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Carbon Gap ASBL

Carbon Gap

Carbon Gap is a climate non-profit focused on making Europe a leader in carbon removal by advocating for policies that support storing carbon in trees, soils, oceans, rocks, and buildings.

Lobbying Activity

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur for opinion) and Institute for European Environmental Policy and

27 Jan 2026 · Performance Regulation

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · European Competitiveness Fund

Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

7 Nov 2025

Alongside deep emissions reductions, carbon dioxide removal (CDR) is essential for achieving net zero and beyond. According to the IPCC, the EU will need 400800 MtCO of removals annually by 2050. Yet, three recently published reports by DG CLIMA identify significant funding gaps for CDR. Carbon Gaps latest report (referenced in the Commissions work), shows that only 0.1% of EU climate funding has gone to CDR so far. The proposed Multiannual Financial Framework (MFF), together with the European Competitiveness Fund (ECF) and Framework Programme (FP10), will determine whether Europe can build the innovation and deployment capacity needed to meet these targets. Carbon Gap has analysed these proposals from a CDR perspective and identified several key challenges: Without a ringfenced CDR budget, rising inflation, shifting political priorities, and competition from other technologies will erode available funding in practice. The loss of the standalone LIFE programme and a dedicated biodiversity budget removes a vital funding pillar for nature-based CDR. Stronger alignment between FP10 and the ECF could ensure continuity of support across the full project life cycle. The absence of explicit CDR references in the text is politically risky: without recognition, CDR will struggle to compete with more established technologies and risks being sidelined. The coming months are make-or-break: CDR needs strategic recognition and sufficient funding nowit cannot afford to wait another seven years. Carbon Gaps recommendations 1. Maintain and ringfence climate spending. Preserve the 35% climate spending target under the MFF and ensure that CDR is explicitly prioritised across all relevant programmes, including the FP10 and the ECF. 2. Secure dedicated funding for CDR under FP10. Allocate at least 2.6 billion to early-stage CDR research, development, and innovation during the next seven-year cycle. Establish a dedicated FP10 CDR destination to cluster relevant calls and ensure this emerging family of technologies is strategically prioritised, and given sufficient and coordinated funding. 3. Explicitly embed CDR into the European Competitiveness Fund. Amend the ECF Regulation to explicitly include carbon removal in Article 3.2(a) and Article 33(c), which refer to support for the clean transition and industrial decarbonisation. Current language only mentions CCS and CCU, which only partially cover CDR methods with a CCS component (e.g. DACCS, BECCS), while excluding others such as marine CDR, biochar, or enhanced weathering, which are not CCS-related. Explicit inclusion would provide legal clarity and fairer access to funding for all credible CDR pathways. 4. Ensure continuity and coordination between FP10 and the ECF. Create mechanisms to ensure that early-stage breakthroughs progress smoothly toward commercial deployment. FP10 and the ECF must align priorities, enabling projects to advance consistently along the TRL scale. Coordination will prevent funding gaps and accelerate the transition from research to market. Europe cannot reach net zero without carbon dioxide removal. The next MFF, FP10, and ECF must make CDR a strategic and budgetary priority or risk losing the opportunity to cultivate a potential 220 billion annual market and 670,000 new jobs in Europe, all vital to European competitiveness.
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Meeting with Nicolás González Casares (Member of the European Parliament) and Clean Air Task Force, Inc. and Bellona Europa

4 Nov 2025 · Climate action

Meeting with Ana Vasconcelos (Member of the European Parliament)

6 Oct 2025 · Climate 2040 targets

Meeting with Susana Solís Pérez (Member of the European Parliament) and Clean Air Task Force, Inc. and Bellona Europa

6 Oct 2025 · European Climate Law

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

1 Oct 2025 · Integration of carbon removal in EU policy

Response to Carbon removals, carbon farming and carbon storage - certification methodologies for permanent carbon removals

22 Sept 2025

Carbon Gap welcomes DG CLIMA continued engagement in building the policy mix CDR requires to grow, and the opportunity to provide feedback on the delegated acts of the Carbon Removal and Carbon Farming (CRCF) regulation. Carbon Gap supports the design of a robust CRCF as a trusted basis for a broader CDR policy mix. Therefore, we urge the Commission to carefully consider the last modifications needed to secure credible methodologies. 1) BECCS: Given the increasingly documented negative trends on LULUCF across Europe, BECCS needs to be kept to reasonable amounts. CRCF is creating a new incentive, needed for permanent CDR to materialize, but also at risk of worsening the situation. While the problem warrants evolutions in the broader policy mix governing the use of biomass, it is key to monitor the effect of CRCF, for which we call for the delegated acts to commit an impact assessment of the incentives created by the CRCF and the associated increase in biomass consumption and associated emissions in the LULUCF by the first and each review of the regulation. 2) Biochar: this methodology has been more controversial than the other two permanent removal methodologies largely because of the different nature of the biochar process and the difficulties to align its certification (monitoring and liability) with the requirements of the EU CO Storage Directive (Directive 2009/31/EC), as requested by the CRCF text (Art 2a and 2b). Consensus position: To support biochar as an important CDR method while limiting misalignment of the delegated acts with the CRCF itself and with the other permanent CDR methodologies, Carbon Gap has actively explored a consensus position with biochar players and NGOs (attached to this submission). A series of amendments is proposed to: - Improve the transparency on biomass sourcing by requiring the operators to disclose the geographical origin of the biomass - require a regular impact assessment of the growth of biomass-based CDR on biomass consumption and associated emissions. Such assessments should be conducted before each revision of the CRCF (the first in 2027) - Address the current lack of liability by introducing a buffer pool of 7% of the credit generated - Request additional targeted research promoted and overviewed by the Commission to reduce uncertainties on the risk of reversal of the recalcitrant fraction of biochar at surface conditions (exposure to biological activity, water, oxygen, radiation), further demonstrating the fate of biochar in a variety of agricultural fields (using tracers or isotopic marking) and exploring innovations that could help monitoring biochar. - Link explicitly this methodology to the reviews of the CRCF (the first one in 2027) to allow for modifications based on the growing science and revision of the buffer pool conditions (maintain, reduce, or release completely) We hope the Commission considers the modifications described here and in the attached documents to secure trusted and widely adopted CRCF methodologies.
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Carbon Gap urges separate targets for carbon dioxide removal

15 Sept 2025
Topic — This consultation concerns amending the European Climate Law with a 2040 target.
Message — Carbon Gap demands separate accounting for emission reductions, permanent removals, and land-based removals. They also call for new incentives and strict rules for international credits.12
Why — Clear targets and separate accounting would boost investment in permanent carbon removal technologies.3
Impact — Companies hoping to offset emissions instead of reducing them face stricter compliance rules.4
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Carbon Gap urges inclusive EU rules for carbon removal infrastructure

11 Sept 2025
Topic — The EU is developing a framework for competitive CO2 transportation and storage markets.
Message — The organization requests that new infrastructure rules accommodate carbon removal technologies alongside traditional capture methods. They advocate for an integrated system with non-discriminatory access to pipelines for all CO2 types.12
Why — This ensures carbon removal projects can access essential infrastructure without being sidelined by industrial giants.3
Impact — Legacy industrial emitters might lose exclusive control over carbon management networks and public funding.4
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Meeting with Mohammed Chahim (Member of the European Parliament)

29 Aug 2025 · Permanent Carbon Removals

Meeting with Christian Holzleitner (Head of Unit Climate Action), Luca De Carli (Head of Unit Climate Action), Mette Koefoed Quinn (Head of Unit Climate Action)

28 Aug 2025 · Carbon removals and international credits in the European Climate Law

Response to Evaluation on the operation of the Innovation Fund - 2025

8 Jul 2025

Making the Innovation Fund work for Carbon Dioxide Removal (CDR) 1. CDR must be a core objective of the Innovation Fund The Innovation Fund should explicitly include support for carbon dioxide removal (CDR) solutions, alongside emissions reductions and other forms of carbon management, including CCS and CCU, as a core objective. CDR is not optional. According to the IPCC, it's essential for climate neutrality, and it is also a strategic enabler of Europes long-term industrial leadership. However, CDR remains severely underfunded, receiving less than 0.1% of the EUs projected climate budget for 20212027, and lacks proper recognition as a standalone strategic objective, including under the IF. 2. Addressing design gaps The IF currently lacks dedicated design features to accommodate CDR. The most urgent gap is the absence of a dedicated CDR window or stream within regular calls for proposals. Without this, CDR projects are forced to compete with mitigation projects on unequal terms and unfit criteria, despite playing a fundamentally different role in the EU climate architecture. 3. Preparing future instruments for CDR deployment To prepare for future needs, the Innovation Fund should also enable: -CDR-specific auctions, once durable removal pathways and MRV standards mature; -Auctions-as-a-Service and Grants-as-a-Service models that allow Member States to co-fund CDR through EU-run frameworks; -Advance market commitments (AMCs) or carbon removal contracts-for-difference (CfDs) to stimulate demand and derisk investment in permanent removals. 4. Reforming selection criteria The current selection criteria risk systematically disadvantaging engineered carbon removal solutions such as DACCS, BECCS, Enhanced Rock Weathering and marine CDR. These projects are typically high-cost, high-risk, and often led by smaller or newer teams, yet they are essential for meeting the EUs net-zero and net-negative targets. The Innovation Fund should: -Introduce a specific criterion for carbon removal and storage durability; -Ensure degree of innovation includes first-of-a-kind deployment, robust MRV, and full-chain integration; -Apply cost-effectiveness with flexibility, acknowledging the higher early-stage costs of CDR. 5. Lowering barriers to participation for emerging actors Participating in the Innovation Fund is resource-intensive, especially for first-time applicants and novel actors in the CDR space. The application, reporting and compliance requirements are administratively heavy and poorly suited to early-stage or small-scale projects. For engineered CDR in particular, fitting within CCS reporting categories creates confusion and unnecessary burdens. In practice, many companiesparticularly start-upsmust hire consultants just to navigate the process. This assumes not just awareness of the opportunity but also the financial capacity to access external support. These barriers disproportionately affect smaller players, limiting applicant diversity and excluding promising projects. Tailored guidance, simplified reporting requirements, and better-aligned categories would ease the burden on smaller actors and improve accessibility. Lowering participation barriers is essential to ensure that the Innovation Fund reaches the full spectrum of climate solutions, including high-impact CDR pathways. Summary of key recommendations: -Explicit recognition of CDR as a distinct category for Innovation Fund support. Currently, only approaches with a CCS component qualify, excluding many promising methods. A dedicated category with appropriate criteria would enable fairer assessment and unlock solution diversity. -Stronger coordination with earlier-stage programmes like Horizon Europe. Lack of synergy currently fragments support and impedes scale-up. -Simplified application processes and improved accessibility for novel actors, particularly start-ups and SMEs. Clearer guidance, lighter documentation, and tailored support are essential.
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Carbon Gap calls for carbon removal in industrial policy

8 Jul 2025
Topic — The consultation aims to accelerate industrial decarbonisation and boost Europe's green competitiveness.
Message — Carbon Gap proposes integrating carbon removal into product labels. They recommend setting sectoral milestones and establishing EU-level contracts for difference. They also call for streamlined permitting.1234
Why — These measures would create a business case and attract private investment for carbon removal.56
Impact — Heavy industries face higher costs as voluntary milestones transition into mandatory removal targets.7
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Environmental Coalition on Standards and

7 Jul 2025 · Letter with 16 signatories for European Competitiveness Fund to deliver climate and energy security for EU citizens and SMEs

Carbon Gap seeks inclusion of permanent carbon removal in ETS

30 Jun 2025
Topic — The consultation reviews the EU Emissions Trading System for maritime, aviation, and stationary installations.
Message — The organization proposes integrating permanent carbon removal into the EU ETS while maintaining strict caps. They suggest a sub-mandate for removals and a separate compliance scheme for other sectors. These measures would ensure long-term demand for diverse removal technologies.123
Why — This would create a predictable, large-scale compliance market for carbon removal providers.45
Impact — Industrial polluters would face mandatory costs to fund expensive carbon removal projects.67
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Meeting with Annalisa Corrado (Member of the European Parliament)

14 May 2025 · Carbon Removal

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

13 May 2025 · Clean Industrial Deal to deliver a Joint Decarbonisation and Competitiveness Roadmap

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

8 May 2025 · CDR, negative emissions

Meeting with Peter Liese (Member of the European Parliament)

10 Apr 2025 · Austausch

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

31 Mar 2025 · discussions on Green Claims Directive

Meeting with Radan Kanev (Member of the European Parliament) and Negative Emissions Platform

18 Mar 2025 · Empowering Europe's Net Zero Future: Carbon Dioxide Removal as a catalyst for a competitive green transition

Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur)

6 Feb 2025 · Green Claims

Meeting with Andrea Wechsler (Member of the European Parliament) and Helmholtz-Gemeinschaft Deutscher Forschungszentren e.V. and Future Cleantech Architects

18 Dec 2024 · EU Energy and industry policy

Meeting with Lena Schilling (Member of the European Parliament)

14 Oct 2024 · carbon dioxide removal

Meeting with Ana Vasconcelos (Member of the European Parliament)

3 Oct 2024 · Carbon removal

Meeting with Oliver Schenk (Member of the European Parliament)

25 Sept 2024 · Net Zero

Meeting with Bruno Gonçalves (Member of the European Parliament) and Sciaena - Ocean # Conservation # Awareness

25 Sept 2024 · ITRE policies

Meeting with Bruno Tobback (Member of the European Parliament)

24 Sept 2024 · Carbon removals

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Sept 2024 · Carbon Dioxide Removal

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

18 Sept 2024 · Meeting with Carbon Gap & NEP about carbon removals in the new mandate

Meeting with Majdouline Sbai (Member of the European Parliament)

18 Sept 2024 · Echange sur les technologies d'élimination de carbone

Meeting with Martin Häusling (Member of the European Parliament)

17 Sept 2024 · Carbon Removal Strategy

Meeting with Christian Ehler (Member of the European Parliament)

10 Sept 2024 · CCUS and carbon removals

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

17 May 2024 · Carbon Removal Strategy

Meeting with Angelika Niebler (Member of the European Parliament)

7 May 2024 · EU climate policy

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

4 Dec 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

31 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Petros Kokkalis (Member of the European Parliament, Shadow rapporteur)

10 Oct 2023 · Green Claims

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Clean Air Task Force, Inc. and Bellona Europa

10 Oct 2023 · Carbon Removals (Staff level)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Apple Inc. and APPLiA (Home Appliance Europe)

28 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur) and APPLiA (Home Appliance Europe) and Round Table on Responsible Soy Association (RTRS)

6 Sept 2023 · Green Claims Directive

Carbon Gap Demands Dedicated EU Strategy for Carbon Removal

16 Aug 2023
Topic — EU consultation on policies for industrial carbon management and carbon dioxide removal infrastructure.
Message — The group calls for a dedicated strategy to scale up permanent carbon removal and infrastructure. They recommend setting 2040 targets and creating a central carbon bank for financial stability.12
Why — A dedicated strategy would establish Europe as a leader while providing long-term investment security.3
Impact — Polluters lose the option of using cheaper biogenic offsets to balance fossil fuel emissions.4
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Response to Environmental claims based on environmental footprint methods

20 Jul 2023

Climate-related claims are one way for companies to attempt to communicate their climate mitigation efforts to their customers. If such claims fail, arent real, and dont stand up to scientific scrutiny, they become a dangerous tool for greenwashing. Not only do such false claims mislead consumers, but they also lead to more carbon in the atmosphere which directly damages the livelihoods of people and the well-being of the planet. Without proper regulation, companies can claim to benefit the climate while continuing their damaging activities and being rewarded for it. In contrast, credible climate claims could allow companies to differentiate themselves from their competitors, enabling conscientious citizens to make educated purchase decisions, or giving governments a tool to incentivise environmental stewardship. Carbon Gap is particularly concerned with claims regarding the climate impact of a product, service, or organisation, and in particular, any claim which attempts to demonstrate progress toward, or the achievement of, climate neutrality or net zero emissions. These claims must be tightly regulated to ensure that only credible claims can be made. Since the publication of the Carbon Removal Certification Framework (CRCF) proposal last November, there has been an expectation that the Green Claims Directive would regulate the substantiation of such climate-related claims based on certified carbon removals, linking the two legislative proposals together. This expectation also comes in the aftermath of a recent finding that more than 90% of carbon credits used by companies to make different claims are largely inadequate, which led to follow-ups calling on the EU to disambiguate net zero claims. Unfortunately, the current Green Claims proposal does not meet these expectations and leaves a gaping hole in the EU legislative puzzle. Carbon Gap calls for stringent guardrails on any claims regarding a product, service, or an organisations net climate impact to prevent greenwashing, ensuring that emissions cannot be falsely netted against avoidance or reduction efforts that do not represent physical fluxes of carbon. To ensure that the Green Claims Directive achieves its aims, Carbon Gap calls on the EU co-legislators to strengthen the requirements around substantiating climate-related claims by: 1. Clearly defining what constitutes a legitimate net zero or climate neutral claim, and at a minimum ensuring that avoided emissions and emission reductions cannot be used to falsely claim that emissions have been neutralised; 2. Respecting the non-fungibility principle and timescales of carbon storage; 3. Addressing mitigation deterrence by providing a definition of residual or hard-to-abate emissions that becomes more stringent over time; 4. Clarifying the link and improving the interoperability with the Carbon Removal Certification Framework; 5. Strengthening requirements around disclosure, especially of which types of carbon credits companies are purchasing (avoidance, reduction, removals), and which emissions they are claiming to compensate with which carbon credits. For further analysis, please find our attached policy brief on Strengthening Net Zero Claims: The missing piece in the EU legislative puzzle.
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Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur for opinion) and Clean Air Task Force, Inc.

10 Jul 2023 · NZIA

Carbon Gap urges mandatory targets for corporate neutrality claims

7 Jul 2023
Topic — Consultation on technical standards for companies reporting environmental, social, and governance factors.
Message — Carbon Gap demands mandatory reporting of emission reduction targets when companies make neutrality claims. They seek to explicitly integrate the Carbon Removal Certification Framework into reporting requirements. The group also requests separating carbon removal credits from emission reduction credits to ensure transparency.123
Why — This would create a credible market for carbon removals by preventing greenwashing.45
Impact — Businesses making unsubstantiated net-zero claims lose the ability to hide behind opaque accounting.67
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Carbon Gap demands carbon removal inclusion in EU green law

27 Jun 2023
Topic — The Commission is proposing a framework to scale up European green technology manufacturing.
Message — Carbon Gap recommends expanding the list of strategic technologies to include carbon dioxide removal. They also support forcing oil and gas companies to build storage for captured carbon.12
Why — The proposal would provide critical support to ensure Europe remains a leader in carbon removal.34
Impact — Energy companies would face significant new costs and legal duties to store captured carbon.56
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

24 May 2023 · Carbon removals and certification

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Clean Air Task Force, Inc. and Bellona Europa

23 May 2023 · Differentiation between different kind of Carbon Removals (staff level)

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Carbon Gap pushes for stricter EU carbon removal certification

23 Mar 2023
Topic — A European Commission proposal to create a regulatory framework for certifying carbon removals.
Message — 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.12
Why — Robust standards would increase the market value and credibility of high-quality removal projects.34
Impact — Fossil fuel emitters would face higher costs if forced to use permanent removals.56
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

21 Mar 2023 · Carbon Removals Certification (staff level)

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

9 Feb 2023 · Green deal industrial plan and State aid.

Response to Interim evaluation of Horizon Europe

29 Jul 2022

This submission is written with projects and research initiatives related to Carbon Dioxide Removal (CDR) or negative emissions technologies in mind. Carbon Gap is an independent environmental NGO dedicated to providing policy support and expertise in the field of carbon dioxide removal and negative emissions. Carbon dioxide removal refers to an assortment of methods, both natural and technological, that remove carbon dioxide directly from the atmosphere (not from point sources like power plants) and safely store the associated carbon. Carbon Gap released an introductory brief on carbon removal, available on our website. Carbon dioxide removal is widely recognised as needing to achieve large scale in a short time frame for the EU and the world to reach net-zero emissions by 2050. The EU has recognized this in the Sustainable Carbon Cyles Communication, published in December 2021, and Horizon Europe has reflected that priority with some of its projects. Carbon Gap has analysed the presence of carbon removal-related projects for the review of the Horizon Europe program and is both optimistic about the volume of projects and funding so far, and hopeful that much more can be done to ensure that Europe is the world leader in safely developing and deploying carbon dioxide removal methods. Other jurisdictions, including the US and UK, have begun dedicating resources to carbon removal in a structured and targeted way. There is an opportunity for the EU to develop better programs, leveraging its scientific, regulatory, and entrepreneurial expertise, that effectively accelerate the growth of the carbon removal industry in support of climate action. Carbon Gap recommends several steps Horizon Europe could take to support the EU’s stated ambitions in this area, including better tracking its support for carbon removal separately from carbon capture and storage, increasing its budget for carbon removal projects, and funding a wider array of carbon removal projects across multiple domains.
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