.jpg)
On October 21st, eighty experts gathered in a conference room in Brussels for the 5th Meeting of the Carbon Removals Expert Group. This meeting flew largely under the radar. The agenda sounded technical, even esoteric. Who has time to pay attention to that kind of bureaucratic minutiae? However, this was a critical milestone for the carbon removal (CDR) industry. It marked the first time a national government had published methodologies for durable carbon removal.
These methodologies set out the guidelines for any company seeking an EU stamp of approval on their carbon credits. They covered three pathways: Direct Air Capture (DAC), Bio-CCS, and biochar. Because they are reasonably high-level in most areas, the expectation is that they will be underpinned by more detailed protocols produced by EU-regulated Certification Schemes (in the voluntary carbon markets, these are known as: “registries” or “standards”—Isometric is one).
The most notable point of contention related to accounting for emissions from biomass. The EU understandably wants consistency across different pieces of climate legislation. This means that emissions from biomass feedstocks are calculated in the same way as under the Renewable Energy Directive (RED), relying on a set of default values. This can miss potentially significant local “market leakage” effects, such as where high demand for biomass in a specific region leads to more land being converted to growing that biomass. This could result in Bio-CCS facilities issuing more credits than they would have done under stricter rules. For example, the buyer’s group Frontier have produced biomass sourcing principles that require projects to account for a comprehensive set of emissions related to the biomass feedstock, including market leakage effects. In the room, this led to a fiery discussion between environmental NGOs pushing for stricter rules, and Bio-CCS suppliers supportive of the Commission’s position.
Notwithstanding this point, there was a surprising degree of consensus on the methodologies. Most of the other topics raised were relatively minor, many of which are likely to be addressed through drafting tweaks. This means the methodologies could move into the next formal stage of the process as soon as Q1 next year. That makes it plausible that they could be formally implemented as Delegated Acts during 2025. Other parts of the Carbon Removals and Carbon Farming Framework (CRCF), such as the approval process for Certification Schemes, will take a few months longer. This means the first CRCF credits are likely to be issued from 2026 onwards.
Road to regulation
I don’t believe the distinction between “compliance” and “voluntary” markets will last the decade. Governments need to regulate carbon credits: define what good credits look like and set rules for the key players involved in generating, verifying, and issuing them. Long before 2050, when the planet needs billions of tonnes of carbon being pulled out of the atmosphere every year, we should have moved to a world not of both compliance and voluntary markets but simply: regulated carbon markets. Just as countries have regulated banks, medicines, and other goods that are too critical to rely on caveat emptor.
But regulation takes time. At Isometric we believe trust is critical to scaling this market. We can’t afford to jeopardize that trust by cutting corners now, just because the markets aren’t properly regulated yet. So our approach has been to behave as if we are already regulated. That’s why we have invested in developing the most scientifically rigorous protocols on the market. It means we are ready for when regulations do arrive.
CRCF has provided our first proof point of this model—our DAC, Bio-CCS and biochar protocols already meet or exceed the substantive requirements set out in the EU’s draft methodologies. Our DAC and Bio-CCS protocols set out requirements for a transition to hourly matching of low-carbon power procurement. And our biochar protocol incorporates random reflectance testing for biochar durability, reflecting the latest scientific developments. These requirements are included in the EU’s draft methodologies. Isometric’s protocols are the only ones on the market to have already implemented these approaches.
CRCF = GDPR * CDR?
CRCF is not the only show in town, but it is the furthest ahead. Japan last month released their long-awaited DAC methodology. Canada has been working on one for a couple of years and publication is due imminently. In the UK, the proposed integration of removals into the ETS from 2028 gives a clear need for methodologies—they have commissioned the British Standards Institute to start working on the first set of these, due out in 2025. The EU’s role as a first mover is important—just as has happened for data with GDPR, there is a good chance that CRCF can have outsized impact through the so-called “Brussels effect”. This is especially true given the incoming Trump administration is very unlikely to set out new regulations for carbon removal. US multinationals are likely to simply follow the EU’s approach in their buying decisions.
Progress on Article 6.4 in Baku may have grabbed the headlines recently. But a wet and windy day in Brussels may actually prove more significant for the industry in the long-run.
