The European Union has committed to achieving climate neutrality by 2050 at the latest under the European Climate Law. This goal requires not only deep decarbonisation but also the deployment of permanent carbon removal technologies, which offset the remaining emissions from difficult-to-sustain sectors. The voluntary Union Certification Framework (CRCF), established by Regulation (EU) 2024/3012, which entered into force on 26 December 2024, is a key strategic tool to ensure the technical integrity of these processes. Its primary role is to create a trustworthy environment that prevents greenwashing by setting strict "Union quality criteria" (quantification, additionality, long-term storage and sustainability).

Analysis of the legal basis The basic regulatory framework established by Regulation (EU) 2024/3012 is operationalised by the Commission Delegated Regulation of 3 February 2026 laying down detailed certification methodologies for industrial activities. Together, these rules define the technical parameters that operators must meet in order for their activities to be recognised as high-quality carbon removal within the meaning of Union legislation.

Key objectives of certification:

* Supporting innovation: Facilitating the deployment of breakthrough industrial carbon removal technologies.

* Facilitating investment: Creating a predictable legal environment to attract private and public capital to DACCS, BioCCS and BCR projects.

* Transparency and integrity: Ensuring rigorous monitoring and verification (MRV) that guarantees the real climate benefit of each unit.

* Establishment of a central Union registry: Creation of a unified technical infrastructure to track units and avoid double counting.

These objectives link the Union's political ambitions with specific technical requirements for eligible permanent removal activities.

1. Technical definitions and scope of activities

A precise categorisation of activities is essential to ensure the technical integrity of carbon removal. According to Articles 1 and 3 of the Delegated Regulation, three basic categories of industrial removal are defined, each subject to specific requirements for the capture and storage process.

Classification of permitted activities:

* DACCS (Direct Air Capture with Carbon Storage): Activity capturing atmospheric CO₂ directly from the ambient air using technical devices with subsequent permanent storage in a geological repository with a permit under Directive 2009/31/EC.

* BioCCS (Biogenic Emissions Capture with Carbon Storage): Capture of biogenic CO₂ produced as a by-product of biomass processing with subsequent geological storage. Legislation strictly prohibits the purposeful increase in biomass consumption solely for the purposes of capture and storage; the capture must be a by-product of the production of goods, energy or services.

* BCR (Biochar Carbon Removal): Biochar production by thermal processing of biomass. The certification applies exclusively to the stable fraction of biochar, which guarantees safe carbon storage for hundreds of years, whether by application to soil or incorporation into materials.

Geographical restrictions All CO₂ capture installations (for DACCS and BioCCS) as well as biochar production and storage facilities (for BCR) must be located within the Union. This restriction ensures direct traceability and compliance with EU regulatory standards.

These definitions are the starting point for determining whether activities are additional to normal market practice.

2. Rules for additionality and baseline setting

The concept of additionality addresses the problem of „market failure“ of DACCS, BioCCS and BCR activities. These technologies generate high investment costs (CAPEX) and operating costs (OPEX), while they do not currently benefit from the benefits of the ETS (e.g. free allowances) and do not produce adequate natural revenue streams without external incentives.

Standardised Baseline For DACCS, BioCCS and BCR activities, a standardised baseline of 0 kg CO₂ equivalent is set. This decision reflects the fact that under current conditions these activities would not be carried out without a certification incentive. In accordance with Article 4(9) of Regulation (EU) 2024/3012, an operator in these categories is not required to calculate an individual baseline, thereby reducing the administrative burden while maintaining integrity.

Financial additionality criteria According to Article 5(1)(b) of Regulation 2024/3012, certification must provide the necessary incentive effect. An activity is additional if the income from the certified units is essential for the financial viability of the project. If the activity is mandatory by law or profitable in itself, it does not meet the additionality condition.

A properly established baseline allows for accurate quantification of net benefit across the entire life cycle.

3. Methodology for quantifying the net benefit of carbon removal

Calculating the net carbon removal benefit represents a shift towards a holistic assessment of the climate impact of an activity.

Calculation formula according to Article 4(1): Net benefit = Total removals – Associated GHG emissions – Baseline (0).

* Total removal: The volume of CO₂ actually captured and stored.

* Associated emissions: Includes emissions from the entire life cycle (energy consumption, transport, indirect impacts). An important methodological simplification according to recital 11 of the Delegated Regulation is that emissions from indirect land use change (ILUC) are considered insignificant for these three technologies when waste biomass is used.

Conservative approach to uncertainties In accordance with Article 4(12) of Regulation 2024/3012, uncertainties in measurements and calculations must be addressed by applying a conservatism factor. This ensures that the net benefit is not overestimated in the event of technical uncertainties.

The quantified benefit is only valid provided that the carbon storage is demonstrably permanent.

4. Rules for permanent storage and responsibility for subsequent release

From the perspective of reversal risk, there is a fundamental difference between geological storage and storage in materials.

Geological storage (DACCS/BioCCS) Activities must comply with the requirements of Directive 2009/31/EC. The operator of the capture facility is fully responsible for any CO₂ leakage during the monitoring period. Any leakage detected must be compensated under liability mechanisms.

Biochar Storage (BCR) Specific monitoring rules apply to biochar:

* Scope of monitoring: Monitoring is only required up to the point of demonstrable application to soil or incorporation into a product. After this step, no further monitoring is required (recital 6 of the Delegated Regulation).

* On-site inspection: The operator must allow access to the application site for at least one year for audit verification purposes.

* Stability: Only the stable carbon fraction is certified, which guarantees the permanence of storage.

Liability mechanisms Adequate mechanisms must be in place to cover the risk of back-release, such as buffers of certified units that serve as a reserve in case of unforeseen emissions.

5. Minimum sustainability requirements

All certified activities must comply with the principle of "Do No Significant Harm" (DNSH).

Sustainability objectives: Activities must support biodiversity conservation, climate change adaptation, circular economy, pollution prevention and water resource protection.

Biomass rules (BioCCS/BCR):

* RED II: Mandatory compliance with sustainability criteria under Directive (EU) 2018/2001.

* Cascade utilization principle: Priority for material recovery of biomass.

* BCR strict limit: According to recital 10 of the delegated regulation, if biochar represents the primary product of the activity (more than 50 % of total energy output), the operator may use exclusively raw materials from waste or residues (as defined in RED II).

These criteria are subject to verification by independent auditors as part of the certification process.

6. Operational process: Monitoring, auditing and certification

The proper functioning of certification schemes is guaranteed by Implementing Regulation 2025/2358. Certification bodies act as guarantors of the integrity of the entire system.

Key operator documents:

* Activity Plan: Description of the technology and demonstration of additionality.

* Monitoring Plan: Measurement methodology and data quality control.

Audit rules:

* Certification audit (validation): Requires an on-site audit and achieving a level of "reasonable assurance" about the effectiveness of internal processes.

* Individual approach: Group auditing is only allowed for carbon agriculture. DACCS, BioCCS and BCR operators must undergo individual audits.

* Avoidance of "scheme hopping": According to Article 8 of the Implementing Regulation, the operator must indicate in the application its history in other schemes over the last 5 years. Failure in another scheme or purposeful change of scheme after deficiencies have been identified leads to exclusion.

Non-conformities report:

•  Critical (e.g. fraud): Immediate certificate revocation.
•  Serious (system errors): Certificate suspension with 90 days to correct.
•  Less serious: Time limit for correction within 12 months.

Registry and archiving All units will be mandatorily registered in the central Union Registry from 2028. The operator is obliged to keep complete documentation for at least 5 years after the end of the monitoring period.

Ensuring continued compliance with these rules is a prerequisite for the long-term stability and credibility of the EU carbon removal market. JRi&CO2AI