The European Union has set itself a binding target under the European Climate Law to achieve climate neutrality by 2050 at the latest. Achieving this ambition requires not only a drastic reduction in greenhouse gas emissions, but also active and sustained removal of carbon dioxide (CO2) from the atmosphere. Regulation 2024/3012 introduces the Union's first voluntary framework for carbon sequestration certification, serving as a tool to increase transparency, integrity and trust in environmental claims.

„"The international community has committed, under the Paris Agreement, to holding the increase in the global average temperature to well below 2°C above pre-industrial levels and to pursue efforts to limit the increase to 1.5°C." — Recital (1) of Regulation 2024/3012

This framework deconstructs the chaos of voluntary carbon markets and combats „greenwashing“ by setting strict methodological rules. It is crucial for the student of environmental policy to understand that certification is not just an administrative exercise, but a scientifically based process of verifying real climate benefits.

Before we begin to analyze the certification process, we need to understand the taxonomic division of activities that are eligible to enter this system.

Categorization of activities: What goes into the process?

The Regulation precisely defines the types of activities in Article 2 according to the nature of carbon storage. For the integrity of the system, it is essential to distinguish between permanent absorption and temporary sequestration, which is subject to the risk of release.

In order for an activity in these categories to receive a certificate, it must cumulatively meet strict quality criteria known under the acronym QU.ALITY.

Four pillars of quality (QU.ALITY criteria)

These criteria (Articles 4 to 7) constitute the methodological core of the Regulation. Each certified unit must be verified against the following four aspects:

• Quantification: Emission removals or reductions must be measured accurately and conservatively. The net benefit is calculated using the formula: Net benefit = Pbaseline – Ptotal – GHGassociated > 0 (Where Pbaseline is the baseline, Ptotal is the total removals of the activity and GHGassociated are the emissions associated with the implementation, including indirect land use).
  • „"So what?": This mathematical approach ensures that no overestimated data is entered into the system. The deduction of associated emissions (GHGassociated) protects the integrity of the activity's life cycle.
• Additionality: The activity must go beyond the legal requirements (Article 5) and must require the incentive effect of certification on its financial viability.
  • „"So what?": When using standardized reference levels Additionality is assumed in standardised baselines. At specific levels, the operator must pass tests, which prevents „perverse incentives“ – i.e. certifying something that would happen even without the legislative incentive.
• Long-term storage: The operator must demonstrate the ability to keep the carbon stored and monitor the risks of its leakage.
  • „"So what?": The regulation distinguishes between permanent units and temporary units (agriculture/products) that have a set expiry date. This ensures that the market accurately values the durability of the climate benefit.
• Sustainability: The activity must comply with the principle „"Do No Significant Harm" (DNSH) – not cause significant damage to environmental objectives (biodiversity, water, circular economy).
  • „"So what?": This criterion aligns certification with the EU Taxonomy and prevents projects that would absorb carbon at the expense of devastating local ecosystems (e.g. monoculture afforestation).

After defining quality standards, a process lifecycle follows, which transforms the activity into a certified unit.

Certificate Lifecycle: Step by Step

The certification process under Articles 9 and 12 takes place in five chronological phases:

1. Application and activity plan: The operator shall submit to the certification scheme activity plan and monitoring plan. Groups of operators (e.g. small farmers) can act together to reduce administrative burdens.
2. Initial certification audit: Independent certification body verifies the plan's compliance with the QU.ALITY criteria and the correctness of the quantification of expected benefits.
3. Issuance of a certificate of conformity: If the audit is successful, a certificate confirming the eligibility of the activity is issued. Information about the location and methods is recorded in a register.
4. Regular recertification audit: At least every 5 years (more often for riskier activities) the certification body will audit the net benefit actually achieved.
5. Issuance and registration of units: Based on successful recertification, the registry will issue certified units (1 unit = 1 ton of CO2 equivalent).

This cycle does not end with the issuance of the unit; it continues with continuous monitoring of the risk of storage reversal.

Accountability and monitoring mechanisms

From an environmental policy perspective, the most critical point is the risk of carbon being re-released into the atmosphere.

CALLOUT: REVERSAL According to Article 2, point 21, this is a leakage (in geological storage) or a voluntary or involuntary release of captured carbon back into the atmosphere (e.g. forest fire or decay of a wooden building).

If a reversal occurs during the monitoring period, the operator bears legal and economic responsibility. The Regulation foresees in Article 6:

• Collective buffers: A portion of the units are not released into circulation but serve as a reserve to cover losses within the scheme.
• Insurance mechanisms: Use of financial instruments to cover the risk of "reversal".
• Direct cancellation of units: As a last resort when accountability mechanisms fail.

Transparency: Union Registry and unit types

A robust digital infrastructure is a key element against double counting. The Commission will set up Union Registry until 27 December 2028. Until then, the certification schemes themselves are responsible for the operation of interoperable registries (Article 12(3)).

The regulation strictly distinguishes four types of certified units:

• Permanent carbon sequestration unit: It does not expire, it represents permanent storage.
• Carbon sequestration unit from agriculture: It has an expiration date at the end of the monitoring period.
• Carbon storage unit in products: It expires after at least 35 years unless further storage is proven.
• Soil Emission Reduction Unit: Specific category for LULUCF and agricultural land emissions.

Key expiration logic: According to Article 12(5), temporary units (agriculture and products) are considered to have been released into the atmosphere after the end of the monitoring period and are deleted from the register unless the operator demonstrates continued monitoring and storage.

Why does credibility matter?

The implementation of Regulation 2024/3012 transforms carbon sequestration from an abstract concept into a measurable commodity with high environmental integrity. The rigour of the process – from conservative quantification to liability mechanisms for reversal – is essential for these units to have a real market value and to truly contribute to the goals of the Paris Agreement.

Takeaway for the future professional:

1. Integrity through formulas: Net benefit never equals gross removal; we always have to subtract associated emissions and account for uncertainties.
2. Time value of carbon: The distinction between a permanent and a temporary unit (expiration) is a fundamental building block of a transparent market.
3. DNSH as a fuse: Carbon sequestration certification must not be carried out in isolation from the protection of biodiversity and other environmental objectives of the Union. JRi&CO2AI