Climate Cleanup Foundation
CC
Reverse climate change by enabling the sector that removes carbon dioxide with nature.
ID: 237676544865-69
Lobbying Activity
Response to Verification of carbon removals, carbon farming and carbon storage in products
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 offer immense carbon storage potential - (with the global potential recently estimated at over 16Gt/y, https://www.science.org/doi/10.1126/science.adq8594). Individual building certification costs 2,000-20,000, making group auditing essential for market viability. Solution: Expand Article 12 to include carbon storage in products. Allow group auditing for bio-based materials with similar properties, processing methods, and storage characteristics regardless of location. 2. Audit Cost Reduction Mechanisms Challenge: Auditor training costs 1,350-2,800 with ongoing requirements, constraining market participation. Costs are likely to rise with disproportionate auditing requirements, especially for small to medium scale projects. Solution: Enhance Article 14 with: * EU-funded tiered training programs with senior auditor mentorship * EU funding for auditing * Standardized digital verification tools reducing on-site requirements * Focus on consortium (group) auditing for multiple small projects * Risk-based sampling for standardised, low-risk activities 3. Ecological Expertise for Auditors Need: Biogenic carbon removal is fundamentally ecological. Auditors need understanding of ecosystem dynamics, soil science, plant physiology, and biodiversity interactions beyond current technical requirements. Enhancement: Modify Article 13(4)(c) to include ecological knowledge for nature-based removal (soil and otherwise). 4. Proportionality Principles Framework: EU law requires proportionate approaches when costs significantly exceed benefits. Current regulation lacks provisions for smaller projects facing disproportionate administrative burdens. Solution: Add Article 6a requiring proportionality assessments for projects under 1,000 tons CO annually, with simplified documentation, extended audit intervals, and standardised baselines where appropriate. Conclusion These enhancements would transform the CRCF into a truly inclusive framework. By extending group auditing to bio-based products, implementing cost reductions, requiring ecological expertise, and applying proportionality principles, the regulation can achieve broad participation while maintaining high standards. Implementation would position the CRCF to harness distributed potential across all project scales, driving innovation and meaningful climate impact throughout the EU.
Read full responseMeeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Stichting Gideon - Building Transitions Tribes
30 Nov 2021 · Rapport Construction Stored Carbon