Carbon Gap

The Industrial Decarbonisation Accelerator Act (IDAA) offers a unique opportunity to future-proof European industry and accelerate deployment of permanent carbon dioxide removal (CDR). As energy-intensive sectors will retain some level of emissions that are economically and technically hard-to-abate, permanent CDR is indispensable for achieving climate neutrality and enabling net-negative emissions beyond 2050.

Alongside deep emissions reductions, carbon dioxide removal (CDR) is essential for achieving net zero and beyond. According to the IPCC, the EU will need 400800 MtCO of removals annually by 2050. Yet, three recently published reports by DG CLIMA identify significant funding gaps for CDR. Carbon Gaps latest report (referenced in the Commissions work), shows that only 0.1% of EU climate funding has gone to CDR so far.

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.

Carbon Gap welcomes the opportunity to provide feedback on the European Commissions consultation on the revision of the EU ETS 1. As an organisation dedicated to responsibly scaling carbon dioxide removal (CDR) in Europe and advancing effective climate policy, we believe this revision will be critical to clarify the potential role of permanent CDR within the EU ETS, maintaining a strong alignment with the EUs…

Climate-related claims are one way for companies to attempt to communicate their climate mitigation efforts to their customers. If such claims fail, arent real, and dont stand up to scientific scrutiny, they become a dangerous tool for greenwashing.

Carbon Gap supports the 90% emissions reduction target for 2040 in the revised European Climate Law. This target is foundational as it sets the trajectory to achieving the EUs 2050 climate neutrality and subsequent net negative emissions.

Carbon Gap sees a strong need of improving the coherence and effective implementation of EU ocean governance, especially when it comes to marine carbon dioxide removal (mCDR) The ocean represents a critical and still under-developed pillar of the EUs carbon removal strategy.

Carbon Gap welcomes the Commissions proposal for a Net-Zero Industry Act (NZIA) and committed efforts to strengthen Europes net zero ecosystem. The NZIA represents significant advances for the sector, especially for the 8 strategic technologies that have been listed. We believe the proposal can be improved to ensure it achieves its objectives, as outlined in the recommendations below. 1.

Europe is setting the course for infrastructure rules that will underpin its carbon management system for decades. The upcoming Regulation will make up the network blueprint that will define who gets to participate in Europes carbon management and who is left behind.

1. The 90% 2040 target should be met through domestic action. In line with the European Scientific Advisory Board on Climate Change, a fully domestic pathway to 90% net emissions reductions by 2040 is within reach. International carbon credits should complement not substitute domestic action and should be reserved for ambition beyond 90% or as a hedge against unforeseen shortfalls. 2.

According to the IPCC, achieving climate goals will require 400-800MtCO of removals annually by 2050. Marine CDR (mCDR) is a good complement to land-based methods because it can help reduce land-use conflicts and lessen dependence on limited geological CO2 storage. This means large-scale mCDR could be decisive for keeping 1.5 °C within reach and a critical pillar of the EU's carbon removal strategy.

The review of the Governance Regulation is a critical opportunity to ensure that the EUs climate governance framework is fit for delivering the post-2030 climate architecture, including the upcoming 2040 climate target. Carbon Gap strongly supports the Commissions objective to transform NECPs into credible investment and delivery plans for the post-2030 period.

The 20302040 decade will be decisive for putting the EU on a credible path to climate neutrality. Achieving the proposed 90% net emissions reduction target by 2040 will require not only accelerated emissions cuts, but also the rapid scale-up of carbon dioxide removal (CDR). The policy framework designed in this decade will determine whether Europe can deliver both in a timely and cost-effective way.