On 30 November 2022, the European Commission published a proposal for a Regulation that would give an EU stamp of approval for public and private activities that claim to remove carbon dioxide from the atmosphere. This law is meant to give incentives to farmers and foresters to achieve the carbon removal target under the Land Use Land Use Change and Forestry (LULUCF) Regulation, but also supports bioenergy production and the existing logic of the Renewable Energy Directive, where bioenergy is seen as ‘carbon neutral’. Given its timid approach (‘neutral’ environmental impact is sufficient) and the decision to embrace dubious products and technologies, it is poised to create a certification scheme that, other than generating undeserved ‘green’ publicity, achieves nothing.
This proposed EU framework is voluntary and would establish minimum criteria for a variety of activities or products that could be certified as having removed carbon. This can include quantifying carbon removed: in ecosystems through activities such as tree-planting, through technical processes like Bioenergy with Carbon Capture and Storage (BECCS), or stored in products like paper or furniture.
It is hard to yet know what could be considered a carbon removal but the proposal appears to suggest that short-lived paper products, BECCS plants and improved forestry methods could all be certified, despite their wildly different environmental risks and impacts.
The proposal does not go beyond ensuring a ‘neutral’ environmental impact, which means it is unlikely to promote activities that restore ecosystems or improve Europe’s biodiversity. To remove carbon and withstand the increasing climate impact, land systems need to be restored to health and resiliency, which would suggest promoting land-use activities such as close-to-nature forestry or agroecology. It is surprising, therefore, that these are not emphasised in this proposal, despite them offering clear alternative business models for farmers and foresters that are not incentivised by current EU subsidy schemes.
Activities with a significant land use impact are explicitly promoted. Activities such as tree-planting are put on a par with unproven engineered solutions like BECCS as potential methodologies/activities to be certified. Yet, the Intergovernmental Panel on Climate Change (IPCC) calls for restrictive use of engineered carbon removal technologies, suggesting it should not be incentivised through policy. This is one of many reasons that NGOs and scientists say that activities such as BECCS should not be considered.
Additionally, the EU considers rewarding wood products that store carbon only temporarily – a dangerous logic: products such as paper may store carbon for a year (or less) before being thrown away. The paper industry has the same climate impact as the aviation sector, and encouraging the continued consumption of such products will only worsen the pressures on forests. Even certification schemes for bioenergy – an activity in the EU which often burn whole logs (FW 279) – are referenced as a tool to ‘certify also the compliance of carbon removal activities with the quality criteria for carbon removals’.
The proposal supports regulating voluntary carbon markets for offsetting, although offsetting would not lead to less carbon dioxide in the atmosphere. When it was last part of legal EU climate requirements, carbon offsetting incentivised companies to pollute more and profit off doing so pollute more and profit off doing so – which is why it was banned. Even in an ideal world, offsetting does not lead to a reduction in carbon emissions; it merely cancels out pollution somewhere else. On principle, therefore, no carbon offset certification can be approved if the credibility of EU policy on carbon removals is to be maintained. It should be crystal clear that any certified carbon removal activity must lead to less carbon in the atmosphere than before.
The EU has bitten off more than it can chew with this proposal. To stay within the goals of the European Green Deal, the EU should be setting out rules for land use activities that respect our biodiversity and climate targets. The current proposal is not set up to achieve these goals; if it is not drastically changed, it will merely be an exercise in greenwashing, and we will be farther from the just transition that forests, and the foresters who tend them, desperately need.