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Restoring sustainable carbon cycles

Climate action

Carbon removals play a crucial role for achieving a climate-neutral EU economy in 2050 because they can balance the emissions that are very difficult to eliminate. The initiative will stress the importance of a robust methodology to certify carbon removals and will promote a new green business model to reward climate-friendly practices by farmers and foresters.

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Public consultation

ID: 13066

Lobbying Activity

64 responses

Consultation response

European Environmental Bureau, 7 Oct 2021

The EEB welcomes the Commission’s efforts to develop a robust legislative framework for carbon dioxide removals (CDR). The latest IPCC report recognises the need to deploy solutions for CDR, and this requires careful steering from policymakers to avoid negative externalities and harness…

Consultation response

Climate Action Network Europe, 7 Oct 2021

While Climate Action Network Europe supports the efforts to develop a sustainable and environmentally effective legislative framework for carbon removals in the EU, we stress that dangerous climate change can only be prevented by rapid and deep emission reductions. The Commission’s Roadmap on…

Consultation response

European farmers, 7 Oct 2021

Carbon farming is an important part of the effort towards achieving climate neutrality by 2035, and to generate negative emissions thereafter. In this regard, Copa and Cogeca welcome the publication of Commission’s Roadmap on the Carbon Farming Initiative. Nonetheless, we call on the Commission and…

Consultation response

Finnish Forest Industries Federation (Metsäteollisuus ry), 5 Oct 2021

Finnish forest industry sees that phasing out fossil emissions should remain as primary target ibn EU climate policy. Natural sinks or technological sinks should not be used as excuse for prolonging fossil economy. A voluntary carbon market, if poorly implemented, could lead to a situation where…

Consultation response

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 7 Oct 2021

The scope of the initiative should include the minimum criteria by which EU originated nature-based solutions/land sector supply can feed the demand of Corsia. We solely believe that supply of diversified and robust nature-based solutions will rise also in the EU, if the regulatory framework is…

Bayer urges EU carbon farming incentives and harmonized certification

Bayer AG, 6 Oct 2021

Bayer requests that the Commission stimulate Member State removal action, mobilize private sector involvement, and develop harmonized certification rules. They advocate for flexible trading of carbon removals across EU sectors and creating a carbon bank to purchase credits. The company emphasizes the need for cost-effective certification and capacity building for farmers.
This would create new revenue streams from carbon credits for Bayer's farming customers.
Environmental groups lose if flexible offsetting dilutes actual emission reduction efforts.

Shell Pushes for Carbon Removal Credits in EU ETS

Shell Companies, 7 Oct 2021

Shell wants the EU to create a certification framework for carbon removals by 2023, then introduce tradable carbon removal units into the EU ETS. They propose allowing companies to use nature-based carbon credits for compliance before 2050, transitioning to a system where removal credits balance residual emissions after 2050.
This would let Shell offset emissions using carbon credits instead of eliminating them.
Climate advocates lose stricter emission reduction requirements for fossil fuel companies.

Consultation response

Stichting BirdLife Europe, 7 Oct 2021

BirdLife Europe welcomes the EC’s efforts to develop a robust legislative framework for carbon dioxide removals (CDR). The latest IPCC report recognises the need to deploy solutions for CDR, and this requires careful steering from policymakers to avoid negative externalities and harness…

Consultation response

Eni S.p.A., 7 Oct 2021

Eni welcomes the opportunity to provide comments on the proposed Roadmap for Restoring Sustainable Carbon Cycles and appreciates the direction taken by the Commission to foster a sustainable carbon cycle. Please find attached our feedback.

Consultation response

Finnish Energy - Energiateollisuus ry, 7 Oct 2021

Finnish Energy welcomes Commission’s initiative and Road Map for developing a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to kick-start the development of technological and nature-based solutions. We consider this…

Consultation response

Unilever, 7 Oct 2021

Unilever fully supports and agrees with the aim of the roadmap on “Restoring sustainable carbon cycles”: achieving climate neutrality objectives cannot only rely on decarbonising our energy and transport sectors, but also requires solutions for capturing carbon dioxide from the atmosphere and…

Consultation response

Confederation of European Paper Industries, 7 Oct 2021

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes…

Consultation response

International Federation of Organic Agriculture Movements EU Regional Group, 7 Oct 2021

IFOAM Organics Europe welcomes the initiative to develop a vision for sustainable carbon cycles and kick-start nature-based solutions, such as carbon farming. Carbon sequestration in the land use sector has a crucial role to play to meet the long-term climate objectives. Common organic farming…

Consultation response

International Association of Oil Gas Producers Europe, 7 Oct 2021

IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and…

Equinor urges EU to embrace technology-based carbon removal solutions

Equinor ASA, 7 Oct 2021

Equinor requests the Commission maintain technology neutrality and include both nature-based and technology-based solutions in the certification framework. They emphasize that achieving net-zero by 2050 requires carbon reductions and removals at unprecedented scale, with support for carbon capture and storage technologies.
This would validate their existing carbon capture investments and create markets for their technology-based removal solutions.
Nature-based solution providers lose if technology-based approaches receive equal or preferential treatment in the certification scheme.

Consultation response

EUROGAS, 7 Oct 2021

Eurogas response to “Restoring Sustainable Carbon Cycles” Roadmap Eurogas welcomes the opportunity to provide comments on the proposed Roadmap for Restoring Sustainable Carbon Cycles. To achieve net zero emissions by 2050, the EU should develop a policy framework that promotes and incentivizes…

Consultation response

CEMBUREAU - The European Cement Association, 7 Oct 2021

The European Cement Association, CEMBUREAU, hereby submits its comments on the European Commission’s “Roadmap on restoring sustainable carbon cycles” and is looking forward to a continued interaction on the topics set out below with all relevant stakeholders in the debate. The reflections in this…

Swedish Forest Industries urges active forest management over carbon storage

Swedish Forest Industries Federation, 7 Oct 2021

The organization requests incentives for active forest management that increases growth rather than passive approaches. They emphasize the importance of substitution benefits when wood products replace fossil alternatives. They also call for prioritizing BECCS technology and maintaining the hierarchy that emission reductions come before carbon removals.
This would maintain wood availability for their products and avoid competitive disadvantages against fossil-based industries.
Climate goals lose if passive forestry reduces wood availability and allows other sectors to continue fossil emissions.

Consultation response

EuropaBio, 4 Oct 2021

EuropaBio appreciates the opportunity to comment on the roadmap on restoring sustainable carbon cycles. Europe’s goal to become the first climate-neutral continent will rely on reducing overall EU greenhouse gas emissions and further transition from fossil carbon to renewable carbon. We appreciate…

Consultation response

SUEZ Group, 7 Oct 2021

SUEZ welcomes the initiative to develop a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to support in the development of technological and nature-based solutions. We look forward to an upcoming proposal for a…

Biogas industry urges EU to prioritise biogenic CO2 over fossil sources

European Biogas Association, 7 Oct 2021

The association requests preferential treatment for biogenic CO2 from biogas across EU legislation. They want urgent reforms to industrial emissions trading rules to credit CO2 avoidance, mandatory disclosure of CO2 origins in products, and financial support for innovation in biogenic CO2 technologies.
This would create new revenue streams from CO2 capture and extend their circular economy business model.

Consultation response

European Coordination Via Campesina, 7 Oct 2021

The EU needs a comprehensive strategy to preserve and develop sustainable agriculture. This strategy must produce enough healthy food to feed all Europeans; drastically reduce greenhouse gas emissions from agriculture and food systems; preserve, restore and enhance biodiversity in the countryside…

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 6 Oct 2021

The DAFC finds that carbon farming must be recognized as an important tool to reduce agricultural GHG emissions through land use and farm practices that can sequester carbon in natural sinks. Carbon farming is an important part of the effort towards reaching the climate target for 2030 and the net…

Yara urges EU carbon farming scheme to reward mineral fertilizers

YARA BELGIUM S.A., 7 Oct 2021

The company requests that carbon farming acknowledge mineral fertilizers' role in improving yields and soil health. They want farmers rewarded for low-emitting activities and certification standards that enable large-scale implementation without onerous verification requirements.
This would position their fertilizer products as eligible for carbon credits and subsidies.
Environmental groups lose if fertilizer use is incentivized over organic alternatives.

Carbon Market Watch urges caution on EU carbon removal framework

Carbon Market Watch, 7 Oct 2021

The organization requests keeping emission reductions separate from carbon removals with distinct targets and instruments. They oppose including carbon capture and utilization in the EU ETS and warn against offsetting industrial emissions with farm-based carbon storage. They urge defining what constitutes real and permanent carbon removal.
This would prevent large industries from transferring compliance burden to farmers through offsetting schemes.
Industrial emitters lose ability to use cheaper carbon farming credits instead of reducing emissions.

Consultation response

Veolia Environnement, 7 Oct 2021

Veolia welcomes the opportunity to provide inputs to Europe's long-term perspective and the integration of carbon removals into the EU climate policies towards 2050. We recognize the crucial role of carbon removals (CDR) to achieve net-zero emissions by 2050. CDR technologies can offset residual,…

Consultation response

Stora Enso Oyj, 7 Oct 2021

Stora Enso is a renewable materials company that employs over 18 000 people in the EU. We deliver products that store carbon and provide low-carbon alternatives to non-renewable products. We are one of the biggest private forest owners in the world and source much of our wood from other,…

Bioenergy Europe urges EU support for carbon capture technology

Bioenergy Europe, 7 Oct 2021

The organization requests financial and regulatory incentives for carbon removal technologies, particularly bioenergy with carbon capture and storage. They want clear definitions of key terms like permanence of storage and inclusion of biochar as a carbon pool.
This would support their core business of bioenergy production while positioning BECCS as essential climate technology.
Advocates of nature-based solutions may lose priority as funding shifts toward technological carbon removal.

Consultation response

Conféderation Européenne des Propriétaires Forestiers, 7 Oct 2021

The Confederation of European Forest Owners welcomes the opportunity to express first general views on the European Commission’s initiative to develop a long-term vision for sustainable carbon cycles (including capture, storage, and use of CO2) in a climate-neutral EU economy and to kick-start the…

Consultation response

PepsiCo, 7 Oct 2021

cycles by developing and deploying natural and technological carbon removal solutions at a scale to meet the EU’s objective of climate neutrality. As one of the world’s leading food and beverage companies with a strong footprint in the EU, PepsiCo strongly supports the European Commission’s Green…

European Dairy Association urges carbon credits stay in-sector

European Dairy Association aisbl, 7 Oct 2021

The group requests cost-efficient tools that do not challenge the profitability of farming. They suggest keeping carbon credits inside the value chain of origin to drive innovation.
Keeping credits within the sector helps dairy companies offset their own emissions.

Consultation response

Bellona Europa, 7 Oct 2021

Bellona welcomes the Commission’s efforts to kick-start the development of technological and nature-based removals. However, clarity must be ensured with regards to what is – and what is not – a carbon removal to prevent wilful and accidental conflation with emission reductions. There is…

Consultation response

Landwirtschaftskammer Österreich, 7 Oct 2021

We refer to our statement attached in the Annex.

Consultation response

Arla Foods amba, 7 Oct 2021

Arla Foods welcomes the opportunity to give input to the Commission roadmap and supports the Commission’s overarching initiative to develop the sustainability agenda. As one of the largest dairy companies in the EU and cooperatively owned by more than 9000 dairy farmers in seven European…

Consultation response

VIER PFOTEN International, 7 Oct 2021

FOUR PAWS welcomes the opportunity to provide feedback to the Commission Roadmap on Restoring sustainable carbon cycles. Please find our more detailed feedback in the attachment.

Consultation response

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 7 Oct 2021

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on restoring sustainable carbon cycles. Carbon removals from forests, agricultural practices or engineered solutions will play an important role in achieving climate…

Consultation response

Negative Emissions Platform, 7 Oct 2021

We welcome the opportunity to respond to the roadmap on Restoring Sustainable Carbon Cycles and the inclusion of planning for development of technological removals therein. General comments: The Roadmap focuses in the first place on nature-based removals from land-use sector and indicates the…

Consultation response

International Confederation of European Beet Growers, 7 Oct 2021

CIBE welcomes the initiative by the Commission aiming to support the development of sustainable carbon removal solutions and to propose an action plan to promote carbon farming and develop a regulatory framework for the certification of carbon removals. Carbon farming has several advantages:…

Consultation response

European State Forest Association, 7 Oct 2021

In the first place, EUSTAFOR wishes to underline that unfortunately the carbon farming concept currently being increasingly promoted by the European Commission seems to be still very ambiguous and insufficiently addresses specificities of forests and their management. Our particular attention goes…

Consultation response

IFIEC Europe, 7 Oct 2021

The climate law requires Europe to reach net zero emissions by 2050, and to aim to achieve negative emissions thereafter. In order to reach these ambitious targets technologies to reduce GHG emissions as well as technologies to remove and utilise CO2 will be required. Industry is currently looking…

Consultation response

European Bioplastics, 7 Oct 2021

European Bioplastics (EUBP) represents the entire value-chain of bio-based, recyclable and biodegradable/compostable materials and products, which provide a key value proposition in waste reduction, recycling and recovery. Over the past 25 years, innovation by this sector has delivered many new…

Consultation response

European Panel Federation, 7 Oct 2021

The European Panel Federation (EPF) warmly welcomes the possibility to provide feedback on the Roadmap on Climate change – restoring sustainable carbon cycles. Reaching net-zero greenhouse gases emissions by 2050 and negative emissions thereafter requires both important carbon emissions reductions…

Consultation response

Sonae SGPS, S.A., 6 Oct 2021

Sonae is a multinational corporation that manages a large portfolio of retail, financial services, technology, wood-based panels, shopping centres and telecommunications businesses, creating value across various geographical areas. In relation to the Green Deal, Sonae welcomes the European…

Carbon capture industry urges inclusion in EU carbon cycle plans

CO2 Value Europe AISBL, 6 Oct 2021

CO2 Value Europe requests that Carbon Capture and Utilisation be appropriately considered in the Commission's sustainable carbon cycles vision. They argue CCU can reduce emissions, create circular systems, enable industrial symbiosis, lead to carbon removals, and provide alternative feedstock to fossil carbon.
This would create competitive industrial markets for their carbon capture technologies and products.

PFPI urges EU to double forest carbon sink targets

Partnership for Policy Integrity, 7 Oct 2021

PFPI demands the EU double its land sector carbon sink target and stop relying on unproven bioenergy technologies. They insist that policy follow the precautionary principle by prioritizing ecosystem restoration over industrial logging.
This would move EU policy toward science-based conservation, protecting the natural forests PFPI defends.
The forestry and biomass industries would lose billions in subsidies and their political influence.

Consultation response

EIT Food ivzw, 7 Oct 2021

EIT Food believes that systems innovation, education, public engagement, and investment will be key enablers for the development and adoption of new green business models and new climate-smart solutions rewarding climate-positive practices, creating new sources of income for farmers by means of…

Consultation response

France Nature Environnement, 7 Oct 2021

France Nature Environnement is the French federation of associations for the protection of nature and the environment. It is the spokesperson for a movement of 6,000 associations, grouped within 53 member organisations, present throughout France, in metropolitan and overseas territories. A more…

Consultation response

Association Générale des Producteurs de Maïs, 7 Oct 2021

AGPM shares the ambition to enhance sustainable carbon cycles to meet the EU's decarbonization goal by using nature based solutions and technological mechanisms. In this context, the agriculture carbon pump is a powerful tool to naturally capture CO2 from the atmosphere, in particular by field…

Consultation response

European Confederation of Woodworking Industries, 7 Oct 2021

The European Confederation of the Woodworking Industries and the European Organisation of the Sawmill Industry believe that in order to meet the Paris Agreement target to keep global warming “well below 2°C”, phasing out fossil emissions should remain a priority in Europe. To achieve net zero by…

Consultation response

Indigo Agriculture Europe GmbH, 27 Sept 2021

Carbon farming can play an important role in reducing emissions from the land use sector and removing carbon dioxide from the atmosphere. This can make a substantive contribution to the achievement of the 2030 emission reduction goal and climate neutrality by the middle part of the century. …

Consultation response

Stockholm Exergi, 4 Oct 2021

Stockholm Exergi (SE) 2021-10-04 It takes a generation to build a new industry – we must start now Stockholm Exergi welcomes the Commission’s ambition to accelerate the development of technological and nature-based carbon storage and usage solutions. It wishes to emphasize that it is critical to…

Consultation response

Grand Est-Europe, 7 Oct 2021

Le collectif Grand Est-Europe, composé de collectivités territoriales, universités et chambres consulaires de la région française du Grand Est accueille avec un vif intérêt l’initiative de la Commission européenne en vue de développer des forêts et des pratiques agricoles favorisant l’absorption du…

Consultation response

Arbeitsgemeinschaft Deutscher Waldbesitzerverbände e. V., 7 Oct 2021

AGDW die Waldeigentümer, begrüßt die Gelegenheit, erste Anmerkungen zur Initiative der Europäischen Kommission zu äußern, eine langfristige Vision für nachhaltige Kohlenstoffkreisläufe (einschließlich der Abscheidung, Speicherung und Nutzung von CO2) in einer klimaneutralen EU-Wirtschaft zu…

Finnish Bioenergy Association seeks incentives for carbon removal technologies

Bioenergia ry - Bioenergy Association of Finland, 7 Oct 2021

The association requests financial and regulatory incentives for technologies like BECCS and biochar. They call for a long-term vision to provide investment predictability and clear targets.
The proposed framework would make bioenergy carbon capture technologies commercially viable and attract investors.
Fossil fuel operators lose their unique regulatory advantage as bioenergy gains similar storage incentives.

Industrial Minerals Association urges recognition of soil acidity management in carbon farming

Industrial Minerals Association - Europe, 7 Oct 2021

The association requests that soil acidification be officially listed as a soil threat and that correcting soil acidity through liming be included in carbon farming policies. They argue liming improves soil health, increases carbon sequestration, and reduces greenhouse gas emissions.
Recognition would expand the market for their liming products used to correct soil acidity.

Consultation response

Industrieverband Agrar e.V., 7 Oct 2021

See attached file

Consultation response

NatureWorks LLC, 7 Oct 2021

About NatureWorks: NatureWorks is an advanced materials company offering a broad portfolio of biobased polymers and chemicals to the packaging, polymers, fibers, and chemicals markets. We call on the Commission to promote policies which enable the recovery and recycling of bio-waste into…

Consultation response

European Suppliers of Waste-to-Energy Technology, 7 Oct 2021

ESWET welcomes the Commission's roadmap and would like to stress that affordable CCUS implementation could provide the opportunity for the Waste-to-Energy sector to become carbon-negative. Waste-to-Energy (WtE) is a waste management option that is complementary to recycling to the extent that it…

Consultation response

Consorzio per la Ricerca e la Dimostrazione sulle Energie Rinnovabili, 6 Oct 2021

Ligno-cellulosic biomass from various sources (e.g. afforestation, reforestation, agroforestry, agricultural residues) can be converted through thermo-chemical conversion processes in a stable C material called biochar. In particular, pyrolisis provides the highest rate of conversion of biomass…

Consultation response

Michael Succow Stiftung, 5 Oct 2021

Sustainable carbon cycles should integrate nature-based solutions as key cost-effective measures with many co-benefits for circular bio-economy, biodiversity, soil and water. This should include enhanced sequestration and safeguarded storage. Peatland are the biggest terrestrial carbon stores…

Consultation response

European Parquet Federation, 4 Oct 2021

FEP – the European Federation of the Parquet industry – is welcoming the Roadmap “Restoring sustainable carbon cycles” and the possibility to comment it. Carbon removals are indeed an important factor to help the EU meeting its Green Deal main objective of carbon neutrality by 2050. Nevertheless,…

Consultation response

Kungl. Skogs- och Lantbruksakademien, 7 Oct 2021

Agriculture Soil carbon stocks in arable mineral soils in Sweden have increased with the equivalent of 2,4 Mton CO2 per year over the last 30 years. Modern Swedish agriculture has turned from a carbon source, through drainage and cultivation of wetlands and intense soil cultivation, to a sink, by…

Consultation response

AGORO CARBON ALLIANCE AS, 6 Oct 2021

Public funding such as the CAP is a critical source of financing to drive the implementation of conservation agriculture practices – the basis for agricultural carbon sequestration and emission removal, and improved nitrogen use efficiency. Experience from current CAP grower financing schemes have…

Consultation response

European Bioeconomy Bureau, 29 Sept 2021

The European Circular Bioeconomy Policy Initiative (ECBPI) appreciates the opportunity to comment on the roadmap on restoring sustainable carbon cycles. We value the roadmap focus on sustainable carbon cycles. This should then provide impetus to formulate both nature-driven and technological…