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Verification of carbon removals, carbon farming and carbon storage in products

Climate action

The implementing regulation lays down rules to promote harmonised third-party verification under the CRCF Regulation (EU) 2024/3012, including rules on certification schemes recognised by the Commission, certification bodies, certification audits, and certification registries.

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Public consultation

ID: 14476

Lobbying Activity

23 responses

Consultation response

Fern, 1 Jul 2025

Dear Madam, dear Sir, thank you for this opportunity to contribute to the elaboration of this very important file: as per the CRCF architecture, inspired from the Renewable Energy Directive, certification schemes for carbon removals will have to ensure the compliance with CRCF methodologies of the…

Oil and Gas Industry Seeks EU Recognition of International Carbon Schemes

International Association of Oil Gas Producers Europe, 1 Jul 2025

The organization requests that the EU recognize international carbon certification schemes like Puro.earth and Verra as equivalent to EU-approved schemes. They argue the current draft forces unnecessary recertification under separate EU schemes, creating administrative duplication without environmental benefit.
This would allow them to avoid recertifying under duplicate EU schemes while using existing international frameworks.
EU regulators lose direct oversight over carbon removal verification standards and methodologies.

Carbon Market Watch Warns Industry Could Dominate EU Carbon Farming Certification

Carbon Market Watch, 1 Jul 2025

The organization requests mandatory on-site visits, random allocation of certifiers, and independent complaints processes. They argue that allowing operators to choose certifiers creates perverse incentives and risks cherry-picking.
This would strengthen oversight of carbon removal claims and prevent industry capture.
Industry operators lose flexibility in choosing certifiers and face higher compliance costs.

Galp Energia Urges Simplified EU Carbon Removal Certification Framework

GALP ENERGIA SGPS, SA, 1 Jul 2025

Galp requests a simplified recognition mechanism for existing credible schemes to avoid duplication. They seek clarification on the commercial use of certificates issued before 2028. Requirements must be proportionate to the scale of nature-based solutions projects.
Harmonised rules would reduce compliance costs and facilitate the trade of carbon certificates.

CCSA urges technical expertise in carbon removal verification

Carbon Capture & Storage Association, 30 Jun 2025

The group supports standard forms to make the certification process clear and consistent. They want governance to focus on expertise and flexibility to switch certification providers.
Standard templates and flexible provider options would reduce regulatory risks and costs for operators.
Agricultural groups face risks because collective certification can be withdrawn if some members fail audits.

Negative Emissions Platform urges flexibility in carbon removal rules

Negative Emissions Platform, 27 Jun 2025

They recommend revising rules to provide greater flexibility for certification scheme governance structures. The platform calls for clearer criteria regarding valid reasons for switching between schemes. They suggest reconsidering mandatory accreditation requirements to avoid potential bottlenecks and maintain scalability.
Reducing administrative requirements would lower compliance costs and speed up project market entry.
Small verification firms lose market access if strict accreditation requirements create high entry barriers.

ZEP Urges Stricter Oversight for EU Carbon Removal Verification

Zero Emissions Platform, 1 Jul 2025

The platform recommends limiting any single stakeholder group to 40% of voting rights. They advocate for a central EU registry of disqualified operators to prevent 'scheme hopping'. The group also calls for 'high-assurance' audits to ensure environmental integrity.
Increased system integrity would protect the credibility and market value of carbon removal projects.
Non-compliant operators would lose the ability to evade sanctions by switching between certification schemes.

TIC Council demands clear auditor independence in carbon rules

TIC Council, 27 Jun 2025

Certification Bodies should stay fully responsible for audits and issuing certificates. Schemes should monitor systems without interfering in individual certification decisions. Initial certifications must always include at least one mandatory on-site audit.
This protects the professional liability and independent authority of certification companies.
Project developers will face higher costs due to mandatory on-site inspections.

TÜV Association seeks better standards for carbon removal verification

TÜV-Verband e. V., 1 Jul 2025

TÜV stresses the need for close alignment with existing international and European standards. They propose changing auditor experience requirements to focus on carbon removals rather than fuels.
This would reduce administrative burdens and simplify hiring criteria for specialized auditors.
Scheme owners lose access to surveillance reports, potentially reducing transparency of certifications.

Consultation response

voestalpine AG, 1 Jul 2025

The following general remark would be worth considering and discussing from our perspective, namely whether the relevant regulations of the EU ETS could be applied here. In principle, for the sake of administrative simplification and legal certainty, specifically also for the simplification of the…

Consultation response

Valio Oy, 29 Jun 2025

The implementing rules of verification are a core part of a certification system that ensures efficient and functioning processes. It is especially important that the roles, responsibilities and tasks of stakeholders are clear, non-overlapping and accountable. Keeping this target in mind, we would…

Consultation response

International Emissions Trading Association, 1 Jul 2025

On behalf of over 320 global companies operating in the carbon market ecosystem, IETA welcomes the opportunity to respond to the European Commissions public consultation on the draft implementing regulation for the verification of carbon removals, carbon farming and carbon storage in products under…

Consultation response

Soil Capital Belgium SRL, 1 Jul 2025

Article 9, Point 2 There is ambiguity in the requirement for Certification Schemes to list on their registries those operators with. Would such listings be publicly accessible to anyone or rather just visible to other Schemes and Registries? If the former, this does not contribute to effective…

Consultation response

European Agroforestry Federation, 1 Jul 2025

EURAF represents members and Affiliated Entities on 23 EU Countires who are working to increase the use of agroforestry on agricultural and forest land. We attach detailed comments on the draft CRCF Implementing Regulation. However in view of some of the critical comments made by some commentators…

Consultation response

Assomela, 27 Jun 2025

The Italian Association of Apple Producers, Assomela, supports the initiative to establish rules on certification schemes, certification bodies and audits for carbon farming activities. The proposed regulations play a crucial role in ensuring the credibility and accuracy of carbon neutrality…

Consultation response

Arbeitsgemeinschaft Deutscher Waldbesitzerverbände e. V., 1 Jul 2025

Die AGDW Die Waldeigentümer begrüßt das Ziel der EU, mit dem CRCF einen transparenten und qualitätsgesicherten Rahmen zur Zertifizierung von CO-Entnahmen zu schaffen. Wälder sind essenzielle Kohlenstoffsenken und leisten einen bedeutenden Beitrag zum Klimaschutz. Ihre Leistungen anzuerkennen und zu…

Consultation response

South Pole Holding Ltd, 30 Jun 2025

Please see attachment.

Consultation response

Puro.earth, 30 Jun 2025

Please find feedback in attached Pdf.

Consultation response

BeZero Carbon Ltd, 30 Jun 2025

We have two pieces of feedback: (1) Implement clear public disclosure requirements for project technical information; (2) Consider introducing a requirement for all CRCF projects to be assessed by an independent carbon credit ratings agency. More detail on these recommendations is provided below.…

Consultation response

St1 Nordic Oy, 1 Jul 2025

The implementing rules of verification are a core part of a certification system that ensures efficient and functioning processes. It is especially important that the roles, responsibilities and tasks of stakeholders are clear, non-overlapping and accountable. Keeping this target in mind, we would…

Consultation response

Climate Cleanup Foundation, 30 Jun 2025

To maximise this framework's potential, Climate Cleanup proposes four critical enhancements. 1. Extending Group Auditing to Bio-Based Products Current Gap: Article 12 restricts group auditing to carbon farming only, missing the construction sector's massive potential. Bio-based building materials…

Consultation response

EUROMALT, 1 Jul 2025

EUROMALT is the trade association of the malting industry in Europe, representing and promoting the interests of the European malting industry at EU and international levels. The European malting industry accounts for approximately 1/3 of the total worlds capacity in malt production (up to 11…

Consultation response

Preferred by Nature, 30 Jun 2025

Introduction (7): As per ISO 14065, the level of assurance is only required for verifications (re-certification), but not for validation (certification of compliance). (9): We do not understand the requirement for certification bodies to be accredited under relevant European standards if it is…