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Puro.earth

Puro.earth is the world’s leading carbon-crediting platform for durable carbon removal.

Lobbying Activity

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

22 Sept 2025

We welcome the publication of draft methodologies, which can support the scaling up of removal activities in the EU and eventually integrate them into the EU ETS. We applaud the Expert group in selecting the first methodologies to cover biochar, BioCCS and DACCS activities. Puro.earth has published 8 methodologies and issued over million credits to durable carbon removal since 2019. Based on that experience we see that biochar is the fastest growing carbon removal which can be deployed now, whereas BioCCS/DACCS offer great volumes with somewhat longer project development times towards 2030 and beyond. It is also good that the two first methodologies engage diverse project developer types: biochar more local small-to-medium size projects and BioCCS/DACCS industrial large-scale developers. The climate urgency needs all hands on deck. Additionality We understand that the current draft aims to incentivise significant short-term growth of permanent removals, and we agree with the rationale presented in Recital 4 of the Draft Delegated Regulation that there currently is a funding gap and lack of economic incentives for operators of these activities. We agree with the current draft that this approach is reviewed within at most 5 years to reassess if the situation has changed and new standardised baseline(s) are warranted. Biomass sustainability We understand the EU-wide harmonised approach in the current drafts that the sustainability requirements for biomass applied in respect of CRCF activities should not go beyond those applied to biomass for bioenergy installations that do not capture CO2. In the same way as renewable energy also BioCCS and Biochar activities should not create unsustainable demand for biomass raw material and should be conducted in accordance with the principle of the cascading use of biomass and should provide a transparent reporting of the type of biomass consumed by the activity and its GHG intensity. BioCCS activities with the primary purpose of producing heat or electricity from biomass combustion should demonstrate that the biomass consumption capacity of the facility has not increased by more than the amount necessary to supply energy for the capture of biogenic CO2 emissions. Uncertainty assessment and adjustment We understand that the EU aims to find a balance between the disproportionate burden for operators and meaningful characterization of uncertainty leaving room for certification scheme to diversify in the requirements they set. The IPCC uncertainty management guidelines referenced written for country-level national inventories are not necessarily appropriate for project-level calculations without unnecessary burden. We see a risk that the scheme-specific uncertainty calculations will not lead to consistent discounts and the same number of units issued. If the aim is to learn, we propose a change such that the uncertainty assessment is required as disclosure only for transparency, but the adjustment (uncertainty discount) should only be applied after a review within 5 years in line with Additionality provisions. If the above change proposal is not acceptable, we ask that the uncertainty ranges (2.5%-5%, 5%-10%, 10%-20%) to be removed and the actual uncertainty percentage to be applied. This small change may have a significant impact on the volume of generated units and project financial viability without compromising the principle of conservatism. For example, under the current draft an uncertainty estimate of 7% would fall in the 5%-10% range and would lead to the application of a conservatism factor of 0.9. This means that 100,000 net-removal tonnes would result in 90,000 units instead of 93,000 units if the actual level of uncertainty is applied. PLEASE SEE THE FULL LIST OF COMMENTS IN THE ATTACHMENT
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Response to Permanent storage of EU ETS emissions through carbon capture and utilisation

16 Jul 2024

Hello, please find attached the feedback from Puro.earth, a global carbon-crediting platform for durable carbon removals. Kind regards, Marianne & Helen
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

27 Oct 2023 · Carbon removals

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

Hello, Please find attached the feedback from Puro.earth an international certification scheme for durable carbon removals. Kind regards, Marianne & Helen
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Response to Environmental claims based on environmental footprint methods

21 Jul 2023

Hello, Please find attached the feedback from Puro.earth, a carbon removal crediting programme and through the Puro Standard we certify durable removal of CO2 from the atmosphere. We issue CO2 Removal Certificates, CORCs, per tonne of CO2 removed and durably stored for at least 100 years. CORCs are issued and retired in the public Puro Registry adding transparency to carbon markets. Kind regards, Marianne and Helen
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

29 Jun 2023 · Carbon Removals (Staff level)

Response to 2040 Climate Target Plan

23 Jun 2023

Please find attached the feedback from Puro.earth, a certification scheme for durable carbon removals globally. Kind regards, Helen Bray
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

9 May 2023 · Carbon removals

Response to Carbon Removal Certification

23 Mar 2023

Puro.earth is a carbon removal crediting platform and through the Puro Standard, we create and verify robust science-based methodologies for removal of CO2 from the atmosphere. Puro issues CO2 Removal Certificates, CORCs, per ton of CO2 removed and durably stored. CORCs are issued and retired in the public Puro Registry, adding transparency to carbon markets. Therefore, Puro.earth could apply to be recognised as a Certification Scheme under the proposed EU Carbon Removal Certification Framework (CRC-F) to certify the supply of EU Carbon Removal Units (EU-CRUs), and report EU-CRUs in the public Puro Registry. Puro.earth are pleased to provide our input, which can be found in the attached document. Kind regards, Marianne & Helen
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