Feedback on the Delegated Act on Carbon Removals Certification Framework(CRCF)
Feedback on the Delegated Act on Carbon Removals Certification Framework (CRCF)
Bioenergy Europe appreciates the opportunity to provide feedback on the draft Delegated Regulation establishing methodologies for certifying permanent carbon removals under the CRCF framework. The Association fully supports the swift and timely adoption of a credible, transparent, and science-based system for certifying removals from DACCS, BioCCS, and BCR.
Bioenergy Europe contributed to the Public Consultation on CRCF methodologies for biochar, BioCCS, and DACCS. The Association fully supports the swift and timely adoption of a credible, transparent, and science-based system for certifying removals from DACCS, BioCCS, and BCR. Establishing such a system will be essential not only to reaching the EU’s net-zero targets, but also to enabling the development and deployment of high integrity negative emissions solutions.
At the same time, we believe that targeted clarifications and adjustments are necessary to ensure the framework is workable, fair, and effective in supporting the scale-up of permanent carbon removals.
In particular, Bioenergy Europe identified six key challenges to tackle, covering the following topics:
- Alignment with the Renewable Energy Directive (RED III)
- Avoidance of unsustainable demand for biomass raw material
- Disclosure requirements on biomass feedstock (Section 4.3 of the Annex)
- Overcompensation clause (Section 2.1.2 of the Annex)
- Activity Period Duration (Section 1.2.1 of the Annex)
- Biochar Carbon Removal
