Carbo Culture Oy
Carbo Culture Oy is a Finnish carbon removal company on a mission to remove one billion tons of carbon from the atmosphere through a technological solution called PyCCS or biochar.
ID: 362580446687-90
Lobbying Activity
22 Sept 2025
Please find Carbo Culture Oy's feedback to the public consultation attached. Kind regards, Hanna Ojanen
Read full response7 Jul 2025
Carbo Culture is a European climate technology company developing high-integrity carbon removal infrastructure based on Biochar Carbon Removal (BCR). Our proprietary pyrolysis technology converts waste biomass into stable biochar, permanently removing carbon from the atmosphere for centuries while enabling circular bioeconomy benefits. We operate with a science-based, verifiable approach aligned with EU climate goals and the Carbon Removals and Carbon Farming Certification Regulation. Carbo Culture is proud to be supported by the European Innovation Council (EIC), reflecting the strategic importance and innovation potential of our work in delivering scalable, durable carbon removal solutions across Europe. Carbo Culture welcomes the opportunity to contribute to the EU ETS public consultation. We strongly support the inclusion of certified carbon removals in the EU ETS. In addition, we emphasise the need for policy consistency and technology openness by ensuring that Biochar Carbon Removal (BCR), alongside other permanent carbon removal methods certified under the Carbon Removal and Carbon Farming Certification Regulation (CRCF), are eligible. We strongly recommend that the ETS aligns with the CRCF to ensure policy coherence The ETS must align with the CRCF, the EUs principal framework for certifying high-integrity carbon removal, and integrate only those carbon removal technologies that meet the CRCFs permanence and quality criteria, such as storage of CO for at least 200 years, and adherence to the QU.A.L.ITY principles. The European Commissions Carbon Removal and Carbon Farming Certification Regulation (CRCF) was designed to set rigorous, harmonised standards for what qualifies as permanent carbon dioxide removal (CDR). The final CRCF agreement supports a technology-open approach that defines permanent CDR as any removal pathway that: - Stores carbon for a minimum of 200 years, and - Meets the QU.A.L.ITY criteria: Quantification, Additionality, Long-term storage, Sustainability, and MRV and is consistent with the CCS Directive. It is essential that the EU ETS remains consistent with this framework, and does not pre-emptively limit eligibility to a narrow subset of technologies. Biochar Carbon Removal (BCR) qualifies under the CRCF's permanence definition, with robust methodologies and MRV in place. Restricting ETS eligibility to only certain technologies would undermine the CRCF's intent and delay the scale-up of viable, high-integrity removals in the European Union. Policy Recommendations To support a credible, scalable, and innovation-friendly CDR integration into the EU ETS, we recommend: - Full alignment between the ETS and the CRCF, particularly regarding permanence definitions and eligibility of removal methods. - Inclusion of all certified permanent carbon removal methods under the CRCF, including biochar, without arbitrary exclusion. - A technology-open approach that rewards climate performance and environmental integrity, not specific technologies. The inclusion of carbon removal in the EU ETS is a critical milestone. To be effective and trusted, this integration must align with the EUs own existing certification under the CRCF. We urge the Commission to uphold the principles of consistency, fairness, and performance-based policy design in the next phase for the EU ETS. Sincerely, Hanna Ojanen Head of Carbon Markets and Policy
Read full responseResponse to Carbon Removal Certification
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 that in addition to ensuring high standards for carbon removal, we must also ensure that carbon removal can be deployed and delivered at the speed and scale required by the scientific community. Biochar Carbon Removal (BCR) represents a durable solution, with a high TRL (TRL8+), that is ready to scale today. We have identified three key recommendations through which the CRCF can reach its full potential and Europes climate targets. We strongly recommend: 1) Expanding permanent storage past geological formations to biochar storage in soil and construction applications 2) Acknowledging the potential of Biochar Carbon Removal (BCR) to reach climate targets. 3) Removing barriers to finance first-of-a-kind carbon removal projects. The current category of "permanent storage" under the CRCF is limited to geological storage and carbon dioxide as defined by the CCS Directive of 2009. The restriction of "permanent storage to geological formations does not welcome other industrial carbon removal methods that deal with solid carbon, such as biochar carbon removal (BCR), which can sequester carbon from several centuries to millennia. To address this shortcoming, a potential solution would be to redefine permanence based on sequestration duration, rather than the storage location across all categories. By doing so, any method that can effectively sequester carbon for a duration of "several centuries", as defined by the CRCF, should qualify as a permanent removal. Carbo Culture wants to highlight that regulatory frameworks and incentives should be developed to support and enable the development and deployment of carbon removal that is not limited to geological storage. While promoting all carbon removal technologies is critical to meeting the goals of the Paris Agreement, some promising solutions are being overlooked in the current draft. In 2022, Biochar Carbon Removal (BCR) accounted for a total of 40% of all high-quality carbon removal purchases, 87% of all deliveries, and 90% of the biggest suppliers of durable high-quality carbon removal (cdr.fyi). Biochar Carbon Removal (BCR) represents a mature (TRL 8+), scalable and durable technology available in the short and medium-term that is substantially contributing to achieving the objective of removing at least -5 Mt CO2eq/year by 2030. Carbo Culture is a leading Biochar Carbon Removal (BCR) company and has developed a novel solution, Carbolysis, and is building one of the largest carbon removal facilities in Europe. The biochar is permanently stored in soil and construction applications. Including Biochar Carbon Removal (BCR) as a permanent carbon storage solution would promote its development and implementation in short and medium term, while scaling up carbon removal in Europe. Continued research on areas for funding mechanisms, in order to build a pipeline of project developers, is critical to build the carbon removal industry. These may include, for example, credit actions to support carbon removal in early-stage research and development or during the verification process. A variety of demand-side methods can help to scale the removals market, including but not limited to advanced market commitments, direct procurement, guaranteed offtakes, reverse auctions, guaranteed price floors, and subsidies for biochar applications to speed up market adoption. We urge the Commission to consider the recommendations presented above. We extend our gratitude to the European Commission for your leadership and for inviting us to provide our response. Please find our full response and proposed amendments in the attachment and do not hesitate to contact us for further discussion.
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