Brussels, September 2025
The European Commission is preparing new certification rules for as part of the Carbon Removal Certification Framework (CRCF). In response, ERGaR has shared detailed input on the draft Delegated Act for certification methodologies.
ERGaR’s main point concerns the creation of a Single Market for (biogenic) CO2). The current rules require detailed knowledge of the full supply chain in the activity plans by the operators. This hampers the trading possibilities of biogenic CO2. More flexibility to make biogenic CO2 a tradable community is crucial in this.
Moreover, detailed recommendations from ERGaR include:
· Legal clarity between RED III and CRCF to prevent double counting and provide operators with certainty when accounting for biogenic CO₂ removals.
· Recognition of biogenic CO₂ as a tradable commodity, enabling market flexibility and the creation of a Single Market for CO₂.
· Improved mass balance tracking through registry or database systems to strengthen transparency and reduce fraud risks.
· Extending the activity period from 10 to 20 years, aligning certification cycles with investment and financing needs.
· Excluding disproportionate capital stock emissions, which would otherwise discourage investment and create unnecessary administrative burdens.
· Alignment of biogenic CO₂ definitions with RED III, along with proportionate sustainability requirements that avoid penalising smaller or innovative projects.
These adjustments would ensure that certification rules support environmental integrity while also fostering investment in permanent carbon removals.