tgo AG
nachhaltiger Umweltschutz und Klimaschutz, insbesondere Speicherung von CO2 und Carbon Farming in Europa 1. CO₂-Zertifikate mit EU-ETS CRCF kompatibel machen, um offizielle Emissionsreduktionen anzubieten. 2. Carbon Farming in EU-Regulierungen verankern (z. B. Bodenstrategie, Green Deal). 3. Unternehmen mit CSRD- und Taxonomie-Pflichten unterstützen, um CO₂-Reduktion handelbar zu machen. 4. Fördergelder für Innovationen Marktführerschaft nutzen. 5. EU-Lobbying für die Anerkennung von Carbon Farming als Schlüsselstrategie der Klimapolitik.
ID: 031056597180-61
Lobbying Activity
Response to Roadmap towards Nature Credits
14 Jul 2025
Feedback on the EU Initiative for Nature Credits Submitted by a nature-based solution provider working at the intersection of biodiversity, regenerative land use, and environmental accounting. We strongly support the European Commissions vision to create a Nature Credit framework that recognizes, measures and rewards ecosystem services beyond carbon. This initiative has the potential to become a cornerstone of Europe's green transition but only if designed for high ecological impact, wide accessibility, scientific integrity, and market readiness. To that end, we propose the following five priorities: 1. Reward verifiable ecological outcomes, not practices Nature Credits must go beyond intentions or standardized practices. They should be issued based on measurable, verified improvements in biodiversity, soil quality, water retention, ecosystem resilience or nutrient cycling. This calls for robust MRV systems, combining on-site data (e.g. soil samples, species inventories) with scalable tools such as remote sensing and AI-supported indicators. Nature regeneration must be traceable, quantifiable, and comparable across geographies without becoming cost-prohibitive for land stewards. 2. Include temporary and rotational services where impact is clear Short-term or rotational measures such as flowering strips, diversified cover crops, buffer zones or agroecological fallow provide real-time ecological services (e.g. pollinator support, erosion control, habitat enrichment). If properly monitored, they deserve temporary crediting. We urge the Commission to create a framework that allows for time-bound Nature Credits where permanence is not the main criterion but positive ecological effect is proven. This enables higher adoption rates and wider participation. 3. Ensure access for small and medium land managers The success of this framework will depend on its inclusivity. Small farms, community projects, and land cooperatives must not be excluded. A digital, low-barrier infrastructure is needed, including user-friendly dashboards, standard contract templates, and fair minimum pricing. A Nature Credit system that relies solely on large intermediaries or bureaucratic procedures risks alienating key actors who manage Europe's most diverse landscapes. 4. Align with but differentiate from carbon frameworks Nature Credits must be compatible with the CRCF, CSRD and SBTN methodologies, but retain their own distinct value proposition. They should not be seen merely as co-benefits of carbon projects, but as high-impact, standalone contributions to planetary health and resilience. Ideally, a registry should enable stacking of credits (e.g. carbon + biodiversity) with safeguards against double-counting, and create clear pathways for inclusion in supply chain decarbonization strategies. 5. Mobilize public-private investment via transparency and trust Nature Credits can serve as a key tool in ESG strategies, nature-positive procurement and biodiversity net gain policies. But trust must be earned through open methodologies, validation, ongoing verification, and accessible third-party review. Funding instruments and voluntary markets should be aligned early on to reduce fragmentation and support scale-up. We are a company actively working with landowners, farmers and municipalities to implement measurable nature-based solutions across Europe. We would be pleased to support the development of a credible, inclusive and effective Nature Credit system and contribute to the Expert Group with hands-on experience in MRV, regenerative metrics, and nature-positive finance.
Read full response25 Jun 2025
EU ETS Consultation Feedback Submission by tgo AG Proposal: Integrating Temporary Carbon Removals via Time Carbon Credit (TCC) Why we are submitting this feedback: We believe that temporary carbon removals from land such as soil carbon storage and agroforestry deserve clear recognition in the EU ETS. These solutions are fast, affordable, and backed by science. But current EU policy lacks a fair and reliable way to include them. With our Time Carbon Credit (TCC) proposal, we aim to close this policy gap. We offer a way to integrate these removals into the ETS, using real damage cost values, strong monitoring, and a transparent structure. This contribution is based on practical experience with farmers, scientific tools, and respect for climate integrity. The tgo AG proposes the introduction of a new mechanism the Time Carbon Credit (TCC) to formally recognize and integrate temporary soil-based CO removals (such as humus build-up and agroforestry) into the EU Emissions Trading System (EU ETS). This addresses a major policy gap: while permanent removals (e.g. DAC, CCS, biochar) are being considered, the EU ETS currently lacks an appropriate framework for scientifically verifiable, temporary carbon sinks, despite their significant climate potential. The TCC is an annually issued, MRV-based certificate that rewards farmers and landowners for each tonne of carbon verifiably stored in the soil. The payment continues as long as carbon remains stored and is discontinued if released preventing greenwashing and double-counting. TCC credits can operate in parallel with permanent removals and offer a scalable tool to complement CRCF and CSRD frameworks. Importantly, TCC pricing is anchored in the real cost of climate damage, not voluntary offsets. Based on the 2024 recommendations of the German Environment Agency (UBA), the damage cost of one tonne of CO is estimated at 880 (0% pure time preference). TCC translates this into 8.80 per tonne per year for 100 years ensuring fairness, transparency, and price stability. This encourages climate responsibility for buyers while making carbon farming economically viable for landholders. We recommend that the Commission Establish a dedicated ETS-R segment for carbon removals (permanent + temporary) Recognize TCCs as valid transitional compliance instruments Enable TCCs to feed into market stability reserves through Carbon Contribution Contracts (CCC) Support pilots and MRV platforms (e.g. AgriCoin, ACS2030) to build reliable infrastructure. TCC makes climate protection affordable, accountable, and inclusive and offers the EU a scientifically sound path to accelerate soil-based carbon removals in the critical years ahead.
Read full responseMeeting with Maxi Espeter (Cabinet of Commissioner Christophe Hansen)
10 Feb 2025 · Exchange of views on optimizing carbon farming