fossil carbon in the EU Communication on sustainable carbon cycles. The EU bioeconomy is contributing towards sustainable carbon cycles. Carbon removal certification can better demonstrate that contribution.
Carbon Dioxide Removals are necessary, alongside carbon reductions, to achieve the EU’s 2050 target. The Intergovernmental Panel on Climate Change’s (IPCC) findings underscore this assumption: within their 116 scenarios that limited global warming to 1.5°C, negative emission technologies were included in 101 scenarios.
Waste-to-Energy (WtE), waste incineration with energy recovery, provides a sanitary service to communities by treating residual waste that cannot be prevented or recycled. There are ca. 500 plants in Europe treating around 100 million tonnes of residual, non-recyclable waste every year, from municipal but also commercial and industrial activities.
The European Industrial Hemp Association (EIHA) welcomes and fully supports the European Commission’s vision and commits to work with EU bodies with the aim of pursuing the Green Deal objectives and contributing to the recovery of the EU Economy.
CIA — Faroltori Italiani, one of the largest agricultural organisations in Europe that presents Italian farmers and agricultural business owners, welcomes the opportunity to provide feedback on the call for evidence: Certification of carbon removals — EU rules Please finish the list of attachments — Italian farmers’ feedback
Filed in Italian · English published by the European Commission
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The sustainable management of agricultural and forestry systems is the only production activity capable of removing carbon dioxide from the atmosphere, incorporating it permanently into soils and plants, thus compensating for residual CO2 emissions from other production sectors as well. The implementation of sustainable carbon cycles is therefore central to achieving the EU’s 2050 climate neutrality objective.
Filed in Italian · English published by the European Commission
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ETIFOR is proud to support the EU’s development of a standardized certification framework for carbon removals. Since 2011, we have strived to meet global climate, biodiversity and water targets in ways that sustain or improve local livelihoods.
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The Austrian Association of Timber Industries, representing over 1 000 businesses in the Austrian wood industry, welcomes the initiative to develop certified CO2 removal measures. The initiative aims at sound and quantifiable carbon storage and the development of the necessary rules to monitor, report and verify the authenticity of such measures.
Filed in German · English published by the European Commission
About the E.ON Group: The E.ON Group is one of Europe's largest operators of energy networks and energy infrastructure and a provider of innovative customer solutions for 50 million customers. Thus, the E.ON Group is decisively driving forward the energy transition in Europe and is committed to sustainability and climate protection.
Openbare raadpleging Certificering van koolstofverwijdering – EU regels Industriële oplossingen Nederland kijkt met interesse uit naar het aangekondigde EU regelgevingskader voor de certificering van koolstofverwijdering. Onderstaande input heeft betrekking op koolstofverwijdering door middel van industriële oplossingen.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The VCI welcomes the efforts of the EU Commission to create a single market for certificates for carbon removal. The German chemical and pharmaceutical industry also support the target announced in the Commission's Communication "Sustainable Carbon Cycles" that at least 20% of the carbon used in chemical and plastic products should come from sustainable non-fossil sources by 2030.
Feedback to EU - Commission regarding Certification of Carbon Removals The Norwegian Biochar Network (NBN) acknowledges the importance of carbon removals to mitigate climate change and achieve the climate targets set by the Paris Agreement. The NBN welcomes the Commission’s initiative to establish a common framework for transparent and sustainable Carbon Removal Certification.
COMP/AGPO/023/22EFinal FoodDrinkEurope contribution to the public consultation on EU rules for a certification of carbon removals 1. General views FoodDrinkEurope strongly supports the European Union (EU) commitment to reaching netzero emissions by 2050, and as part of this target, to achieve a 55% reduction in emissions by 2030.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Carbon farming certification should apply model frameworks for land management that emphasizes carbon as an organizing principle. Land management within this framework leads to enhanced rates of carbon capture, increases the provision of important ecosystem services (including water), builds agricultural resilience, and mitigates climate change.
CO2 Value Europe is the European Association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030 and 2050 and the development of the CCU industry. We represent more than 70 stakeholders along the entire CCU value chain.
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Carbon farming certification should apply model frameworks for land management that emphasizes carbon as an organizing principle. Land management within this framework leads to enhanced rates of carbon capture, increases the provision of important ecosystem services (including water), builds agricultural resilience, and mitigates climate change.
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Stockholm Exergi applauds the CRC-M initiative. A robust certification mechanism is essential for volume deployment of removals with geological storage. Based on the recent IPCC report and the extra-ordinary climate value delivered by removals with permanent storage, and considering the challenges in scaling this industry, we believe that the EU should give high priority to these types of removals in the CRC-M.
Reforest'Action is a certified B Corp company whose mission for the past 12 years has been to preserve, restore and create forests around the world in response to the climate emergency and the erosion of biodiversity. Our ambition is to contribute to the creation of new models of sustainable societies.
Our full position paper is attached. Our key points are summarised below. Considering the possible implications of the proposed certification framework for carbon removals for the forest-based downstream value chain and forest-based products, we would like to recommend the following: • Recognise the key role of the sustainable circular bioeconomy in removing carbon from the atmosphere.
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Certification of carbon removals – Call for Evidence Finnish Energy, branch organisation for the industrial and labour market policy of the energy sector, welcomes the call for evidence for an impact assessment regarding certification of carbon removals. A framework for carbon removals is needed swiftly Finnish Energy calls for a swift establishment of a framework for the certification of carbon removals.
The Agoro Carbon Alliance supports the EU Commission's proposal to introduce a European Carbon Removal Certification. Implemented and leveraged appropriately, in combination with emissions reducing mechanisms, an outcome based and harmonised European certification for carbon removal, based on quality criteria, ensuring the highest environmental impact and thus also carbon market value, can act as a potent…
Our forests are key in addressing the global challenges of climate change and biodiversity loss. Forests boasts the majority of terrestrial biodiversity, and they are one of the most important solutions to addressing the effects of climate change as they provide important carbons sinks absorbing and storing large quantities of CO2 and supply renewable and recyclable raw materials to substitute fossil resources.
We see many issues in the present call for contributions. The document suggests a mechanism that leads the way to carbon market which are highly problematic not only for small and medium scale farming in Europe, but also for the entire food system, land tenure and resource challenges. The EU should not let these certifications under the responsibility and benefits of private industry and interests.
We need to collectively optimise the contribution of forests to achieve the Green Deal (climate, biodiversity) while minimizing the trade-offs on its current benefits (social, economic and environmental). Hence, Tetra Pak welcomes the European Commission’s proposal to develop a carbon removal certification mechanism for activities that sequester carbon.
Input on EU CCS-certification in relation to timber and wood usage The municipality of Amsterdam and its metropolitan area consider wood as a construction material to be an important potential carbon sink. However, this possibility to capture and store carbon in the build environment is not used to the fullest.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
International Climate Change Solitions Ltd. welcomes the fact that the European Commission's (EC) consultation on the certification of carbon offsets (CDRs) has been made public and we have been given the opportunity to comment. We hope that the regulation will help to sae our planet.
Submission to the public consultation on Certification of carbon removals in the EU Within the attached discussion report, we provide an in-depth assessment of the inconsistenties of the GHG accounting of different existing (EU) climate incentive schemes for carbon farming and carbon removal activities in the land-use sectors.
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AGRI Carbon Storage 2030 We support the recognition of emission allowances under the ACS2030 standard (Feedback ref. F3251922) on the basis of the BonNares study https://literatur.thuenen.de/digbib_extern/dn062163.pdf taking into account carbon fractionation in accordance with DIN 19539. Please include this proposal in the Regulation.
Filed in German · English published by the European Commission
Vattenfall position on an EU framework for industrial carbon removals Last update: 2nd May 2022 ▪ Vattenfall fully supports the EU’s goals of becoming a climate-neutral economy by 2050 and achieving at least -55 % reductions of the EU’s net-GHG emissions by 2030. The ‘Fit-for-55’ package is a crucial initiative to align the EU’s 2030 policy framework with these goals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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We welcome the European Commission’s initiative on Certification of Carbon Removals. We consider it necessary that the certification rules include the following basic standards: Parameters defining a baseline, ensuring additionality, ensuring permanence, avoiding double counting, including leakage management and representativeness of the measurement methods used.
Filed in German · English published by the European Commission
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The EU´s initiative to develop a robust carbon removal certification mechanism (CRCM) is a welcome and timely proposal. If well-designed, the CRCM can promote a consistent and high-integrity approach to defining, quantifying, and accounting for removals, and for generating and using certificates.
AgriCaptureCO2 is a European Commission H2020 funded project by 14 partners from 7 countries, and with 6 pilots on regenerative farming; the project was launched in January 2021 (https://agricaptureco2.eu/). AgriCaptureCO2 focuses on enhancing carbon capture in agricultural soils and mitigating climate change. It is developing an innovative, robust, and scalable solution to measure carbon capture in soil.
NovoCarbo is a carbon removal company based on PyCCS technology. NovoCarbo welcomes the EU initiative on sustainable carbon cycles and would like to point out the technology and market around carbon removal through PyCCS (Pyrogenic Carbon Capture and Storage). PyCCS is the most advanced technical solution for removing CO2 from the atmosphere.
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EVA welcomes this initiative and is aligned with its goals to use carbon markets to scale land use climate protection activities within Europe. EVA’s mission is the valorization of ecosystem services through standards and certification. EVA is developing the German Forest Carbon Standard, based on a broad multi-stakeholder dialogue.
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Humus Aufbau is one of the most important themes of our time. We support the recognition of emission allowances under the ACS2030 standard (Feedback ref. F3251922) on the basis of the BonNares study https://literatur.thuenen.de/digbib_extern/dn062163.pdf taking into account carbon fractionation in accordance with DIN 19539. Please include this proposal in the Regulation.
Filed in German · English published by the European Commission
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IBERDROLA welcomes the “Certification of carbon removals” initiative, as it will be key to set a proper regulatory framework to enable sustainable carbon removals that can be appropriately monitored, reported and verified to make an efficient contribution to achieving EU carbon neutrality objective in 2050 and negative emissions thereafter.
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Dans le cadre la politique de la Métropole Européenne de Lille (MEL) en matière de neutralité carbone, la certification des crédits carbones est une nécessité à plusieurs titres : - assurer une juste équivalence entre les efforts consentis au travers de méthode de calcul - assurer, dans le cadre du marché européen une équivalence de traitement en cas de commande publique, quelque soit le pays d'origine du répondant.
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We would like to introduce an additional carbon removal strategy: Reverse Carbon Mining (RCM) is an indirect carbon removal strategy where plant photosynthesis takes CO2 from the air. We pyrolyze responsibly sourced excess biogenic residues into a char. Measured quantities of the contained carbon are moved to geo-located underground depots, where they are conserved for the foreseeable future.
Carbon Engineering’s response to the EU’s Carbon Removal Certification Mechanism call to evidence 1 Why industrial permanent removal? The IPCC’s summary for policy makers1 on climate change mitigation states that “The deployment of CDR2 to counterbalance hard-to-abate residual emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved”.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
POLICY PAPER Date 2021-05-02 Swedenergy’s comments on the call for evidence for an impact assessment regarding certification of carbon removals Swedenergy is a non-profit industry and special interest organisation for companies that supply, distribute, sell, and store energy. Mainly electricity, heating, and cooling.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Confederation of European Forest Owners (CEPF) welcomes the opportunity to express first views on the European Commission’s initiative to develop EU rules on certifying carbon removals. European forest owners offer key solutions for EU´s ambitious climate work in many essential ways: sustainably managed forests sequestrate carbon (sink), store carbon in forests and wood products (storage), and replace…
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The RE-CORD Consortium Consortium welcomes the initiative of the European Commission for the certification of carbon remote sequestration. With the adoption of this initiative, there should be a push toward an agricultural transition processed to the use of sustainable agricultural practices including organic carbon (Corg) in agricultural soils.
Filed in Italian · English published by the European Commission
Policy Paper EU Rules for the Certification of Carbon Removals The European steel industry contribution to the European Commission Calls for Evidence Publication date: May 2022 Introduction The European steel industry is among the economic sectors currently developing solutions for the capture and use (hereinafter as CCU) of CO2 contained in industrial off-gases, residual waste streams from internal production…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stellungnahme des Industrieverband Agrar e.V. zur Initiative: Zertifizierung des CO2Abbaus - EU-Vorschriften Der Industrieverband Agrar begrüßt die Pläne der Kommission, im Sinne der europäischen Klimaziele eine langfristige Vision zur Schaffung nachhaltiger Kohlenstoff-Kreisläufe einschließlich des Einfangens, der Lagerung und der Nutzung von CO2 zu entwickeln.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The Greenhouse Gas Protocol (GHG Protocol) is a multi-stakeholder partnership of businesses, nongovernmental organizations (NGOs), governments, and others convened by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD).
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Dear European Commission, We are writing as the Dutch organisation for National Carbon Certificates in the Netherlands (Stichting Nationale Koolstofmarkt, SNK, https://nationaleco2markt.nl/). SNK originates from a public-private collaboration to establish standardised accounting rules for emission reductions and carbon removal through Dutch climate projects.
TotalEnergies Corbion welcomes the proposal of the European Commission on certifying carbon removals, that will contribute to Europe's goal of climate neutrality and represents an unique opportunity for Europe's bioeconomy sector.
The members of European Bioplastics (EUBP), the association representing the bioplastics industry in Europe, fully support the European Commission’s commitment set out in the European Green Deal and the European Climate Law to achieve a balance between greenhouse gas (GHG) emissions and removals at the latest by 2050.
The European Agroforestry Federation (https://euraf.isa.utl.pt/) links organisations campaigning for agroforestry in 20 Member States (so far). Agroforestry is the integration of trees, crops and/or livestock on the same area of land. Trees can be inside parcels or on the boundaries (hedges).
The call for evidence document states that “the climate-neutral EU requires the large-scale deployment of solutions for capturing CO2 from the atmosphere and durably storing it in terrestrial and marine ecosystems, geological reservoirs or products without doing harm to ecosystems.” While the EU needs to reduce its energy consumption and improve efficiency while effectively protecting its existing carbon stocks in…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German chemical and pharmaceutical industry welcomes the proposal of the European Commission on certifying carbon removals that can accelerate implementation of the Green Deal and European Climate Law. With such measures as carbon farming, the agrochemical industry could provide additional contribution based on its long-standing experience and know-how towards achieving climate neutrality, building a sustainable…
Enagás welcomes this EC’s initiative for a Regulation. To ensure an ambitious, but implementable Regulation, we would like to share some recommendations: • The EU shall establish a common standard for carbon removals, with a smooth and clear interaction with (i) the EU ETS, as avoided greenhouse gas shall not pay a carbon price, and (ii) a system of guarantees of origin to trace the production and consumption of…
We kindly refer to the attached position paper, in which we advise the Commission to: 1. Follow the IPCC and define four Nature-based Solutions MRV Protocols for Land, Ocean, Rock and Construction Stored Carbon; 2. Align the certification framework to financial sector structures and initiatives (including the PCAF Framework); 3.
Perpetual Next contributes to the EU proposal for the legislation of the certification of carbon removals. The need for high quality, EU-level agreed upon, standards for carbon removals is evident. Perpetual Next’s carbon removal activity in the form of biochar is reliable, scalable, verifiable and with a high level of permanence.
Wir begrüssen das Vorhaben der EU für eine einheitliche Regelung zur Schaffung eines Rahmens für die Zertifizierung des CO2-Abbaus und bedanken uns für die Möglichkeit zur Stellungnahme. PyCCS (englisch: pyrogenic carbon capture and storage, deutsch: pyrogene Kohlenstoffabscheidung und -speicherung) ist eine Form der CO2-Abscheidung und Speicherung. Durch Pyrolyse (>450 °C) von Biomasse entsteht Pflanzenkohle.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Recognising that carbon removal through nature regeneration is necessary in order to reach the targets under the Paris Agreement, Climate Cleanup works with entrepreneurs to help implement natural carbon removal solutions.
Recognising that carbon removal through nature regeneration is necessary in order to reach the targets under the Paris Agreement, Climate Cleanup works with entrepreneurs to help implement natural carbon removal solutions.
Agriculture and forestry production is one of the key instruments to reach the European climate targets in 2030. However, to control the delicate balance between climate change and agricultural and forest production, agro-environmental and economic parameters must be considered throughout the whole farming system – ensuring that our transition to a greener business model does meet consumers’ demands, farmers, and…
Agriculture and forestry production is one of the key instruments to reach the European climate targets in 2030. However, to control the delicate balance between climate change and agricultural and forest production, agro-environmental and economic parameters must be considered throughout the whole farming system – ensuring that our transition to a greener business model does meet consumers’ demands, farmers, and…
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To control the delicate balance between climate change and agricultural and forest production, agro-environmental and economic parameters must be considered thorough out the whole farming system – ensuring that our transition to a greener business model does meet consumers’ demands, farmers, and foresters’ expectations, and delivers on the undeniably needed environmental outcomes.
Shell response – Call for Evidence: Carbon Removals Certification – EU Rules Ref. Ares(2022)3354581 - 01/05/2022 01 May 2022 Shell Companies EU Transparency Register: 05032108616-26 Shell1 welcomes the initiative of the European Commission to propose rules on certifying carbon removals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Shopify applauds the European Commission for its leadership in seeking to develop a regulatory framework for the certification of carbon removals. Carbon removal utilization and storage will play a vital role in securing the EU's emission-reduction objectives but it will not begin to happen unless incentives are provided to kickstart its deployment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Parents for Future Italia (PFF Italia) welcomes the EU initiative to establish an appropriate legal framework to control CO2 removal measures. 1. Scope of the Regulation PFF Italia presumes that it covers not only measures for the direct immobilisation of CO2 from technical processes, but also measures for the technical immobilisation of CO2 from the atmosphere and measures for the biological immobilisation of CO2…
Filed in Italian · English published by the European Commission
Clean Air Task Force (CATF) welcomes the initiative of the European Commission to provide the first public certification mechanism for carbon dioxide removals in the world. The proposed certification mechanism provides the necessary signals that the EU is a global leader on climate policy and is determined to advance climate action in the EU by providing the necessary regulatory support in this area.
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We strongly welcome the EU Commission's initiative to develop a legal framework for the certification of carbon removals. The instrument of certification is crucial to ensure that carbon removal activities are real, permanent, additional, and do not cause negative side effects. A clear distinction must be made between nature-based and technology-based solutions.
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We offer farming as a service and carbon farming as a service to farmers in South Africa and Africa. Great initiative but consideration must be taken to consider and include emerging countries to participate in the submission of agriculture and forestry projects. All continents are all in one universe and we need to approach the problem and desired solutions to be inclusive.
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As a matter of principle, the wrong way of making money is at the expense of citizens and businesses by imposing certification constraints and redistributing money under the pretext of environmental protection. Climate policy is an abuse of the idea of protecting the environment. This is why this lobbying initiative should be rejected.
Filed in German · English published by the European Commission
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We at go-climate AG develop carbon projects in Europe and thus strongly welcome this EU initiative. Setting minimum MRV-standards and methodologies increases the quality, efficiency and scalability of voluntary carbon action.
The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the roadmap on the future EU Commission proposal for a regulatory framework on certification of carbon removals. We have five main recommendations: 1. Standardisation of national certification approaches and monitoring, reporting and verifying (MRV) methodologies will help to expand the voluntary carbon market 2.
FederlegnoArredo (FLA), the Italian Federation of Woodworking, Cork, Furniture, Lighting and Furnishing industries warmly welcomes the possibility of engaging the call for evidence for an impact assessment on the certification of carbon removals, announced in the Commination on restoring sustainable carbon cycles.
Fertilisers Efficiency Enhancers appreciates the opportunity to contribute to the Call for Evidence on carbon removals. We recognise carbon storage plays a key role in climate change mitigation and believe that complementary measures aimed at further carbon emissions reduction should be supported and promoted as well.
· · filed 29 Apr 2022 · source
Gas Networks Ireland (GNI) welcomes the European Commission’s proposal to introduce a regulation on the certification of Carbon Removals. Carbon Removals will be a key tool in enabling Europe and the Global Community as a whole to achieve its climate ambitions, with the latest IPCC report highlighting that the 1.5C target set out in the Paris Agreement cannot be achieved without them.
Orense 6, 5º A 1 • 28020 Madrid • Tel: [phone removed] • Organización Profesional – C.I.F. G-84309350 www.asoprovac.com EU Public consultation « Certification of carbon removals » Questionnaire Introduction Responding to the urgency of climate action highlighted in the successive assessments of the Intergovernmental Panel for Climate Change (IPCC), the European Union has set in law its objective of economy-wide…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
A regulatory framework that would establish sustainable and climate-resilient carbon cycles can reduce greenhouse gases emissions and streamline solutions to capture carbon emissions from the atmosphere at industrial, farming and forest level. This needs to be complemented by a robust conformity assessment system, including certification.
While climate mitigation should clearly prioritise absolute emissions reductions, carbon sequestration in the land sector can contribute to long-term climate objectives. Carbon sequestration should be additional to reduction efforts and not disincentivise them.
Fundación Global Nature (FGN) is a private non-profit foundation dedicated to nature protection with three main topics: conservation of habitats and species, agri-food sustainability and corporate sustainability. It’s necessary to provide a European regulatory framework for carbon farming projects.
Request “TGO/ACS2030” (TGO Agri Carbon Storage 2030) Dear representatives of the European Union, for the ‘Land Use and Forestry Regulation 2021-2030’ (LULUCF), it is imperative to consider arable land as a carbon storage medium. Agricultural soils are a huge carbon pool that we have almost completely emptied in recent decades.
Filed in German · English published by the European Commission
[Please see attachment for response] Equinor pursues the ambition to become a net-zero energy company by 2050, by providing solutions and new technologies that also will enable other economic actors to reduce emissions and help deliver towards the EU’s climate neutrality.
LanzaTech welcomes the EU Commission's initiative on Carbon Removals. Carbon Capture and Utilization technologies are an essential pathway to reaching the EU climate goals. By capturing and transforming carbon oxides such as CO and CO2 scalable alternatives to fossil carbon become available to produce fuels and products helping to address both the climate emergency and energy security concerns.
· · filed 29 Apr 2022 · source
For the aviation industry, the clear priority is to reduce and avoid CO2 emissions first and only then offset the unavoidable remainder. For the perspective of a CO2-neutral aviation industry in 2050, we need the possibility of carbon removals in the long term. In this context, the certification of carbon removal measures is an important step in order to enable a reliable quantification of the actual CO2 reduction.
The Institute for Climate Economics (I4CE) is a Paris-based think tank with expertise in economics and finance with the mission to support action against climate change. Through its applied research, the Institute contributes to the debate on climate-related policies.
EDA supports the initiative aimed at establishing common EU standards for the certification of carbon removals. The dairy sector is in favour of financial schemes to reward farmers for removal of carbon from the atmosphere and we recognize that such a business model is needed to speed up carbon removals in the agricultural sector.
· · filed 29 Apr 2022 · source
Finnish forest industries would like emphasize following aspects: • Nature-based carbon removals should primarily help member States to reach their LULUCF targets. More clarity is needed on the interaction between the LULUCF regulatory framework and the proposed certification of carbon removals and on the impact on raw materials availability • Carbon removals from forests play a key role in achieving the EU climate…
The Aquaculture Advisory Council (AAC) has unanimously adopted the recommendation enclosed in response to this public consultation on "Carbon sequestration by molluscs". It has also been officially sent to the European Commission's Directorate-General for Fisheries and Maritime Affairs (MARE).
This a feedback from an interdisciplinary group of the University of Bologna (our view does not reflect the official view of our Alma Mater). We argue and conclude that comprehensive rules on the certification of each type of carbon removal are necessary and that validation of projects and the subsequent verification of carbon removals achieved, should be carried out preferably by by public authorities, possibly as…
GE welcomes the possibility to contribute to the consultation on certification of carbon dioxide removals (CDRs) opened by the European Commission (EC). As a company, we believe climate change is an urgent priority, affecting all sectors of the economy.
· · filed 29 Apr 2022 · source
The likely economic and social impacts can be positive for land managers, as the removal of CO2 from the atmosphere based on carbon removal certificates can be extended as a business model and will enable them to secure their livelihoods in rural areas. This aspect is of existential importance for forestry and agriculture.
Filed in German · English published by the European Commission
In June 2021, Finnwatch published a report on the market for emission compensations in Finland. The report also deals comprehensively with Finnish land-use sector projects, so its findings and recommendations are relevant to the proposal for certification of carbon removal. The PDF version of the report is attached and can also be found at https://finnwatch.org/fi/julkaisut/anekauppaa-vai-ilmastotekoja
Filed in Finnish · English published by the European Commission
PARTNER EUROPEAN CIRCULAR BIOECONOMY POLICY INITIATIVE EU Transparency Register # 513420241041-72 Address: c/o Lumina Consult sprl, Rue d’Oultremont 34, 1040 Bruxelles, Belgium Web: www.ecbpi.eu email [email removed] Tel : [phone removed] April 29th 2022 Consultation on carbon removal Our Mission is for the advancement of the European Economy, the regeneration of our Environment, the sustainability of our…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FNADE’s Position FNADE’s feedback on carbon removal certification April 2022 FNADE, the French waste management and environmental services association, welcomes the European initiative on carbon removal certification.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 29 Apr 2022 · source
The role of the EU in the certification of carbon removals To secure in the long run the possibility for landowners to sell their carbon credits also internationally and outside the EU we need credible, transparent, and market-based solutions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ESWET – the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technology which, within the frame of the waste hierarchy, safely treats municipal non-recyclable waste that would otherwise end up in landfills (which are a significant source of methane emissions), and plays an…
PepsiCo welcomes the opportunity to provide input to the EU’s work to establish a regulatory framework for the certification of carbon removals. As one of the world’s leading food and beverage companies with a strong footprint in the EU, PepsiCo strongly supports the European Commission’s Green Deal and wishes to play a key role in shaping an improved food system, aimed at bringing sustainable and long-term…
· · filed 29 Apr 2022 · source
Carbon capture regulations should encourage agricultural practices to capture CO2 from the air to bring it into the soil while preserving water — soil — air and biodiversity resources. What must be avoided is to encourage practices that have a negative impact on the environment: mainly the use of plant protection products and the use of nitrogen fertilisers.
Filed in French · English published by the European Commission
· · filed 29 Apr 2022 · source
ClieNFarms -the Horizon Europe project aiming to make farming systems climate neutral- agrees that the adoption of beneficial management practices for carbon removal and sequestration in the agricultural sector should be encouraged and farmers be supported financially in the transition to climate neutral farming practices.
Bayer welcomes the possibility to contribute to the Call for Evidence leading to a proposal for a Regulation for the Certification of Carbon Removals. Climate change mitigation, as soon as possible, is urgently needed. Reaching net-zero emissions in 2050 is crucial to stay below 1.5OC global warming, and to mitigate the serious social, environmental, and economic consequences of climate change.
29th April 2022 EARSC Statement Regulation on Certifying Carbon Removals The European Association of Remote Sensing Companies (EARSC) is a trade association based in Brussels, representing the Earth Observation downstream services sector. EARSC counts more than 135 members across 25 countries in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Repsol is a global multi/energy company, our main goal is to become a net zero emissions company by 2050, in line with the targets set out in the Paris Agreement. Reflecting our ambition to reach climate neutrality, we fully support the proposed increase of the EU’s climate targets for 2030 up to 55%.
· · filed 29 Apr 2022 · source
Opinion on the “Certification of CO2 removals” initiative C.A.R.M.E.N. e.V. welcomes the initiative to establish a framework for the certification of CO2 removals and the possibility of participating in an opinion.
Filed in German · English published by the European Commission
Carbon Direct applauds the EU for their recognition of the role of carbon dioxide removal in achieving EU climate neutrality by 2050. The recent IPCC WGIII report further underscores the importance of carbon dioxide removal in achieving climate goals. Carbon Direct supports the EU Sustainable Carbon Cycles (SCC) initiative and the development of the EU ‘CRC-M’ certification mechanism.
· · filed 28 Apr 2022 · source
This is a concrete proposal to eliminate CO2 from the air by means of an innovative forest building concept. The innovative forest concept has the working title ‘Fast Carbon consuming Forest’ (FCCF). Now it is likely that you will be the first idea: “this takes a long time until a newly established forest can capture significant quantities of CO2”.
Filed in German · English published by the European Commission
Call for Evidence for an impact assessment Contribution from a group of researchers of the University of Bologna, April 2022 The call for evidence is asking if 1. An EU certification framework should set common minimum standards for the certification methodologies, including monitoring, reporting and verification, or provide for comprehensive rules on the certification of each type of carbon removal. 2.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
GE welcomes the possibility to contribute to the consultation on certification of carbon dioxide removals (CDRs) opened by the European Commission (EC). As a company, we believe climate change is an urgent priority, affecting all sectors of the economy.
· · filed 28 Apr 2022 · source
Fundación Repsol is convinced about the urgent need to adopt swift climate and energy policies and we believe that such an ambition requires both breakthrough technologies as well as policy frameworks that enable the optimization of solutions that are available today and can already contribute to the reduction and abatement of emissions.
Sopra Steria feedback: The lack of a common EU standard for carbon removals constrains the creation of projects and the supply of carbon credits from them, thereby raising prices for such credits, discouraging climate action and inhibiting the integration of carbon removal into EU climate policies.
Soilfood welcomes the possibility to contribute to the EU proposal for the legislation of the certification of carbon removals. The voluntary carbon market may at best provide a robust addition to emissions reductions and carbon removals in the agriculture sector. The need for high quality, EU-level agreed upon, standards for carbon removals is evident.
· · filed 28 Apr 2022 · source
KSLA shares the Commission's view on the value of integrating carbon sequestration into EU climate policy. We are positive about using innovative solutions to separate, recycle, store carbon dioxide and increase the amount of carbon dioxide in plants in agriculture and forestry through methods for increased growth.
Date 27. april 2022 Page 1 of 2 Danish Dairy Board, Brussels s.a. Rue du Luxembourg 47-51. B2 B-1050 Brussels T [phone removed] F [phone removed] Société Anonyme / Naamloze Vennootschap Banque / Bank 310-1873223-45 BIC: BBRUBEBB IBAN: [bank details removed] The Danish Dairy Board Brussels welcomes the consultation on certification of carbon removals and that the Commission, with its communication of December 2021 on…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 27 Apr 2022 · source
We at Svensk Kolinlagring, a swedish non-profit corporation working to shift the agriculture sector from an emission source to a carbon sink, are very positive to a common EU certification/standard for carbon removals.
European Commission DG CLIMA.C3 Brussels, 27 April 2022 EPF response on the call for evidence for an impact assessment on the certification of carbon removals – EU rules The European Panel Federation (EPF) warmly welcomes the possibility to engage with the call for evidence for an impact assessment on the certification of carbon removals that was announced in the Commination on restoring sustainable carbon cycles.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In the framework of its two-year sustainability policy programme, the European Council of Young Farmers (CEJA) welcomes the possibility to contribute to the call for evidence launched by the European Commission in the perspective of the preparation of the legislative proposal on a certification for carbon removals.
Assomela, the Italian Association of Apple Producers, welcomes the possibility to comment on the consultation on carbon removal certifications, as one of the steps in the transition towards the European climate neutrality within 2050.
We welcome this initiative which is fundamental for the future of European agriculture. Our company provides innovative solutions - based on the selective activation of microbiology - primarily on soil revitalization.
· · filed 19 Apr 2022 · source
Compassion in World Farming EU welcomes the public consultation on the certification of carbon removals. When it comes to carbon removals, we need to emphasize the necessity to adopt a holistic approach and take the complexity of ecosystems into account. The climate crisis and continued biodiversity loss are inherently intertwined and need to be tackled jointly.
· · filed 13 Apr 2022 · source
For the establishment of sustainable carbon cycles, the European Commission suggests five carbon farming practices, but the biochar option is missing. This demonstrates a woefully incomplete coverage of carbon removal technologies. The report of COWI et al.
· · filed 13 Apr 2022 · source
The charcoal resulting from the pyrolysis process is a safe and easy route to the carbon sink. For example, charcoal produced in agriculture can be presented in various applications (feeding, soil, compost, others) and materials (such as climate-neutral concrete). The scientific basis already provides clear evidence of the product’s persistence and stability.
Filed in German · English published by the European Commission
We expect high general standards of carbon offsets based on EU certification principles. It should support all kinds of CDR – nature based and technology based, with long term and short term durability, etc. We need to remove CO2 from the atmosphere in high volumes very quickly so we need all of them.
· · filed 11 Apr 2022 · source
One of the most important issues of the current climate problem is how to reduce CO2 emissions and how to capture CO2 in the atmosphere. Living soils are the most capable of doing so. However, soil life presupposes a good chemical balance, which is completely disrupted by intensive farming, excessive fertiliser use and chemicals.
Filed in Hungarian · English published by the European Commission
Stellungnahme der im Transparenzregister der EU registrierten NGO Parents for Future Germany zur Initiative der EU „Zertifizierung von Maßnahmen zur Entfernung von CO2 – EU-Vorschriften“ Begrüßung der Initiative Parents for Future Germany (P4F Germany) begrüßt die Initiative der EU, einen geeigneten Rechtsrahmen zur Kontrolle der Maßnahmen zur Entfernung von CO2 zu schaffen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Feedback to EU-Commission regarding certification of carbon removals The Danish Agriculture and Food Council (DAFC) welcomes the possibility to contribute to the hearing on certification of carbon removals. The DAFC acknowledges that carbon removals cannot replace emission reductions but is an additional tool that can be used to reduce (biological) emissions in the agricultural sector.
Thank you for the opportunity to give feedback. It is important to enable agricultural carbon removals and specifically in the form of adding biochar to soils. The scientific evidence for the permanence and stability of biochar is solid. The evidence and level of positive side benefits of the carbon removal is large.
· · filed 1 Apr 2022 · source
For the agricultural sector, it is important to have a European certification mechanism translated into Member States, so that the private carbon market has confidence in the system of carbon storage in soil, thus investing from the private market in carbon storage in agricultural soils (Carbon Farming).
Filed in Dutch · English published by the European Commission
ZEP response to the call for evidence on the certification of carbon removals Reaching climate neutrality by 2050 will require all readily available, scientifically proven, net-zero compatible technologies to be developed and deployed at scale.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 16 Mar 2022 · source
Comment from the Central Union of Irrigators of the Tagus-Segura Water Transfer (SCRATS: scrats.es). From SCRATS, in Murcia, southeastern Spain, we welcome with great satisfaction the publication of this initiative which will propose EU standards on carbon removal certification.
· · filed 26 Feb 2022 · source
A model project for CO2 reduction - the greening with climbing plants of a concrete wall at the Schwendermarkt in Vienna on a busy road is not realized. Instead, the concrete wall is regularly painted with toxic paints and aerosols. A road construction joint-stock company is given a month-long contract - to later plant three blades of grass. How is that still possible in 2022 ?
At www.eAgronom.com, we share European Commission’s view that agriculture can help mitigate climate change. Agriculture is one of the major sources of global emissions, but also a potential solution to removing CO2 from the atmosphere. To maximise the potential for positive change, it is critically important to enable private sector contribution in supporting agriculture’s transition towards climate positive.
Carbon farming: Four actions the EU can take to make it happen. See also enclosed doc or use the link: https://economics.rabobank.com/publications/2022/february/carbon-farming-four-actions-the-eu-can-take-to-make-it-happen/ Summary: Based on our own experience in pilots, we share four actions that can support scaling up carbon farming now. 1.
· · filed 20 Feb 2022 · source
I believe that a carbon market is the wrong path ahead for forestry and agriculture. They have multiple functions and if carbon sequestration is paid for other functions will be set aside. This is of course also the case with product markets where production of commodites is on the expense of other ecosystem functions. But the cure for this problem is not to create markets for each function.
Every year, on a global level, tanneries recover and valorise some 8 million tons of raw hides and skins from the food sector. Without the leather industry and its upcycling activity, this residual material would simply become waste. In the EU, there are still about 1.600 tanneries recycling the hides and skins generated for the production of meat for human consumption.
· · filed 16 Feb 2022 · source
How about stopping massive deforestation? How about stopping forest fires? How about planting a tree? How about a better education of the person who wants to become a young entrepreneur in agriculture? None of the above ideas will cost you any money, they are not rocket science, they are common sense ideas, unlike the Green Deal, which will impose new costs.
· · filed 9 Feb 2022 · source
Good afternoon, Hope my message finds you well. Our [email removed] is to have all the trucks in Europe participating on a platform where they can be monitored for their CO2 footprint. Having experience in the European road transportation sector we feel improving methods in this area would make a big impact on our environment. Also possibility to further regulate CO2 emissions would be ideal.
In our company we are assessing a project to manufacture ethylenecarbonate from carbon dioxide and ethylene oxide by chemical reaction and subsequent purification. The chemical compound ethylenecarbonate is stable and used in lithium batteries as solvent. The viability of the project is highly dependent on deducting the carbon dioxide consumed as a raw material in the chemical process.
Filed in Spanish · English published by the European Commission
· · filed 9 Feb 2022 · source
Dear European Commission, Dear Lady/Sir, On behalf of the Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16], we bought it with thanks your call for opinions on “Certification of carbon dioxide capture - EU rules”.
· · filed 8 Feb 2022 · source
It is absolutely necessary, for a number of reasons, to lay down the framework and instructions for the certification of CO2 reduction measures. In my view, reference should be made to the following further points: * to avoid dopplel counts of “business carbon neutrality” with the carbon footprint of states, or the matching “who owns CO2” * an environmental assessment of the carbon sink projects must be carried out…
Filed in German · English published by the European Commission
· · filed 8 Feb 2022 · source
The certification of CO2 reduction measures is certainly an important step in order to be able to reliably quantify actual CO2 removals. In addition to the planned environmental aspects, the certification framework should also include sustainability aspects. It is only because a measure contributes to CO2 removals that it is still far from sustainable.
Filed in German · English published by the European Commission
· · filed 8 Feb 2022 · source
For EAPN Nederland, two cases are of major importance in this legislation. 1. Provide additional support to small farmers, so that they can also use it to convert to ecological, sustainable, agriculture and livestock farming. Use this also to limit the livestock population for the immediate future and to reduce it. 2.
Filed in Dutch · English published by the European Commission
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