What the new European framework on removals is and why the first transaction matters
The CRCF is a voluntary EU framework to certify high-quality carbon removals. Its full name is the Carbon Removals and Carbon Farming Certification Framework, and it covers three families: permanent carbon removals, carbon farming, and carbon storage in products.
It is not an “EU ETS 2.0”. The point is not to create a compliance market of allowances, but to set common rules on quality, MRV (monitoring, reporting, verification), and registries, so that a “tonne removed” is defined in a more defensible and comparable way across projects and countries.
The dates matter because they move go-to-market from “idea” to “process”. Regulation (EU) 2024/3012 was published on 6 December 2024. Implementation then proceeds through operational rules on certification schemes, bodies, and audits via Implementing Regulation (EU) 2025/2358. And the piece that truly unlocks supply is the adoption of the first methodologies for “permanent removals” by the Commission via a delegated act, announced on 3 February 2026.
The first public “CRCF-aligned” or “CRCF-ready” transaction matters because it becomes price discovery. The first deals effectively set what it means to buy “1 ton CO₂ removals” in an EU context: which minimum data fall within scope, how buffers and liabilities are handled, how much detail is needed for the audit, and which buyer-side requirements become standard in procurement and assurance.
The difference versus private voluntary standards is not just a label. For a European buyer that must answer to the board, auditors, and investors, a certification anchored to EU rules on schemes, controls, and authorisations increases auditability and defensibility, and reduces the information asymmetry that fuels greenwashing accusations.
Once the “why” of the CRCF is clear, the practical question is “how”. In BECCS, quality is decided in the system boundaries: biogenic vs fossil CO₂, geological storage, associated emissions, and accounting. That is where accounting errors originate.
BECCS in practice: how a removal unit is generated across biomass, capture, and geological storage
A BECCS unit exists only if storage is permanent and verifiable. Capture alone is not enough: without injection and monitored geological storage, you are not buying a “permanent carbon removal” in the sense the EU is setting out.
The BECCS supply chain, viewed operationally, is: feedstock or biomass → energy conversion or industrial process → CO₂ capture (post-combustion or process capture) → compression and conditioning → transport (pipeline or ship) → injection and geological storage. Every step generates data and, if not measured properly, also generates “losses” of tonnes.
For procurement it helps to think in terms of scale, not slogans. In Europe several projects in the pipeline talk about hundreds of ktCO₂/year. One example cited in public discussions is Stockholm Exergi, with a BECCS project indicated at around 800 ktCO₂/year and an indicative operational start around 2028, with CO₂ shipped for storage in the Northern Lights project.
Unit issuance follows a simple logic, but one full of details. You start from the mass of CO₂ measured at capture, then subtract losses and associated emissions: energy for capture and compression, reagents, transport, any venting, and other contributions defined by the boundary. The result is net removals. The critical point is precisely the boundary: what you include from the biomass upstream, what you include from logistics, and how you treat storage.
Infrastructure dependence is an economic and delivery driver. If there is no transport and storage capacity, even a ready capture plant cannot deliver. Northern Lights, for example, has announced a capacity expansion beyond 5 MtCO₂/year by the end of 2028 (Phase 2). For those signing BECCS offtake, these numbers matter because they determine bottlenecks and delivery risk.
Once it is clear how a unit is produced, the next question is how sound it is. In BECCS the risks are not theoretical: additionality, biomass sustainability, leakage, and permanence feed directly into price and contract terms.
Integrity and BECCS-specific risks: additionality, biomass sustainability, leakage, and permanence
Additionality in BECCS is not automatic. “I capture biogenic CO₂” does not, by itself, prove that you are generating removals beyond a credible baseline. You must explain what would have happened without the project, and why the revenue or incentive linked to removals is materially relevant to start it or scale it.
Policy stacking is a sensitive point in due diligence. If a project combines public support and corporate sales of removals, the buyer must understand how perceived double-incentive risks are managed and, above all, how this affects the additionality argument and the narrative to stakeholders. In Europe there are BECCS projects supported in public-policy contexts, and this makes the issue even more relevant for buyers operating under EU scrutiny.
Biomass sustainability is a supply-chain risk before it is an MRV risk. The practical distinction is between feedstocks such as residues and by-products, and more “contested” biomass such as roundwood. Here the buyer is not looking only for a statement, but for controls: traceability, proof of origin, chain of custody, mass-balance rules, and audit rights over critical suppliers.
Leakage and indirect emissions are where tonnes are lost without noticing. Typical points are: changes in biomass destination, displacement of existing uses, maritime transport, additional energy for capture, losses in compression and transport. In practice, this translates into a due-diligence checklist: LCA with scenarios, documented emission factors, explicit assumptions, and sensitivity analysis on the drivers that move the net figure.
Permanence is the reason geological storage changes the category of the credit. In the EU framing, geological storage is what enables “permanent carbon removal”, and it brings with it an issue that procurement cares about more than marketing: long-term obligations and liabilities, consistent with the rules governing storage. This is where it is decided whether the credit is perceived as premium and bankable.
Once the risks are mapped, the question becomes how we measure them and make them auditable. This is the step where MRV, traceability, and double-counting prevention stop being words and become requirements.
MRV and traceability in the EU system: required data, verification, registries, and double-counting prevention
The CRCF introduces a layer of governance that directly affects buyers. Implementing Regulation (EU) 2025/2358 governs how certification schemes, certification bodies, and audits operate. For a buyer this means something concrete: it is not enough to have “a verifier”; you need to understand who is authorised, under which obligations, and with what documentary traceability and cooperation with authorities.
The BECCS data room, if you want to do serious procurement, looks more like a technical dossier than a certificate. The datasets that a sophisticated buyer typically requests include: flow and captured-CO₂ measurements, gas composition, energy consumed, reagents, logistics (ship or pipeline), receipts and injection logs, storage monitoring (pressure and plume behaviour), instrument QA/QC, metadata, versioning, and change controls.
Double-counting prevention must be understood in a B2B way, not ideologically. One thing is making a claim about purchased removals. Another is corporate accounting and reporting. If you want to report removals as “yours” in a strict sense, they must not be sold to third parties and must not be double-counted. The logic is consistent with the ESRS approach: emissions are reported gross, and credits and removals appear in dedicated disclosures, with attention to characteristics, contracts, and retirements.
The registry is the piece that reduces fraud and re-selling. The CRCF foresees an evolution toward an EU electronic registry to ensure uniqueness and traceability: serialisation, unit states (issued, transferred, retired), and more robust controls. For those structuring multi-buyer purchases or syndications, this is a practical change: less “re-sale” risk, easier audit and reconciliation.
With MRV and registries clarified, the buyer moves to the purchasing decision. This is where procurement and contracts come in, how to price delivery risk, and above all how to use, or not use, removals in claims in CSRD and ESRS contexts and in SBTi alignment.
Implications for Italian buyers: procurement, contracts, price, delivery risk, and use in claims (CSRD/SBTi)
Procurement must start from verifiable requirements, not promises. In a sensible RFP today, you explicitly ask for CRCF-aligned or CRCF-ready units, a complete audit trail, LCA disclosure with assumptions, biomass chain of custody, and proof of storage. And then you put into the contract data access and audit rights, including the possibility to review the verifier’s work if inconsistencies emerge. This is particularly relevant for Italian buyers operating under EU-wide CSRD/ESRS reporting expectations.
CDR contracts for BECCS look more like energy offtakes than “spot purchases” of credits. Typical structures include multi-year forward offtake, milestone-linked deliveries, true-up and make-good mechanisms, buffers or insurance covers, and liquidated-damages clauses. Delivery risk hides in permitting, commissioning of the capture unit, availability of shipping and storage, and operational downtime. The growth of transport and storage capacity, as in the case of the announced Northern Lights expansion, is a signal that the market is trying to make these contracts more deliverable.
Price should not be debated through generic numbers. The real drivers are: capture CAPEX, energy and solvent OPEX, CO₂ logistics, storage tariff, MRV and assurance costs. In general, the more geological permanence and auditability increase in an EU context, the more the buyer expects a premium versus less robust credits or avoidance-based units.
In claims and reporting, the key point for boards and legal teams is this: under ESRS E1, emissions are reported gross, without subtracting credits or removals. Carbon credits and removals appear in dedicated disclosures, and contract quality and double-counting management become part of the defensibility of communications. If you are buying forward removals, the timing of retirement and clarity on retirement also matter.
After procurement and claims, the strategic question remains. What happens between 2026 and 2030, which BECCS projects can scale, which CO₂ infrastructures are make-or-break, and which policy and market signals to monitor to avoid being left without supply.
Roadmap 2026-2030: which projects can scale in Europe and which signals to monitor (policy, CO2 infrastructure, demand)
The CRCF timeline is clear on the steps, less so on market timing. The methodologies for permanent removals were adopted by the Commission on 3 February 2026, but unit issuance depends on schemes, accreditations, and operational rollout. Many operators expect that the first certifications and the first credits “in practice” will arrive over the next few years, with a window often read as around 2027 for the first actual issuances.
Scalable BECCS projects in Europe should be read as a reference class. Stockholm Exergi is a useful case because it combines industrial scale, a target of about 0.8 Mt/year, and a cross-border approach to storage. For a buyer, scalability is not an abstract word: it depends on an already-large biomass plant, thermal integration, access to port and shipping, and storage already contracted.
CO₂ infrastructure is the hardest gating factor. The announced Northern Lights expansion to over 5 Mt/year by the end of 2028 is a proxy for the pace at which the supply of storage-backed CDR can grow. Without transport & storage, BECCS does not deliver, even if capture is ready and the project is certifiable on paper.
Demand in 2026-2030 will be driven by two forces that add up. The first is strategic: net-zero targets and residuals management push toward high-durability removals. The second is reporting: ESRS increases pressure for transparency on credits and removals, and makes it more costly—reputationally and in assurance terms—to buy units that are not very auditable. The expected result is more demand for units with geological permanence and strong traceability, compared with avoidance or temporary credits.
The operational signals to monitor are five, and they are the ones that truly change risk for a buyer:
- CRCF updates on methodologies, subsequent acts, and consultations.
- FID and commissioning of BECCS plants, with evidence of performance and uptime.
- Transport and storage contracts: open seasons, capacity booking, and real availability.
- Evolution of guidance on claims and assurance practice in CSRD and ESRS contexts.
- Convergence on registries and interoperability: serialisation, unit states, and retirement rules, to reduce arbitrage and double counting.
