Lobbying on Carbon Removal Certification

Carbon Removal Certification

Climate action

To help scale up and encourage the deployment of sustainable carbon removals from ecosystems and industrial solutions, the European Commission will propose a regulatory framework for certifying carbon removals. Certification will be based on robust and transparent carbon accounting in order to monitor and verify the authenticity of carbon removals, representing a necessary and important step towards a trustworthy integration of carbon removals in EU climate policies.

Links

Public consultation

ID: 13172

Lobbying Activity

202 responses

Environmental groups reject EU carbon removal framework as greenwashing tool

European Environmental Bureau, 9 Mar 2023

The EEB demands the framework prioritize drastic emission reductions over offsetting, require positive biodiversity impacts rather than neutral ones, and exclude unsuitable activities like soil carbon sequestration and BECCS from certification. They insist emission reductions must not be certified as removals and that fundamental rules on liability, storage timelines, and monitoring be included in the basic act.

This would prevent corporate greenwashing and ensure climate action focuses on real emissions cuts.

Corporations lose ability to claim carbon neutrality without reducing actual emissions.

WWF: EU carbon removal plan risks enabling corporate greenwashing

WWF European Policy Programme, 16 Dec 2022

WWF demands the proposal exclude carbon removal certificates from existing trading systems. They want tailored methodologies for removal activities and clear liability rules.

Strengthening these rules ensures that carbon removals support biodiversity and genuine climate goals.

Large industrial polluters would be prevented from using reversible carbon removals to offset emissions.

Microsoft urges EU to prioritize durable carbon removal technologies

Microsoft Corporation, 23 Mar 2023

Microsoft requests clear definitions differentiating carbon removals from reductions, stronger durability standards favoring long-term storage solutions, and robust additionality tests. They want certification access for experimental engineered solutions like direct air capture and carbon mineralization.

This would enable them to meet their carbon-negative commitments using preferred high-durability technologies.

Nature-based solution providers face stricter leakage accounting and lower priority versus engineered technologies.

Chemical industry urges recognition of industrial carbon removal solutions

European Chemical Industry Council, 23 Mar 2023

The industry requests that technological carbon removal solutions be fully recognized in the certification framework and eventually in the EU ETS. They argue that capturing CO2 from industrial point sources should be prioritized over Direct Air Capture as it is less costly and energy-intensive. They also want clarity on how circularity contributes to carbon removal objectives.

This would provide investment certainty and allow them to monetize carbon removal activities.

Environmental groups lose if industrial emissions are offset rather than eliminated first.

Chemical industry promotes fertiliser enhancers as climate solution

European Chemical Industry Council, 29 Apr 2022

The organization urges recognition of urease and nitrification inhibitors as complementary emission reduction measures. They seek wider endorsement through CAP eco-schemes and clear legislative measures promoting these technologies.

This would expand markets for their fertiliser enhancer products across EU agriculture.

European farmers urge rewards for carbon capture and biodiversity

European farmers, 1 May 2022

The organization demands that environmental benefits beyond carbon be recognized and rewarded. They suggest EU minimum standards to reduce complexity and legal uncertainty for farmers. They insist carbon credits must not allow industries to avoid direct emission reductions.

Certification would turn carbon removals into a stable additional income source for farmers.

Industrial companies could be prevented from using agricultural credits to avoid decarbonization obligations.

European agri-cooperatives urge EU to reward existing carbon farming

European agri-cooperatives, 1 May 2022

They support common EU standards but insist on validating existing private schemes. The group advocates for rewarding specific farming practices rather than just new carbon credits to avoid penalizing early adopters.

This framework would provide legal security and create new income streams.

Industrial polluters are warned not to use these credits to avoid reducing their own emissions.

Steel giant ArcelorMittal urges EU to certify industrial carbon reuse

ArcelorMittal, 2 May 2022

The industry wants the certification to include industrial carbon capture and use while avoiding distinctions between carbon avoidance and removal. They advocate for recognizing temporary storage solutions, such as polymers and fuels, alongside permanent ones.

This allows the steel industry to monetize captured emissions that are currently unrewarded by existing carbon markets.

Nature-based projects may face stricter scrutiny and reduced incentives due to competition with industrial solutions.

Finnish forest industry demands recognition for wood-based carbon storage

Finnish Forest Industries Federation (Metsäteollisuus ry), 21 Mar 2023

The group wants recognition for carbon stored in wood and fossil material substitution. They request a clear definition of renewable carbon to distinguish biogenic and fossil sources. Certification should include product storage and incentivize industrial carbon capture technologies.

This would secure industrial access to timber and create markets for bio-based products.

Environmentalists lose as the plan seeks to prevent carbon from being locked in forests.

Finnish forest industry urges recognition for carbon-storing wood products

Finnish Forest Industries Federation (Metsäteollisuus ry), 29 Apr 2022

They request that the full mitigation potential of forest products be rewarded. Recognition of carbon storage products and their substitution effect is considered vital. The capture of biogenic carbon should remain an optional choice.

This would boost demand for wood and incentivize investments in sustainable forest management.

Fossil fuel and non-renewable sectors lose market share as wood products substitute their materials.

Eurelectric urges higher EU targets for industrial carbon removals

Eurelectric aisbl, 15 Mar 2023

Eurelectric encourages the European Commission to increase the level of ambition of 5 Mt CO2 industrial carbon removals. They recommend clearly defined ownership and certification by independent private entities.

Clear certification and higher targets would provide essential signals to attract industrial technology investors.

Carbon removal developers lose immediate access to the ETS to protect market integrity.

Finnish farmers demand simpler rules for carbon removal certification

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 2 Feb 2023

MTK calls for simple certification criteria and verification costs that align with market prices. They insist that funding must come from private sources rather than agricultural subsidies. The rules should also avoid binding future landowners with long-term contractual obligations.

This would allow forest owners to profit from climate benefits without depleting existing agricultural budgets.

Strict EU regulations could drive private investment toward carbon projects located outside of Europe.

Finnish farmers urge EU to adopt private carbon standards

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 29 Apr 2022

MTK rejects new EU standards, preferring existing private carbon market platforms. They want rules allowing farmers to sell credits globally. The system should provide immediate pre-financing for climate actions.

Private standards help landowners reach global markets with fewer regulatory hurdles.

Regulators lose control as private firms would handle all project verification tasks.

Bayer urges flat baseline and flexible permanence for EU carbon farming

Bayer AG, 17 Mar 2023

Bayer requests a flat standardised baseline for arable mineral soils, flexible longevity options through monitoring extensions and portfolio-wide mechanisms, and inclusion of social and economic co-benefits alongside environmental ones. They emphasize carbon removals should supplement emissions reductions, not replace them.

This would reduce transaction costs and reward their existing carbon farming initiatives.

Climate integrity suffers if removals offset emissions that should be reduced instead.

Bayer urges EU carbon removal framework with market integration

Bayer AG, 29 Apr 2022

Bayer requests a regulatory framework linked to existing emissions trading systems, result-based finance for farmers, and harmonized monitoring standards. They want certified carbon removals to be tradable in LULUCF, ESR, and eventually EU ETS markets. The framework should build on voluntary carbon markets and avoid prescribing specific farming practices.

This would create market demand for their carbon farming programs across Europe.

Environmental groups lose stronger safeguards against avoided loss crediting and baseline manipulation.

Shell urges market-based carbon removal trading system

Shell Companies, 23 Mar 2023

Shell requests a market-based mechanism for trading carbon removal credits and clarity on cross-border storage treatment. They emphasize using IPCC definitions and keeping emission reductions separate from removals.

This would enable Shell to use carbon removal credits toward its net-zero target.

Climate advocates lose if carbon removals substitute for direct emission reductions.

Shell urges EU carbon removal credit trading system

Shell Companies, 1 May 2022

Shell requests an EU certification framework allowing activity-specific methodologies based on common principles, with certified removals tradeable in compliance and voluntary markets. They advocate for technical and natural carbon removals to be recognized.

This would allow Shell to generate tradeable credits from carbon removal investments.

Climate advocates lose if credits offset fossil fuel emissions rather than drive reductions.

BirdLife urges nature-positive rules for EU carbon removal certification

Stichting BirdLife Europe, 23 Mar 2023

BirdLife calls for mandatory positive biodiversity impacts and separate accounting for emission reductions versus removals. They argue that land-based sequestration cannot be used to offset fossil fuel emissions.

Prioritizing nature-based solutions would direct financial support toward ecological restoration and biodiversity.

Industrial carbon capture developers and monoculture foresters would face exclusion from certification.

Fern demands ban on carbon offsets in EU certification

Fern, 22 Mar 2023

Fern demands a ban on carbon offsets and a shift toward activity-based certification. They want strict environmental criteria and the exclusion of emission reductions from the framework.

This would secure direct funding for restorative farming practices rather than administrative carbon monitoring.

Carbon market intermediaries and industrial lobbies lose their financial and regulatory grip on certification.

Eni urges including carbon credits in the EU carbon market

Eni S.p.A., 2 May 2022

Eni suggests allowing companies to use carbon removal credits to meet carbon market rules. They also advocate for better infrastructure for transporting and storing captured carbon.

New rules would create demand and increase the market value of their technologies.

Environmental groups lose if credits are used to avoid reducing actual factory emissions.

FoodDrinkEurope Urges Value Chain Focus for Carbon Removal Certificates

FoodDrinkEurope, 20 Mar 2023

The organization requests carbon removal certificates be used within the food value chain. They argue food production must remain the primary priority for farmers.

Food manufacturers would lower their environmental footprint by claiming removals from suppliers.

Other industrial sectors lose out on buying agricultural carbon offsets to compensate emissions.

FoodDrinkEurope Urges Keeping Carbon Credits Within Agri-Food Chains

FoodDrinkEurope, 2 May 2022

FoodDrinkEurope calls for a system that keeps carbon removals within the agricultural sector to meet targets. They also want rewards for farmers who already maintained carbon stocks before the new rules.

This allows food processors to claim emission reductions within their own supply chains at lower cost.

Non-food industries lose access to cheaper agricultural offsets if credits are restricted to food value chains.

Neste Urges Alignment Between Carbon Certification and Renewable Rules

Neste Oyj, 2 May 2022

Neste wants the framework to align with existing renewable energy rules. They suggest removals should either offset emissions or be included in product footprint calculations. Finally, they recommend using voluntary schemes to manage certification.

This would help Neste reduce the life-cycle carbon footprint of its sustainable fuel products.

Operators of biomass combustion for heat and power would see their technology excluded from promotion.

Consultation response

Deutscher Bauernverband, 23 Mar 2023

Bitte beachten Sie die beigefügte Stellungnahme des Deutschen Bauernverbandes.

German Farmers' Association urges uniform carbon certification standards

Deutscher Bauernverband, 2 May 2022

The association demands a uniform, scientifically sound, and practical standard for measuring carbon sink performance. They argue that widespread carbon storage in soil requires long-term additional compensation and should be funded through the emissions trading system.

Standardized rules would provide farmers with financial security and reliable income from climate services.

Industrial sectors would lose revenue as funds from the emissions trading system are diverted.

Fortum urges EU to recognize waste-derived carbon in removals

Fortum Oyj, 7 Feb 2023

Fortum requests that the definition of carbon removal include waste-derived carbon from incineration. They also suggest the framework support carbon capture in products without requiring geological-level permanence.

This allows Fortum to monetize carbon captured from their incineration and plastic production operations.

Climate groups lose if the framework certifies fossil-based carbon capture as a permanent removal.

Iberdrola backs carbon removal certification focused on hard-to-abate sectors

IBERDROLA, 23 Mar 2023

Carbon removals should focus on residual emissions in sectors where no other solution is available. Iberdrola requests a central registry and clear definitions for long-term storage to ensure transparency.

This framework protects Iberdrola's renewable business by preventing low-quality removals from undermining mitigation efforts.

Fossil fuel industries lose as the proposal excludes them to prevent technological lock-in.

Iberdrola calls for strict fossil-free carbon removal certification

IBERDROLA, 2 May 2022

Iberdrola argues that removals should exclude any processes relying on fossil fuels to prevent carbon lock-ins. They recommend a certification system based on robust monitoring and verification to ensure removals are additional and permanent.

Standardized certification would provide investment signals and boost the credibility of Iberdrola’s climate-neutral claims.

Industrial players using carbon capture on fossil-fueled processes would be excluded from certification.

Ørsted urges differentiated standards for carbon removal certification

Ørsted A/S, 23 Mar 2023

Ørsted proposes that the scheme reflects differences between nature-based and technological projects more explicitly. Sustainability requirements should align with existing legislation to avoid burdensome regulatory inconsistency. The framework should not assume carbon re-emission immediately after monitoring periods end.

Aligning with existing rules would reduce administrative costs and facilitate project deployment.

Private certification schemes could face reduced competition from universal EU requirements.

GE urges EU to include carbon capture in removal certification

General Electric Company, 29 Apr 2022

GE recommends certifying carbon reduction technologies like CCS alongside removals for the next decade. They also favor integrating carbon removal certificates into the EU Emissions Trading System.

GE would secure financial incentives and regulatory recognition for its existing gas power decarbonization technologies.

Private carbon certifiers could lose their market influence as the EU standardizes removal regulations.

Finnish Energy Demands Rapid Certification for Industrial Carbon Removals

Finnish Energy - Energiateollisuus ry, 2 May 2022

They call for a swift certification framework for industrial carbon removals by 2026. Industrial processes should be fast-tracked independently from the more complex carbon farming sector.

The framework would enable energy companies to monetize removals and attract private funding.

Carbon farming initiatives could lose political priority if industrial removals are fast-tracked.

European Paper Industry Demands Recognition for Biogenic Carbon Storage

Confederation of European Paper Industries, 20 Mar 2023

The framework should "be explicit about different types of sustainable carbon sources" and define "renewable carbon." They want the "upcoming certification" to "recognise the substitution effects" of "renewable, bio-based products." They recommend "aligning the upcoming certification with existing EU methodologies" for assessing climate benefits.

This would create a market for renewable carbon, increasing the competitiveness of wood products.

Fossil-intensive industries lose market dominance as policies incentivize wood-based materials as climate-friendly alternatives.

IFOAM Urges Carbon Certification to Reward Organic Farming Frontrunners

International Federation of Organic Agriculture Movements EU Regional Group, 23 Mar 2023

They want management-based certification that rewards ecological practices rather than just carbon results. The framework should promote biodiversity and ensure frontrunners like organic farmers are not penalized. Social safeguards must also be included to prevent land price inflation and land grabbing.

Organic farmers would receive financial recognition for maintaining existing soil health and carbon.

Industrial sectors lose access to easy carbon offsets used to delay emissions reductions.

Consultation response

International Federation of Organic Agriculture Movements EU Regional Group, 29 Apr 2022

While climate mitigation should clearly prioritise absolute emissions reductions, carbon sequestration in the land sector can contribute to long-term climate objectives. Carbon sequestration should be additional to reduction efforts and not disincentivise them. However, the adoption of beneficial…

BDEW urges EU to integrate carbon removals into emissions trading

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 22 Mar 2023

BDEW wants EU-wide trade of removal certificates and integration into the Emissions Trading System. They request faster certification for industrial projects and simpler rules for calculating emission baselines.

Joining the emissions market would create new business models for energy plant operators.

Environmental protections may be weakened if the proposal's strict sustainability criteria are relaxed.

RWE Urges Pragmatic EU Certification for Carbon Removals

RWE AG, 22 Mar 2023

RWE calls for a pragmatic certification system that separates technical development from political influence. They request prioritizing methodologies for permanent industrial technologies like DACCS and BECCS to ensure a fast ramp-up.

This would allow RWE to monetize removals by integrating them into the EU-ETS market.

Environmental groups could see weaker sustainability protections if stricter taxonomy-based criteria are abandoned.

Equinor urges clarity on carbon removal certification definitions and eligibility

Equinor ASA, 20 Mar 2023

Equinor requests precise definitions that separate removals from reductions, clarification on which solutions qualify, and flexibility to include emerging technologies. They want all CDR options eligible and clear treatment of cross-border storage.

This would ensure their diverse carbon removal technologies and cross-border projects qualify for certification.

Equinor urges EU to support CCS alongside nature-based carbon removals

Equinor ASA, 29 Apr 2022

The organization requests that both emission reductions and removals be supported, including CCS technology from fossil sources. They argue reduction technologies should not be deferred and recommend including reduction credits in a future EU carbon market compatible with the EU ETS.

This would enable them to monetize their existing CCS technology and infrastructure investments.

CEMBUREAU demands EU recognition for concrete carbon removal potential

CEMBUREAU - The European Cement Association, 21 Mar 2023

The association wants the EU to certify biogenic CO2 capture and concrete carbonation as permanent carbon removals. They also propose making these certificates tradable within the existing EU emissions trading system.

This would allow cement companies to generate tradable credits and offset their industrial emissions.

The timber sector is disadvantaged by recommendations to exclude wood products from carbon removal certification.

E.ON Urges Swift EU Carbon Removal Certification for Investors

E.ON SE, 22 Mar 2023

E.ON requests the framework becomes operational by 2025 to provide investors with foresight. They advocate for market quotas and distinct certificate sub-categories to reward permanent carbon storage solutions.

A clear certification timeline and market quotas would de-risk E.ON's large-scale industrial investments.

Rural industrial areas could face migration if emissions from long transport routes are penalised.

E.ON urges swift EU carbon removal certification framework

E.ON SE, 2 May 2022

E.ON calls for a swift establishment of a framework for the certification of carbon removals. It requires a clear delimitation from carbon market allowances to avoid double counting. The company believes open access to transport and storage infrastructure is important.

Valuable carbon removals will incentivize E.ON to invest in the needed infrastructure.

Providers of fossil fuel carbon capture face a diminishing market in the long term.

Swedish Forest Industries urge focus on active management and BECCS

Swedish Forest Industries Federation, 2 May 2022

The federation calls for a framework prioritizing active forest management and wood harvesting. They advocate for financial support for BECCS and inclusion in existing accounting systems. They also argue that additionality is an arbitrary concept for managed forests.

This would secure their raw material supply while providing subsidies for industrial carbon capture.

Environmental groups lose influence as the industry prioritizes wood harvesting over passive forest conservation.

Coldiretti demands direct financial rewards for agricultural carbon removals

Confederazione Nazionale Coldiretti, 23 Mar 2023

Coldiretti requests a certification system ensuring direct economic compensation for agricultural carbon sequestration. They advocate for simplified procedures so small farms avoid complex bureaucratic burdens.

This framework would enable farmers to create new income from their environmental services.

Environmental goals are undermined if farmers monetize capture activities they already perform.

SUEZ Group calls for recognition of hybrid carbon removal methods

SUEZ Group, 23 Mar 2023

SUEZ recommends that the framework better promote Bioenergy Carbon Capture and Storage, biochar, and compost. They suggest creating a new 'hybrid-based solution' category for methods combining nature and technology. The group also urges aligning certification baselines with existing voluntary market standards.

This would allow SUEZ to monetize its waste management activities through carbon certificates.

European Biogas Association urges recognition of biogenic CO2 removals

European Biogas Association, 2 May 2022

The group seeks a certification mechanism covering biogenic CO2 storage and sustainable farming. They demand harmonization with existing energy laws to ensure the system remains practical. They also call for rules allowing certificate trading on voluntary carbon markets.

This would create new revenue streams for biogas producers by monetizing their carbon-capturing by-products.

Fossil-fuel based manufacturers would face increased competition from newly incentivized recycled bio-based materials.

German chemical industry urges linking carbon removals to EU-ETS

Verband der Chemischen Industrie e.V., 17 Mar 2023

VCI requests that the Commission "allow the usage of carbon removal certificates for compliance in EU-ETS". They argue "chemical recycling... should be officially recognized as an additional feedstock" and advocate for incentivizing "emission capture from point sources".

This would provide the sector with flexible balancing options for residual emissions.

Direct air capture developers lose out to favored industrial point-source technologies.

German chemical industry urges broad definitions for carbon removal

Verband der Chemischen Industrie e.V., 2 May 2022

VCI demands broad definitions for carbon removals including chemical recycling. They want all non-fossil carbon contributions recognized as sustainable.

This would reduce compliance costs by certifying existing industrial recycling processes.

Environmental groups lose if the framework rewards temporary emission delays.

Consultation response

European Coordination Via Campesina, 23 Mar 2023

ECVC does not welcome positively the current CRCF proposal as it ignores serious concerns it addressed to the EC: https://lstu.fr/letter-cf-ecvc Here ECVC will focus on elements related to land and agriculture. The recent release of the IPCC report was an alarming reminder of the climate change…

Consultation response

European Coordination Via Campesina, 2 May 2022

We see many issues in the present call for contributions. The document suggests a mechanism that leads the way to carbon market which are highly problematic not only for small and medium scale farming in Europe, but also for the entire food system, land tenure and resource challenges. The EU should…

Air Liquide Urges Flexible Certification for Industrial Carbon Capture

AIR LIQUIDE, 2 May 2022

Air Liquide wants a flexible certification scheme that avoids administrative burdens on companies. They argue low-carbon hydrogen using carbon capture should be supported alongside renewable options.

This would help the company secure funding and deploy industrial carbon capture technologies faster.

Advocates for renewable-only energy lose if funding is diverted to low-carbon industrial projects.

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 6 Apr 2022

Feedback to EU-Commission regarding certification of carbon removals The Danish Agriculture and Food Council (DAFC) welcomes the possibility to contribute to the hearing on certification of carbon removals. The DAFC acknowledges that carbon removals cannot replace emission reductions but is an…

Carbon Market Watch Demands Separate Targets to Protect Climate Action

Carbon Market Watch, 2 Mar 2023

Removals must supplement deep emission reductions rather than serving as offsets for polluters. Policymakers should establish a dedicated separate target and exclude temporary storage methods like carbon farming. The framework must ensure permanent storage for at least two centuries to be considered valid.

This ensures the framework prioritizes climate integrity rather than creating revenue for specific actors.

Industrial polluters would lose the opportunity to delay real emission reductions through cheap offsetting schemes.

Carbon Market Watch warns certification scheme risks legitimising offsetting

Carbon Market Watch, 2 May 2022

The organization demands the certification mechanism set strict conditions ensuring only high-quality removals qualify, including comprehensive life cycle assessments and permanent storage monitoring. They argue removals must supplement rather than replace emissions reductions and oppose using certified units for offsetting in trading schemes like the ETS.

This would prevent their climate advocacy being undermined by false equivalences between emissions and removals.

Climate goals lose if offsetting diverts resources from emissions reductions to questionable removal schemes.

Vattenfall urges priority for industrial carbon removals by 2026

Vattenfall, 23 Mar 2023

Vattenfall requests that the certification system becomes fully operational by 2026. They argue industrial removal methodologies should be adopted quickly, while ensuring credits go to the company capturing the emissions.

This would provide Vattenfall with direct financial rewards and regulatory certainty for its carbon capture projects.

Carbon farming initiatives face potential delays and stricter scrutiny compared to the company’s preferred industrial methodologies.

Metsä Group calls for certification of wood-based carbon storage

Metsäliitto Cooperative, 23 Mar 2023

The group advocates for recognizing wood-based products as legitimate carbon storage solutions. They request clear definitions that distinguish renewable biogenic carbon from fossil-based sources. Active forest management must be supported to ensure a steady supply of raw materials.

Certification would incentivize investments in bio-based technologies and protect production volumes.

Environmental groups lose if policy shifts from strict protection to active management.

Vattenfall urges faster and more ambitious industrial carbon removal certification.

Vattenfall, 2 May 2022

Vattenfall requests an operational certification system by 2026 that prioritizes industrial solutions. They also advocate for higher 2030 targets and ensuring credits reward the capturing companies.

This would create financial incentives and market value for Vattenfall's bio-energy projects.

Nature-based projects may face delays as Vattenfall pushes for industrial priority.

Young farmers urge fair rewards in carbon removal certification

CONSEIL EUROPEEN DES JEUNES AGRICULTEURS, 22 Apr 2022

CEJA requests a certification system focusing on actions rather than results during the initial stages. They advocate for remuneration that covers both implementation costs and income foregone.

The framework would provide young farmers with new revenue streams and soil quality.

New farmers may face higher barriers due to increased land competition and costs.

Consultation response

Environmental Coalition on Standards, 20 Mar 2023

Having assessed the Proposal for establishing a Union certification framework for carbon removals (CRCF), ECOS would like to highlight some fundamental features we consider highly problematic and that need to be taken into account to ensure the proposed framework is trustworthy and avoids…

German Utilities Urge Water Protection and Carbon Removal Incentives

Verband Kommunaler Unternehmen e.V., 10 Mar 2023

The VKU calls for robust water resource protection and technology neutrality for carbon capture. They advocate for integrating certification into the EU Emissions Trading System to ensure economic viability.

This would create market-based incentives for municipal waste treatment and ensure planning security.

The European Commission loses unilateral power over environmental standards through the requested procedural changes.

Repsol urges EU to provide financial certainty for carbon removals

Repsol, S.A., 23 Mar 2023

Repsol calls for a framework prioritizing emission reductions and providing financial certainty. They advocate for robust carbon accounting including carbon capture and use in products. The regulation must ensure consistency with existing policies like the EU Emissions Trading System.

A harmonized framework would secure returns on massive investments in industrial storage infrastructure.

Environmentalists may challenge the inclusion of commercial forestry exploitation as a removal activity.

Consultation response

Veolia Environnement, 21 Mar 2023

We welcome the European Commissions proposal for a Carbon Removal Certification Framework (CRCF) put forward in November last year with the aim to develop a trustworthy system to quantify and valorise removals and achieve climate neutrality by 2050. The proposal outlines the start of a process that…

Repsol urges EU to integrate carbon removals into ETS

Repsol, S.A., 29 Apr 2022

Repsol supports a technology-neutral framework that integrates removal certificates into the EU trading system. They recommend using existing voluntary market standards and international rules for immediate implementation.

This allows the company to meet climate targets through removal credits and geological storage.

Stora Enso Urges Separate EU Certification for Biogenic Carbon

Stora Enso Oyj, 20 Mar 2023

Differentiate between fossil and biogenic removals to prevent carbon storage from masking high emissions. Include biogenic removals in the land-use framework and ensure additionality rules are workable.

This validates their wood products as carbon sinks and incentivizes their industrial carbon capture investments.

Fossil fuel companies lose the ability to obscure emissions by combining them with biogenic accounting.

German NGO BUND slams EU carbon removal plan as distraction

Bund für Umwelt und Naturschutz Deutschland e. V., 23 Mar 2023

The organization opposes the proposal, arguing it delays climate action and protects fossil fuels. They demand excluding industrial carbon removal and carbon farming from certification.

A rejection of the proposal would protect the group's priority investments in renewable energy.

The fossil fuel industry loses its primary mechanism for maintaining business as usual.

Bioenergy Europe urges permanent removal status for biochar technology

Bioenergy Europe, 22 Mar 2023

The organization requests clarification of permanence criteria to include biochar and other novel removal technologies, not just those under the CCS Directive. They seek harmonization with existing bioenergy sustainability requirements in RED to minimize administrative burdens.

This would allow bioenergy producers to certify biochar as permanent removal and avoid conflicting requirements.

UPM urges EU recognition for bio-based carbon storage products

UPM-Kymmene Oyj, 2 May 2022

UPM advocates for a technology-neutral system that rewards carbon storage in bio-based products. They want the framework to align with existing sustainability certifications.

UPM would gain market value and competitive advantages for its renewable material solutions.

Fossil-based material producers lose market share as demand shifts toward bio-based alternatives.

Bioenergy Europe Urges EU Carbon Removal Framework with Economic Incentives

Bioenergy Europe, 2 May 2022

The organization requests a robust certification mechanism with economic incentives for negative emission technologies, including technology-neutral approaches and multiple approved methodologies. They emphasize the urgency of immediate implementation to meet 2050 climate targets.

This would create revenue-generating markets to support and upscale bioenergy carbon capture technologies.

Forest owners call for simple carbon removal certification rules

Conféderation Européenne des Propriétaires Forestiers, 8 Mar 2023

CEPF demands simple and implementable rules for monitoring and verifying carbon credits. They request that all wood-based products are included in the certification framework. The organization warns against a one-size-fits-all approach to certification criteria preparation.

A voluntary certification framework allows forest owners to diversify their income streams.

Environmental groups lose if biodiversity and restoration requirements are delayed or omitted.

European forest owners urge voluntary, market-based carbon removal certification

Conféderation Européenne des Propriétaires Forestiers, 2 May 2022

All sustainable forest management practices and wood products should be incentivised. The framework must be voluntary and market-based, establishing only minimum standards. It should not result in restrictions on sustainable harvesting levels.

This allows forest owners to monetize wood products and maintain existing commercial operations.

Environmental groups lose if the framework prioritizes commercial harvesting over strict forest conservation.

PepsiCo seeks preferential carbon credit access for food producers

PepsiCo, 29 Apr 2022

PepsiCo recommends building the framework on international standards while rewarding historical carbon sequestration efforts. They propose granting food manufacturers 30-day preferential access to nature-based carbon credits. The system must also ensure carbon storage does not prioritize sequestration over food security.

This would allow PepsiCo to secure affordable credits and meet climate targets within their own supply chain.

Non-food sectors would face restricted access and higher prices for nature-based carbon offsets.

Consultation response

Rabobank, 23 Feb 2022

Carbon farming: Four actions the EU can take to make it happen. See also enclosed doc or use the link: https://economics.rabobank.com/publications/2022/february/carbon-farming-four-actions-the-eu-can-take-to-make-it-happen/ Summary: Based on our own experience in pilots, we share four actions…

European feed industry seeks verified carbon removal accounting

Fédération Européenne des Fabricants d'Aliments Composés, 22 Mar 2023

FEFAC supports the proposal to ensure suppliers deliver credible and verified solutions. They also request incorporating carbon removal accounting into life cycle assessment calculations.

This would help the sector manage unavoidable emissions to reach neutrality.

Providers of uncertified carbon removal schemes may lose market access.

Consultation response

Bellona Europa, 23 Mar 2023

Bellona Europa is an independent, non-profit organisation that meets environmental and climate challenges head on. We are solutions-oriented and have a comprehensive and cross-sectoral approach to assess the economics, climate impacts and technical feasibility of necessary climate actions. To do…

European Dairy Association urges recognition for existing soil carbon

European Dairy Association aisbl, 21 Mar 2023

EDA requests that the framework includes GHG reductions and rewards maintenance of existing soil carbon. They argue the system must be practically manageable and avoid unnecessary administrative burdens.

Dairy producers would gain a new income stream by monetizing existing pastureland carbon storage.

Climate groups lose if credits are issued for existing practices without proving additionality.

European Dairy Association wants rewards for intensive farming carbon removals

European Dairy Association aisbl, 29 Apr 2022

The EDA requests that certification includes intensive farming and keeps removals within the food value chain to meet sector targets. They also advocate for rewarding frontrunners who have already sequestered large volumes of carbon in their soils.

This approach would turn carbon sequestration into a profitable business model while helping dairy producers offset their own livestock emissions.

Non-agricultural industries lose access to offsets if carbon credits are restricted for use within the food value chain.

Austrian farmers demand clearer rules for carbon removal certification

Landwirtschaftskammer Österreich, 23 Mar 2023

The group wants key rules in the main law rather than secondary legislation. They seek shorter monitoring periods for carbon storage and clearer starting points. Farm-level requirements should not be linked to national land use targets.

This would allow farmers to earn more money while avoiding multi-generational commitments.

Climate goals are weakened if carbon storage is temporary rather than lasting centuries.

Carbon Gap pushes for stricter EU carbon removal certification

Carbon Gap ASBL, 23 Mar 2023

They demand the exclusion of emission reductions from the definition of carbon removals. They want strict rules on certificate use to prevent greenwashing and deterrence of climate action. The group also calls for clearer storage categories based on durability.

Robust standards would increase the market value and credibility of high-quality removal projects.

Fossil fuel emitters would face higher costs if forced to use permanent removals.

Swedenergy urges separate, faster certification for industrial carbon removals

Energiföretagen / Swedenergy, 28 Feb 2023

The group suggests separating industrial removal from carbon farming to avoid delays. They also advocate for higher 2030 targets and including funding information in certificates.

Faster certification helps energy companies secure investment and launch large-scale carbon capture projects.

Environmental groups lose protections if the industry successfully lobbies to weaken project sustainability criteria.

Swedenergy urges fast-tracked certification for industrial carbon removals

Energiföretagen / Swedenergy, 2 May 2022

Swedenergy requests that the certification framework is implemented by 2026 to support early industrial projects. They advocate for separating industrial removals from carbon farming to ensure a quicker certification process.

This framework would enable member companies to access essential funding and private markets.

The carbon farming sector may face slower regulatory progress if decoupled from industry.

Eurima urges permanent storage focus in carbon removal certification

European Insulation Manufacturers Association, 23 Mar 2023

Eurima requests that the EU prioritise permanent storage and use standard life cycle assessment methodologies. They believe certification must require proof of ecological management to prevent market distortions.

This ensures mineral wool producers avoid competitive disadvantages against materials claiming temporary carbon storage.

Bio-based material producers lose the advantage of accounting methods that favor early-life carbon sequestration.

Insulation manufacturers urge separate accounting for carbon removals

European Insulation Manufacturers Association, 2 May 2022

Eurima requests that carbon removals be accounted for separately to ensure priority remains on reducing emissions. They support using established European standards for life cycle assessments instead of simplified national models.

This prevents competitors from using skewed carbon storage accounting to hide their total environmental impacts.

Future generations lose out when emissions and environmental impacts are shifted into the future.

FEAD urges carbon removal certification for waste recycling technologies

FEAD, 23 Mar 2023

The framework must include carbon capture and utilisation technologies as removal activities. Certification should cover carbon from waste and products with short lifespans. Organic recovery from biowaste must be explicitly recognized as carbon removal.

This would ensure financial incentives and investment security for waste management infrastructure.

Arla Foods urges simple carbon removal rules for dairy farmers

Arla Foods amba, 20 Mar 2023

Arla Foods advocates for simple methodologies to minimize administrative burdens for farmers. They suggest the framework recognize past efforts and include various emission reduction activities.

Simplifying rules and rewarding past actions would reduce costs for cooperative members.

Enagás advocates for carbon removal standards supporting synthetic gas infrastructure

Enagás S.A., 1 May 2022

The EU should create a common standard that interacts with the ETS and renewable gas certificates. The scheme must recognize industrial carbon capture and utilization from fossil fuel sources. Certificates should help lower prices for synthetic fuels like e-methane to aid industrial decarbonization.

This would allow Enagás to utilize its existing gas storage and infrastructure for new fuels.

Environmental groups lose if carbon reuse from fossil fuels is certified as permanent removal.

IKEA Urges Strict Standards for EU Carbon Removal Certification

Inter Ikea Systems BV, 23 Mar 2023

IKEA wants the framework to prioritize emission reductions and certify only long-term storage. They also propose including wood-based furniture as a valid form of carbon storage.

IKEA could certify its vast inventory of wood-based products as legitimate carbon storage.

Industrial emitters like cement producers would be disqualified from being labeled as carbon removers.

CCSA Urges Clear Standards for Permanent Engineered Carbon Removals

Carbon Capture & Storage Association, 23 Mar 2023

The CCSA requests a robust definition of carbon removals that distinguishes them from emissions reductions. They advocate including waste-to-energy and trans-boundary storage within the certification framework.

These rules would create new revenue streams and investment certainty for industrial CCS.

Nature-based storage providers may see their credits devalued against geological solutions.

Energy Traders Europe backs EU-wide carbon removal certification framework

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 23 Mar 2023

The group recommends fast-tracking methodologies for industrial removals and increasing 2030 targets. They also propose replacing the five-year recognition limit with regular reviews.

A common standard would enable the trading of certificates in liquid markets.

Stricter sustainability criteria than existing rules could hinder negative emission technology developments.

Green Transition Denmark warns against carbon farming and offsetting

Rådet for Grøn Omstilling, 23 Mar 2023

The organization insists that emission reductions are not removals and should not be certified. They call for separate targets to prevent greenwashing through offsetting.

This would ensure their environmental standards are adopted while preventing policy integrity failures.

Agricultural and industrial sectors would lose revenue from temporary or non-permanent storage methods.

Negative Emissions Platform urges broader permanent carbon removal labels

Negative Emissions Platform, 23 Mar 2023

NEP asks that permanence labels include biochar and other novel removal methods. They also request alignment with existing EU laws to reduce administrative burdens.

Broadening labels allows NEP's diverse technology members to qualify for premium carbon certifications.

Traditional geological storage providers would lose their exclusive status as the only permanent solution.

Negative Emissions Platform seeks tailored rules for carbon removal certification

Negative Emissions Platform, 2 May 2022

NEP requests the timely implementation of a framework using method-specific assessments for different technologies. They advocate for a competitive verification system involving private companies and existing standards. The group emphasizes that industrial removals need dedicated rules to reflect their permanence.

Tailored standards and private verification would lower administrative costs and reduce regulatory uncertainty for developers.

Providers of non-permanent storage solutions face implementation delays due to more complex monitoring and reporting requirements.

Energy Traders Europe backs harmonised carbon removal certification

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 29 Apr 2022

Energy Traders Europe calls for standardized carbon removal rules to expand voluntary markets. They propose making certificates freely tradable and eventually integrating them into the EU ETS.

A unified market would reduce barriers for traders moving carbon instruments between countries.

Sellers of unverifiable carbon offsets will be disqualified from the regulated market.

Compassion in World Farming urges livestock cuts for climate

Compassion in World Farming Brussels, 19 Apr 2022

Carbon removals cannot replace deep emission cuts. The EU should prioritize a significant reduction in the number of animals kept for food production.

Mandatory animal reduction would help the organization achieve its goal of ending factory farming.

Industrial animal agriculture would lose its dominant position in European food systems.

KWS urges inclusion of carbon avoidance in EU certification

KWS SAAT SE Co. KGaA, 9 Mar 2023

KWS proposes expanding the certification scheme to include carbon avoidance measures alongside carbon removal activities. They argue that high-performing seeds significantly reduce agricultural emissions through increased input efficiency.

Including avoidance would boost demand for KWS’s proprietary seeds and hybrid crop varieties.

Early adopters of soil carbon practices may face a competitive disadvantage compared to others.

Zero Emissions Platform urges clear permanent carbon storage rules

Zero Emissions Platform, 23 Mar 2023

ZEP demands a robust definition that excludes mere emission reductions from removals. They also want biogenic carbon capture in the waste-to-energy sector to be eligible for certification.

Granting industrial removals certification would unlock significant new revenue for the waste sector.

Nature-based projects lose their equal status if the framework prioritizes geological storage.

Consultation response

Zero Emissions Platform, 25 Mar 2022

The feedback of the Zero Emissions Platform can be found in attachment.

JBCE seeks flexibility for temporary carbon storage certification

Japan Business Council in Europe, 22 Mar 2023

JBCE requests flexibility in defining storage periods to include temporary solutions like e-fuels and carbon farming. They also call for better alignment with existing carbon credit systems to simplify compliance for businesses.

This would reduce regulatory hurdles and lower compliance costs for Japanese firms.

Environmental advocates may fear that short-term storage increases the risk of re-emissions.

Drax Urges EU Support for Bioenergy Carbon Removal Technology

Drax Group plc, 20 Mar 2023

Drax requests appropriate business models like Carbon Contracts for Difference to scale up. They also urge assessing the role of carbon removals in the EU ETS. Finally, they suggest a consistent approach for the sustainability of biomass.

This framework would provide the financial clarity needed to attract major investments.

Non-sustainable producers lose as zero rating remains conditional on meeting sustainability requirements.

I4CE Urges EU to Include Emissions Reductions in Carbon Certification

Institute for Climate Economics, 29 Apr 2022

They recommend certifying both carbon removals and greenhouse gas emission reductions. The Commission should also allow shared claims between companies and countries.

This approach would increase the influence of their established French certification model.

Campaigners may argue that double-counting and early credits reduce actual climate progress.

Conservation International urges empirical risk accounting for carbon farming

Conservation International Europe, 22 Mar 2023

The organization requests that the Commission replace the assumption of total carbon loss with empirical evidence. They argue the current proposal creates an artificial bias against nature-based solutions.

This would allow projects to monetize climate benefits without facing an inequitable double-standard.

Flawed accounting creates perverse incentives for harvesting wood, harming forest ecosystems and climate goals.

European waste-to-energy plants urge carbon removal certification

Confederation of European Waste-to-Energy Plants, 23 Mar 2023

CEWEP requests a platform for negative emissions accounting and market mechanisms to recognize carbon removals. They highlight that carbon capture technologies could turn waste plants into net negative emission sources.

This framework would provide legal security for investments and stimulate broader technological development.

State foresters demand long-term climate focus in carbon certification

European State Forest Association, 14 Mar 2023

EUSTAFOR insists that certification must prioritize active forest management over short-term offsets for polluters. They argue that methodologies should recognize existing state efforts and include national experts.

This ensures state foresters receive financial recognition for their ongoing and historical carbon sequestration efforts.

Heavy polluters lose the ability to use forest offsets to avoid reducing fossil fuel emissions.

EUSTAFOR urges EU to include wood products in carbon certification

European State Forest Association, 2 May 2022

The organization calls for a holistic approach that recognizes the carbon storage potential of forest-based products. They emphasize that sustainable forest management already contributes to mitigation and warn against unfair additionality requirements. The framework must acknowledge existing synergies with the bio-based circular economy to avoid greenwashing.

This would allow state forest organizations to maintain harvesting levels while receiving climate credits.

The bioeconomy and wood-reliant industries suffer if policies prioritize forest sinks over harvesting.

Waste-to-Energy industry backs EU carbon removal certification framework

Confederation of European Waste-to-Energy Plants, 2 May 2022

CEWEP seeks a clear platform for negative emissions accounting and market mechanisms. They want waste-to-energy to be recognized as a net negative emissions energy source.

Certification would provide legal security for investments and stimulate technological development.

Bundesdruckerei Demands National Centralization of Carbon Removal Certification

Bundesdruckerei GmbH, 23 Mar 2023

Bundesdruckerei recommends establishing a territorial principle with one central certification system per member state. They request high-level identity management using eIDAS standards for all system participants to ensure security. Furthermore, they seek a strict separation of roles between certification systems and other market actors.

Centralizing certification per state would create demand for their national identity and security services.

International certification schemes lose the ability to operate across different European national borders freely.

Bio-based industries demand affordable, science-based carbon removal certification

Bio-based Industries Consortium, 2 May 2022

BIC wants credits for substituting fossil products with renewable alternatives. They demand manufacturers receive rewards for taking innovation risks. Schemes must remain affordable for industry compliance.

This framework would lower compliance costs and secure financial credits for bio-based producers.

Fossil fuel companies face reduced demand as the policy shifts toward renewable feedstock.

Consultation response

Shopify Inc., 1 May 2022

Please find attached Shopify's comments.

Valmet urges EU to clarify rewards for technological carbon removals

Valmet Oyj, 6 Mar 2023

Valmet requests clear guidelines on how certificates are used to ensure rewards for high-cost technological investments. They also propose an EU fund to manage carbon release risks and want bioenergy rules to match existing standards.

This would secure financial returns for Valmet's technologies and prevent new, burdensome regulatory hurdles.

The voluntary carbon market would lose flexibility if certificates are banned from offsetting emissions.

Agroecology Europe urges systemic farming redesign for carbon certification

Agroecology Europe, 2 May 2022

They recommend redesigning food systems following agroecological principles to restore soil carbon stocks. The group warns against a limited market-based approach that ignores the social and economic complexities of agriculture.

This framework would scale up agroecological practices by remunerating farmers for providing essential ecosystem services.

Young farmers and newcomers may face higher land prices due to speculation from carbon markets.

Consultation response

European Industrial Hemp Association, 2 May 2022

The European Industrial Hemp Association (EIHA) welcomes and fully supports the European Commission’s vision and commits to work with EU bodies with the aim of pursuing the Green Deal objectives and contributing to the recovery of the EU Economy. EIHA intends to focus particularly on highlighting…

German Potash Industry Urges Flexible Carbon Removal Rules

Verband der Kali- und Salzindustrie e.V., 22 Mar 2023

The organization calls for a distinct separation between carbon removals and reductions to ensure precise accounting. They also propose an operational definition of permanence to facilitate a faster transition for European farming systems.

Flexible certification standards would lower compliance barriers for the potash sector's agricultural products.

Climate groups lose if permanence requirements are weakened during the proposed transition period.

Starch Europe seeks priority access to carbon removal certificates

STARCH EUROPE, 20 Mar 2023

Starch Europe wants certificates from carbon farming used for scope 3 accounting. They request preferential access or first refusal for certificates generated in their chain.

This allows companies to claim removals within their supply chain and reduce emissions.

Other sectors face reduced availability of carbon credits if agri-food firms get priority.

Czech business chamber demands clearer carbon removal definitions

Hospodářská komora České republiky, 17 Mar 2023

The group requests clearer storage definitions and wants the Commission to manage the registry. They demand that registries only list valid certificates and keep audit reports private.

Operators would protect their sensitive business data and face more predictable certification rules.

Transparency groups lose access to the detailed evidence used to verify carbon removal claims.

European Bioplastics seeks carbon removal certification for bio-based products

European Bioplastics, 2 May 2022

The industry requests that the framework recognizes biogenic carbon captured in bio-based plastics. They also seek the inclusion of recyclable bio-plastics to ensure market fairness.

Certification would enhance the competitiveness of bio-based products against fossil-based alternatives.

The fossil fuel sector faces reduced demand as Europe transitions to bio-based materials.

Consultation response

DNV, 22 Mar 2023

DNV welcomes the Commissions effort to develop a reliable, transparent and high-quality certification system for carbon removal technologies within the EU in addition to the significant mitigation work already in place and in the making. It is DNVs view that: All available removal technologies…

Wood panel industry seeks carbon certification for timber products

European Panel Federation, 20 Mar 2023

EPF requests including harvested wood products in the certification framework. They want rewards for carbon storage in furniture and construction. Policies should prioritize material use over burning wood for energy.

This would increase market demand for wood and provide new financial rewards.

Conservationists lose as set-aside programs might be restricted to maintain timber supply.

European Panel Federation seeks carbon credits for wood products

European Panel Federation, 27 Apr 2022

EPF requests certifying carbon storage in harvested wood products like construction and furniture. They advocate for active forest management instead of strictly protecting forest areas.

This would create new business models and increase market competitiveness for wood-based panels.

Environmental groups lose if forest set-aside programs are deprioritized in favor of logging.

German cement industry seeks ETS inclusion for carbon removals

Verein Deutscher Zementwerke e.V., 23 Mar 2023

The industry calls for separating technical sinks from natural ones to ensure accounting reliability. They want carbon removal units integrated into the carbon market to provide investment certainty. Additionally, only permanent storage solutions should be acknowledged.

This would provide financial incentives and legal certainty for expensive carbon capture investments.

Environmental groups may see weakened safeguards if sustainability criteria are relaxed for industrial projects.

CCU Industry Urges Recognition of CO2 Mineralisation as Permanent Carbon Removal

CO2 Value Europe AISBL, 22 Mar 2023

The organization requests clear recognition of CCU technologies that permanently store atmospheric or biogenic carbon, particularly CO2 mineralisation in construction products, as carbon removals in the legislation. They want definitions precise enough to avoid confusion but broad enough not to exclude future innovations.

This would allow their mineralisation technologies to qualify for carbon removal certificates and ETS exemptions.

CO2 Value Europe calls for CCU technologies recognition as carbon removals

CO2 Value Europe AISBL, 2 May 2022

The association requests recognition of carbon capture and utilisation technologies as carbon removals when CO2 is captured from air or biogenic sources and stored durably in materials. They want clear principles and legal certainty for investing in CCU technologies that lead to negative emissions.

This would enable their 70+ member organizations to claim carbon removal credits for CCU technologies.

Consultation response

TotalEnergies Corbion B.V., 2 May 2022

TotalEnergies Corbion welcomes the proposal of the European Commission on certifying carbon removals, that will contribute to Europe's goal of climate neutrality and represents an unique opportunity for Europe's bioeconomy sector. Since the launch of its first European Bioeconomy Strategy in 2012,…

Consultation response

Finnwatch ry, 29 Apr 2022

Finnwatch julkaisi kesäkuussa 2021 raportin päästökompensaatioiden markkinasta Suomessa. Raportti käsittelee kattavasti myös suomalaisia maankäyttösektorin hankkeita, joten sen havainnot ja suositukset ovat relevantteja hiilen poistamisen sertifiointia koskevan esityksen kannalta. Raportin…

Novamont urges EU to include bioeconomy in carbon certification

Novamont SpA, 23 Mar 2023

Novamont requests that sustainability objectives include the promotion of the bioeconomy and soil protection. They argue that compostable applications enable efficient organic waste collection and carbon storage.

This would allow Novamont to certify its bioplastic products as carbon-removing solutions.

France Nature Environnement warns carbon certification risks corporate greenwashing

France Nature Environnement, 16 Mar 2023

FNE calls for mandatory emission reduction strategies before certification to prevent companies from avoiding real climate action. They demand that removals provide positive biodiversity impacts and undergo rigorous NGO oversight.

These safeguards would protect environmental integrity and prevent companies from misusing labels for greenwashing.

Private companies would lose the ability to use offsets to mask a lack of emission cuts.

Novamont calls for high compost standards in carbon certification

Novamont SpA, 2 May 2022

Incentives should only support high-quality compost that meets EU Fertiliser Regulation standards. Specific land management practices like regenerative agriculture and mandatory grassland maintenance must be prioritized.

Stricter quality standards would create a larger European market for their bioproducts.

Waste treatment facilities producing low-quality compost would be excluded from carbon incentives.

Consultation response

Association Générale des Producteurs de Maïs, 23 Mar 2023

LAssociation Générale des Producteurs de Maïs (AGPM) estime que le projet de Cadre de certification des retraits de carbone (CFCR) devrait prendre en compte notamment les points suivants : permettre la poursuite du développement de la méthode grandes cultures Label Bas Carbone Les crédits doivent…

Consultation response

European Biochar Industry Consortium, 23 Mar 2023

In addition to emission avoidance and reduction, carbon removal remains the last chance to reach net zero within the timeframe envisaged by the EU. It is mandatory to compensate for hard-to-abate emissions and reduce the greenhouse gas concentration in the atmosphere to a level that preserves human…

Consultation response

Österreichischer Raiffeisenverband, 22 Mar 2023

Der Österreichische Raiffeisenverband begrüßt die Initiative der Kommission zur Schaffung einheitlicher Standards im Bereich der "Carbon Removals". Für die Erreichung der Klimaziele ist die Reduktion von Emissionen immer vorrangig und an erster Stelle, es benötigt aber auch Regeln für den Umgang…

Consultation response

Indigo Agriculture Europe GmbH, 21 Mar 2023

Indigo welcomes the European Commission`s legislative proposal for a regulatory framework for the certification of high integrity carbon removals. We believe that certified carbon removals can make a meaningful contribution to climate change mitigation and enable agriculture to be part of the…

Woodworking industry seeks EU certification for carbon-storing timber

European Confederation of Woodworking Industries, 2 May 2022

CEI-Bois requests a standardized EU framework that rewards carbon storage in bio-based products. They also suggest expanding eligible categories to include materials like wood-based insulation.

A robust certification scheme would significantly expand market opportunities for the timber industry.

Producers of carbon-intensive materials like cement may lose business to wood-based alternatives.

Consultation response

Confédération Européenne de la Production de Maïs, 23 Mar 2023

Veuillez trouver ci-joint la contribution de la Confédération Européenne de la Production de Maïs (CEPM)

Consultation response

Danish Dairy Board Brussels s.a., 22 Mar 2023

The Danish Dairy Board Brussels s.a. welcomes the consultation on certification of carbon EU rules. We refer to our consultation reply in the Commission public consultation Call for evidence for an impact assessment of 2022. We would additionally like to highlight the following point in response to…

Consultation response

Corbion, 2 May 2022

Corbion welcomes the recommendation in the Communication on Sustainable Carbon Cycles (Communication) that: "at least 20% of the carbon used in the chemical and plastic products should be from sustainable non-fossil sources by 2030". • Evidence put forward in the annex proofs that this percentage…

French waste association urges inclusive carbon removal certification framework

Fédération Nationale des Activités de Dépollution et de l'Environnement, 29 Apr 2022

FNADE recommends extending the certification scope to all operators providing carbon removal. They argue rewards must be shared equally across the value chain to trigger investments.

Inclusive certification provides waste companies with funding for innovative carbon removal techniques.

End-users lose exclusive financial benefits if rewards are shared more broadly among operators.

Consultation response

Danish Dairy Board Brussels s.a., 27 Apr 2022

see attached file

European lime industry seeks recognition for carbon-capturing products

European Lime Association, 23 Mar 2023

The European Lime Association argues that carbonation in lime products and soil liming should be formally recognized as permanent carbon removal solutions. They request clear rules for certifying these processes to support industrial sectors with unavoidable process emissions.

This would allow the industry to certify its products as carbon sinks and offset significant process-related emissions.

Consultation response

European Lime Association, 2 May 2022

SEE attached document

Italian farmers demand price floors for carbon removal credits

Cia - Agricoltori italiani, 2 May 2022

The organization calls for a fair minimum price for carbon credits and the creation of voluntary markets funded by national resources rather than agricultural subsidies. They advocate for short-term five-year contracts and the recognition of carbon farming practices already implemented by farmers. Furthermore, they propose creating absorption consortia to simplify reporting and include small landowners.

Farmers would secure additional income while avoiding bureaucratic costs and investment risks.

Large landowners and financial interests would lose their competitive advantage over smaller farmers.

Consultation response

International Emissions Trading Association, 23 Mar 2023

International Emissions Trading Association (IETA) welcomes an opportunity to provide feedback on Commission proposal for EU Carbon Removals Certification Framework (CRCF). The CRCF proposal is a first steps towards EU policy on carbon removals, albeit it is lacking details on the actual use of…

Consultation response

Soil Capital Belgium SRL, 24 Jan 2023

1. On Quantification : Reduction in greenhouse gas emissions resulting from the implementation of the carbon removal activity not in scope of net removals but can be counted as a co-benefit to increase the value of the certificate. There could be a technical accounting challenge in separating out…

Consultation response

LanzaTech EU B.V, 29 Apr 2022

LanzaTech welcomes the EU Commission's initiative on Carbon Removals. Carbon Capture and Utilization technologies are an essential pathway to reaching the EU climate goals. By capturing and transforming carbon oxides such as CO and CO2 scalable alternatives to fossil carbon become available to…

Consultation response

Assomela, 17 Mar 2023

Assomela, the Italian Association of Apple Producers, welcomes the possibility to comment on the proposal for a regulation on carbon removal certifications. The Italian apple sector works actively on monitoring the carbon footprint of the productions with the goal to apply agronomic techniques and…

Consultation response

Groupe Avril, 17 Mar 2023

Please find attached Avril Group written contribution to the public consultation on the Proposal for a Regulation establishing a Union certification framework for carbon removals.

Ragn-Sells urges EU to certify fossil carbon storage

Ragn-Sellsföretagen, 27 Feb 2023

Ragn-Sells requests that the EU allow certification of fossil carbon removals. They argue CCUS projects should be eligible for funding regardless of carbon origin. This should occur at least during a transitional phase to foster innovation.

Access to fossil carbon would provide the resources needed to develop their technology.

Environmental efforts are harmed when strict rules block innovations that reduce emissions.

Consultation response

European Agroforestry Federation, 2 May 2022

The European Agroforestry Federation (https://euraf.isa.utl.pt/) links organisations campaigning for agroforestry in 20 Member States (so far). Agroforestry is the integration of trees, crops and/or livestock on the same area of land. Trees can be inside parcels or on the boundaries (hedges). One…

Consultation response

Confédération des Associations Nationales de Tanneurs et Mégissiers de la Communauté Européenne, 16 Feb 2022

Every year, on a global level, tanneries recover and valorise some 8 million tons of raw hides and skins from the food sector. Without the leather industry and its upcycling activity, this residual material would simply become waste. In the EU, there are still about 1.600 tanneries recycling the…

Finnish bioenergy group urges EU to include biochar as permanent storage

Bioenergia ry - Bioenergy Association of Finland, 23 Mar 2023

The association requests that biochar be explicitly classified as a permanent storage method alongside industrial technologies. They also advocate for aligning sustainability criteria with existing bioenergy laws to avoid conflicting requirements. Furthermore, they argue that technical methodologies should not be used to settle political questions.

These changes would reduce administrative burdens and ensure bioenergy operators can access carbon markets.

Environmental groups may lose out as the industry pushes for less stringent sustainability standards.

Spanish cement industry seeks recognition for concrete carbonation

Agrupación de fabricantes de cemento de España, 23 Mar 2023

OFICEMEN requests that the EU recognize biogenic capture and concrete carbonation as removals. They also advocate for these certificates to be tradeable within the carbon market.

This would enable cement manufacturers to generate revenue by trading carbon removal certificates.

Timber and wood product sectors would be excluded from claiming valuable removal credits.

Consultation response

Brazilian Tree Industry, 6 Mar 2023

1. CONTEXT OF THE PROPOSAL Activities storing CO2 from an ETS installation in a storage site permitted under the CCS Directive are explicitly included in the EU ETS Directive and EU ETS allowances must be surrendered in the event of CO2 leakages. The proposed certification framework will ensure…

Bioenergy Association urges ambitious EU carbon removal targets

Bioenergia ry - Bioenergy Association of Finland, 2 May 2022

Bioenergia ry calls for a certification framework by 2026 with significantly higher targets. The system must remain technology neutral to support both biochar and industrial carbon capture.

This framework would generate revenue to support and upscale the bioenergy sector's technology.

Producers of short-term carbon products lose out as the association demands stricter permanence rules.

Consultation response

Aquaculture Advisory Council, 29 Apr 2022

The Aquaculture Advisory Council (AAC) has unanimously adopted the recommendation enclosed in response to this public consultation on "Carbon sequestration by molluscs". It has also been officially sent to the European Commission's Directorate-General for Fisheries and Maritime Affairs (MARE).

Consultation response

Carbon Engineering ULC, 23 Mar 2023

Please find attached Carbon Engineering's submission to the public consultation. Kind regards, Omar

Consultation response

Nederlandse Zuivel Organisatie, 23 Mar 2023

The Dutch Dairy Association (NZO), representing the Dutch Dairy Industry, supports the contribution of the European Dairy Association on the consultation of the proposal EU-rules for the certification of carbon removals. Additional to the key points in the EDA-document, the NZO would like to draw…

Consultation response

Danish 92 Group - Forum for Sustainable Development, 20 Mar 2023

Generelt mener vi, at dette forslag bør forkastes, hvis ikke forslaget styrkes gevaldigt, da: Forslaget har for mange mangler og en potentiel risiko for, at kulstoflagring og -optag kommer til at stå i stedet for reduktioner, hvilket er dybt bekymrende. Reduktioner i kulstofudledninger ikke kan…

Consultation response

Carbon Engineering ULC, 2 May 2022

Please find attached Carbon Engineering's submission to the call for evidence. Kind regards, Helen

Consultation response

Industrieverband Agrar e.V., 2 May 2022

Please find our statement in the file attached.

Consultation response

FederlegnoArredo - Federazione Italiana delle Industrie del Legno, del Sughero, del Mobile e dell'Arredamento, 29 Apr 2022

FederlegnoArredo (FLA), the Italian Federation of Woodworking, Cork, Furniture, Lighting and Furnishing industries warmly welcomes the possibility of engaging the call for evidence for an impact assessment on the certification of carbon removals, announced in the Commination on restoring…

Consultation response

TomatoEurope Processors Association, 23 Mar 2023

Please find attached TomatoEurope Processors Association's feedback to the Commission proposal establishing a Union certification framework for carbon removals.

Consultation response

Puro.earth, 23 Mar 2023

Puro.earth is a carbon removal crediting platform and through the Puro Standard, we create and verify robust science-based methodologies for removal of CO2 from the atmosphere. Puro issues CO2 Removal Certificates, CORCs, per ton of CO2 removed and durably stored. CORCs are issued and retired in…

Waste-to-energy suppliers urge clear carbon removal certification rules

European Suppliers of Waste-to-Energy Technology, 23 Mar 2023

ESWET requests clear rules for measuring biogenic and fossil carbon in waste-to-energy plants. They advocate for a feasible certification mechanism that avoids being overly burdensome for operators. They also want recognition for the full range of carbon capture and utilization technologies.

This would provide clarity for investors and help the sector reach net-zero targets.

Consultation response

Bundesverband Bioenergie e.V., 23 Mar 2023

Der Bundesverband Bioenergie e.V. (BBE) begrüßt die Initiative zur Schaffung eines Zertifizierungsrahmens für CO2-Entnahmen. Die Speicherung von biogenem Kohlenstoff in langlebigen Holzprodukten, Pflanzenkohle oder in Form von abgeschiedenem flüssigen oder gasförmigen CO2 ist ein unverzichtbarer…

Consultation response

SINTEF AS, 22 Mar 2023

This initiative will propose EU rules on certifying carbon removals. It will develop the necessary rules to monitor, report and verify the authenticity of these removals. The aim is to expand sustainable carbon removals and encourage the use of innovative solutions to capture, recycle and store CO2…

Consultation response

Luleå tekniska universitet, 19 Mar 2023

EUROPAFORUM NORTHERN SWEDEN The four northernmost counties in Sweden are working together to influence EU-policy through the political network Europaforum Northern Sweden (EFNS). The work in EFNS is based on common interest and commitment from regional and local politicians and officials. What…

Consultation response

Eesti Erametsaliit, 31 Jan 2023

When describing in European carbon certification framework the additionality principle, e.g. actions that are not business as usual (BAU), Estonian Forest Owners Association emphasizes the need to agree on "business as usual" on European level for land based carbon credits (growing carbon stock,…

Consultation response

TomatoEurope Processors Association, 2 May 2022

TomatoEurope Processors Association welcomes the opportunity to provide feedback on the initiatives for the creation of EU rules on certifying carbon removals. The Commission has recently published its Communication on sustainable carbon cycles, which includes proposals that could significantly…

Waste-to-energy tech suppliers urge EU carbon removal certification

European Suppliers of Waste-to-Energy Technology, 29 Apr 2022

ESWET calls for monitoring standards suitable to Waste-to-Energy and a recognized 50/50 biogenic emission split. They also request financial support and end-of-waste status for captured carbon.

A solid certification framework would establish the business case needed for carbon capture investments.

Environmental groups lose if carbon accounting relies on fixed estimates rather than precise monitoring.

Organic fertilizer industry urges support for carbon farming

European Consortium of the Organic-based Fertilizer Industry, 23 Mar 2023

ECOFI wants soil carbon sequestration through organic fertilizers recognized as a best practice. Farmers require financial support and advisory services to adopt carbon farming techniques effectively. They insist that food security must remain the top priority for European farming.

Recognition in the framework would likely increase market demand for organic-based fertilizer products.

Consultation response

European Carbon Farmers Sp. z o.o., 20 Mar 2023

The European Carbon Farmers is fully supportive of the EU Certification of Carbon Removals Framework yet highly concerned with the lack of leadership at the EU Commission level in creating a bridge between the Common Agricultural Policy of the EU and its climate ambitions. We believe - and present…

Consultation response

DuDeChem GmbH, 23 Mar 2023

We thank the Commission for its consideration of our suggestions and for the opportunity to provide feedback, which is found in the attached file.

Consultation response

Assemblée des Régions Européennes Viticoles, 23 Mar 2023

AREV soutient les engagements climatiques de l'Union européenne, à savoir : latteinte dune réduction de -55 % des émissions d'ici 2030, et un bilan climatique neutre dans le secteur de l'Utilisation des Terres de la Foresterie et de l'Agriculture pour 2035. Dans ce contexte, AREV salue la…

Consultation response

ICL Europe Coöperatief U.A., 23 Mar 2023

ICL Group welcomes the European Commission proposal for a Regulation establishing a Union certification framework for carbon removals (COM(2022) 672). The proposal represents a positive starting point for an EU harmonised voluntary and regulated market for carbon removals and especially carbon…

Consultation response

Institute for Agriculture and Trade Policy, 23 Mar 2023

The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to give feedback to the European Commissions proposal for a Carbon Removal Certification Framework. We would like to highlight twelve major concerns about the proposal and urge the European Commission to consider those…

Consultation response

European Parquet Federation, 23 Mar 2023

FEP the European Parquet Federation is warmly welcoming the European Commission proposal for a Regulation establishing a Union certification framework for carbon removals, and the possibility to comment it. We also welcome the recognition of the carbon stored in long-life wood products such as…

Consultation response

Suomen Biokierto ja Biokaasu ry, 22 Mar 2023

The Finnish Biocycle and Biogas Association promotes nutrient recycling and the use and development of biogas technology and its knowledge in the society. We welcome the ECs proposal for the EU Certification of Carbon Removals Framework. There is a clear need for the framework, and the lack of…

Polish chemical industry seeks clarity on carbon removal rules

Polska Izba Przemysłu Chemicznego, 22 Mar 2023

The organization requests precise definitions for durable products and long-term storage to ensure regulatory clarity. They also propose creating a formal list of products eligible for permanent carbon storage certification.

Clearer rules would allow chemical firms to certify and profit from carbon storage.

Consultation response

Stichting Rewilding Europe, 2 May 2022

As nature (not just carbon) related reporting standards become a market norm, it can be expected that mitigation will seek to cover biodiversity and nature related mitigation measures together with carbon and climate targets. This will be critical to demonstrating and achieving commitments to…

Consultation response

Institute for Agriculture and Trade Policy, 2 May 2022

Please find attached the Institute for Agriculture & Trade Policy's feedback as part of the call for evidence on the carbon removals certification framework.

Consultation response

Michael Succow Stiftung, 2 May 2022

Michael Succow Foundation, partner in Greifswald Mire Centre is welcoming the initiative of the European Commission to set up a Europe-wide Certification sheme of carbon removals. This should also include avaoided emissions eg. from rewetting and restoration of peatlands as the largest terrestial…

Consultation response

Alma Mater Studiorum - Università di Bologna, 29 Apr 2022

This a feedback from an interdisciplinary group of the University of Bologna (our view does not reflect the official view of our Alma Mater). We argue and conclude that comprehensive rules on the certification of each type of carbon removal are necessary and that validation of projects and the…

Consultation response

International Association for Sustainable Aviation e.V. (IASA), 8 Feb 2022

Die Zertifizierung von CO2-Reduzierungsmaßnahmen ist ganz sicher ein wichtiger Schritt, um den tatsächlichen CO2-Abbau auch verlässlich quantifizieren zu können. Ergänzend zu den geplanten ökologischen Aspekten sollte der Zertifizierungsrahmen auch Nachhaltigkeitsaspekte umfassen. Nur weil eine…

Consultation response

Carbo Culture Oy, 23 Mar 2023

Carbo Culture welcomes the European Commission's proposal for a European Carbon Removal Certification Framework. High-quality carbon removals play a crucial role to avoid overshooting climate targets and reaching net zero emissions. The climate crisis does not wait, and therefore it is important…

Consultation response

ASSOCIATION DE LA TRANSFORMATION LATIERE, 22 Mar 2023

ATLA supports the initiative aimed at establishing common EU standards for carbon removals. Such a business model could be beneficial to speed up carbon removals in agriculture. Carbon sinks such as dairy pasturelands are, amongst others, crucial in the transition towards a carbon neutral EU by…

Consultation response

Horisont Energi AS, 22 Mar 2023

Horisont Energi welcomes the European Commissions proposal for carbon removal certification. As confirmed by the IPCC, carbon emissions reduction alone will not be sufficient to limit global temperature increase to 1,5°C. Thus carbon removals will play an indispensable part to reach global climate…

Consultation response

EcoLog Ltd., 20 Mar 2023

ECOLOG welcomes the European Commissions new regulatory proposal establishing a Union certification framework for carbon removals. Pragmatic and fit-for-purpose regulation coupled with financial support for carbon removal technologies and practices, including Carbon Capture and Storage (CCS), is…

Consultation response

Value Maritime, 24 Feb 2023

In its attachment you can find Value Maritime's full response. The most important takeaways can be found in these three points: Support innovative technologies We would like to suggest you consider including carbon capture utilization technology in the relevant regulatory framework as soon as…

Consultation response

Svenska Bioenergiföreningen, 2 May 2022

Carbon removal technologies are necessary to reach ambitious EU climate targets with carbon neutrality by 2050. Most climate models that can reach the target in the Paris agreement to limit global warming to 1.5°C above pre-industrial levels include deployment of negative emissions technologies.…

Consultation response

LTO Glaskracht Nederland, 2 May 2022

Please see attached file for the feedback of the Dutch Organisation for Greenhouse Horticulture (Glastuinbouw Nederland) on certification of carbon removals (EU legislation).

Consultation response

Fachverband Pflanzenkohle e.V., 2 May 2022

Der 2017 gegründete Fachverband Pflanzenkohle e.V. (FVPK) hat einen besonderen Fokus auf Pflanzenkohle als Negativemissionstechnologie und setzt sich für die sichere Herstellung und umweltfreundliche Nutzung von Pflanzenkohle ein. Mit über 190 Mitgliedern aus Wissenschaft, Naturschutz,…

Consultation response

, 2 May 2022

The European Biochar Industry Consortium (EBI) welcomes the Commission’s initiative to elaborate a common European Carbon Removal Certification Mechanism. According to the IPCC, the world and the EU must implement large-scale permanent carbon removal to keep global warming within the targets set by…

Consultation response

Deutsche Säge- und Holzindustrie Bundesverband e.V. (DeSH), 2 May 2022

Einleitung Der Deutsche Säge- und Holzindustrie Bundesverband e.V. (DeSH) begrüßt die Initiative zur Zertifizierung von Maßnahmen zur Entfernung von CO2. Der Roh- und Werkstoff Holz bietet enorme Potenziale, einen Beitrag zum Klimaschutz zu leisten. Diese Potenziale gilt es voll auszuschöpfen und…

Consultation response

AGORO CARBON ALLIANCE AS, 2 May 2022

The Agoro Carbon Alliance supports the EU Commission's proposal to introduce a European Carbon Removal Certification. Implemented and leveraged appropriately, in combination with emissions reducing mechanisms, an outcome based and harmonised European certification for carbon removal, based on…

Consultation response

Ecosystem Value Association e.V., 2 May 2022

EVA welcomes this initiative and is aligned with its goals to use carbon markets to scale land use climate protection activities within Europe. EVA’s mission is the valorization of ecosystem services through standards and certification. EVA is developing the German Forest Carbon Standard, based on…

Consultation response

RCMP Solutions GmbH, 2 May 2022

We would like to introduce an additional carbon removal strategy: Reverse Carbon Mining (RCM) is an indirect carbon removal strategy where plant photosynthesis takes CO2 from the air. We pyrolyze responsibly sourced excess biogenic residues into a char. Measured quantities of the contained carbon…

Consultation response

Fertő tó Barátai Egyesület, 2 May 2022

See our contribution in the attached file

Consultation response

Parents For Future Italia, 1 May 2022

Parents for Future Italia (PFF Italia) accoglie con favore l'iniziativa dell'UE di stabilire un quadro giuridico appropriato per controllare le misure di rimozione della CO2. 1. Ambito di applicazione del regolamento PFF Italia presume che non si intendono solo misure per l'immobilizzazione…

Consultation response

European Bioeconomy Bureau, 29 Apr 2022

Please see the attached submission from ECBPI

Consultation response

Kungl. Skogs- och Lantbruksakademien, 28 Apr 2022

KSLA shares the Commission's view on the value of integrating carbon sequestration into EU climate policy. We are positive about using innovative solutions to separate, recycle, store carbon dioxide and increase the amount of carbon dioxide in plants in agriculture and forestry through methods for…

Consultation response

GAIAGO FINANCEMENT, 21 Apr 2022

We welcome this initiative which is fundamental for the future of European agriculture. Our company provides innovative solutions - based on the selective activation of microbiology - primarily on soil revitalization. These products help awaken and boost beneficial soil micro-organisms in order…

Consultation response

Parents For Future Germany, 6 Apr 2022

Als Anlage beigefügt finden Sie den Text der Stellungnahme.

Consultation response

Sindicato Central de Regantes del Acueducto Tajo Segura, 16 Mar 2022

Comment from the Central Union of Irrigators of the Tagus-Segura Water Transfer (SCRATS: scrats.es). From SCRATS, in Murcia, southeastern Spain, we welcome with great satisfaction the publication of this initiative which will propose EU standards on carbon removal certification. In Spain, we have…

Consultation response

Initiative Schwendermarkt, 26 Feb 2022

A model project for CO2 reduction - the greening with climbing plants of a concrete wall at the Schwendermarkt in Vienna on a busy road is not realized. Instead, the concrete wall is regularly painted with toxic paints and aerosols. A road construction joint-stock company is given a month-long…

Asociatia Principia urges forest conservation over Green Deal costs

Asociatia Principia, 16 Feb 2022

The organization calls for stopping deforestation and planting trees instead of costly regulations. They argue that the Green Deal imposes unrealistic financial burdens on young entrepreneurs.

Small businesses would avoid bankruptcy and the high costs of mandated technology.

Consumers are harmed by higher prices as entrepreneurs pass on regulatory costs.

Consultation response

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 9 Feb 2022

Dear European Commission, Dear Lady/Sir, On behalf of the Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16], we bought it with thanks your call for opinions on “Certification of carbon dioxide capture - EU rules”. After reading this document, the text of which…