A coalition of environmental organizations has formally requested the European Commission to review recently adopted methodologies governing biogenic emissions capture with carbon storage (Bio-CCS) and biochar carbon removal under the European Union’s Carbon Removals and Carbon Farming (CRCF) Regulation. The request for internal review argues that the methodologies fail to meet the regulation’s requirement of delivering permanent carbon dioxide removal from the atmosphere and therefore do not fulfill their intended climate objectives.
The challenge has been submitted by several environmental groups, including organizations focused on climate policy, forest conservation, biodiversity protection, and environmental accountability. The coalition contends that the methodologies overlook important scientific evidence and international standards related to the quantification, monitoring, and sustainability of carbon removal activities. According to the organizations, the current framework does not adequately address the impacts of these activities on forests, agricultural land, and broader ecosystems.
The environmental groups argue that the methodologies could weaken the credibility of the European Union’s carbon removal framework by certifying activities that may not result in genuine long-term carbon removal. They warn that some projects could potentially increase carbon dioxide emissions rather than reduce them, undermining climate mitigation efforts and diverting investment away from more reliable carbon removal technologies and practices.
Concerns have also been raised regarding the potential future use of carbon removals within the European Union Emissions Trading System (ETS). The organizations fear that if flawed carbon removal credits are permitted to offset fossil fuel emissions, it could weaken overall climate action efforts and reduce incentives for direct emissions reductions. They stress that carbon removal methodologies must be based on robust scientific evidence to ensure environmental integrity and prevent greenwashing.
Under the Aarhus Regulation, the European Commission is required to examine the request and provide a response within a specified timeframe. The Commission may either accept or reject the grounds for review. If the request is denied, the environmental organizations have the option of pursuing legal action before the General Court of the European Union to challenge the decision.
Environmental advocates involved in the review request argue that they have spent several years engaging with the Commission through expert groups, consultations, and policy discussions. They claim that numerous recommendations aimed at strengthening the methodologies were not adequately reflected in the final delegated act. As a result, they believe the adopted rules do not fully comply with the objectives and requirements established under the CRCF Regulation.
Several organizations involved in the challenge emphasize that effective carbon removal policies must account for impacts on forests, biodiversity, water resources, air quality, and agricultural systems. They argue that carbon accounting approaches that focus solely on carbon storage without evaluating broader ecosystem effects risk creating unintended environmental consequences. Critics also express concern that incentives for biomass-based carbon removal technologies could increase demand for forest resources, potentially affecting forest health and long-term carbon storage capacity.
The Carbon Removals and Carbon Farming Regulation was developed to establish a voluntary European framework for certifying high-quality carbon removals, carbon farming activities, and carbon storage solutions. The regulation aims to support the European Union’s climate neutrality goals while ensuring that certified activities produce measurable and verifiable climate benefits. It is intended to encourage investment in climate solutions while preventing misleading environmental claims.
The delegated act under review represents the first set of certification methodologies adopted under the CRCF framework. These methodologies cover permanent carbon removal approaches, including direct air carbon capture and storage, Bio-CCS, and biochar carbon removal. The regulation defines permanent carbon removals as activities that remove carbon dioxide from the atmosphere and securely store it for centuries.
The current challenge highlights the growing debate surrounding the role of carbon removal technologies in climate policy. While many policymakers view carbon removals as an important tool for achieving long-term climate goals, environmental organizations continue to stress the need for rigorous scientific standards, transparent monitoring systems, and strong safeguards to ensure that carbon removal projects deliver genuine and lasting environmental benefits.
As the European Commission reviews the request, the outcome could have significant implications for the future development of carbon removal markets, climate certification standards, and the broader implementation of the European Union’s climate strategy. The decision may also influence how carbon removal activities are integrated into future climate policies and emissions reduction frameworks across Europe.







