CRCF: Europe's rules of play for carbon removal and carbon farming

Key Takeaway

Here's what's happening: The EU’s Regulation 2024/3012 - the Carbon Removals and Carbon Farming Certification Framework (CRCF) - is now in force, creating the first EU-wide voluntary framework for certifying carbon removals, carbon farming and carbon storage in products, across Europe. Approval of first methodologies expected by end of 2025/ early 2026.

Why it matters for companies: CSOs should build supplier relationships now to secure access to CRCF certified carbon credits for their forward portfolios.

Section 1: Framework Background

Concept & Purpose: The CRCF introduces a voluntary but harmonized EU quality standard, built on four pillars: quantification, additionality, long-term storage, and sustainability (QU.A.L.ITY). The framework covers permanent removals (several centuries), carbon farming (>5 years permanence), and product-based storage (>35 years permanence). The CRCF Certificate of Compliance set a standard to enable the deployment of carbon removal and carbon farming activities across the EU to to help achieve the EU’s nationally determined contribution (NDCs).

Impact & Status: The CRCF positions the EU as a global standard-setter in the emerging carbon removal economy. The Commission released initial and revised draft methodologies for certifying DACCS, BECCS and Biochar. The nominated Expert Group also discussed second drafts of carbon farming methodologies (agriculture and agroforestry, peatland, trees). Workshops on purchasing programs under the CRCF were hosted by the Commission introducing seven policy options.

Section 2: Expected Legislative Changes

Upcoming Deadline: In late 2025 and early 2026, the Commission plans to adopt two delegated acts, one for (a) methodologies related to DACCS, BECCS and Biochar, and (b) one for several carbon farming methods such as peatland rewetting, reforestation and agroforestry. Certification of the first units under the CRCF is expected throughout 2026. Adoption of rules to promote harmonised third-party verification is expected for Q3 2025. By mid-2026, the Commission will assess the potential inclusion of carbon removals with permanent storage in the EU ETS.

Regulatory Adoption: Draft methodologies proposed in April 2025 face scrutiny for potentially falling short of best practices of the VCM and Article 6.4. A substantial and consistent public funding of CRCF initiatives remains a key point of discussions.  

Section 3: Risks & Opportunities

Risks of Inaction:  Late movers potentially face limited access to supply of CRCF Certificates of Compliance from carbon removal and carbon farming projects from the EU in the early years. This might jeopardize the integrity of voluntary climate action as it is expected that CRCF rules will determine what credits qualify for any future integration of removals into the ETS. For participants in the mandatory market, opportunity costs might arise against higher ETS costs.

Benefits of Proactive Engagement: Early adopters can lock in long-term contracts before durability requirements rise. CRCF integration with CSRD creates operational efficiency, while “insetting” through internal carbon farming or storage unlocks both compliance and revenue. Early engagement builds internal expertise, investor trust, and strategic optionality as CRCF units move toward broader recognition.

Conclusion – 3 Strategic Actions for CFOs/CSOs

Alongside Article 6.4, the CRCF can become the cornerstone for scaling corporate carbon removal into the billions. To earn that role, it must set an uncompromising bar for quality - anchoring best practices from voluntary initiatives like the ICVCM. It must be embedded in UN frameworks, especially Article 6.4, and linked with the EU ETS to build a coherent global carbon market. Equally, it must open pathways for projects beyond Europe, ensuring climate action brings fair benefits to the Global South while safeguarding biodiversity in the planet’s most fragile ecosystems. The stakes are global. Anything less than a CRCF built on true integrity will not suffice.

CSO/CFOs should hence: 

• Monitor the Commission’s delegated acts for permanent removals, carbon-farming and storage-in-products. Submit input during Expert Group consultations.
• Update procurement guardrails and align RFPs and due-diligence checklists with CRCF “QU.A.L.ITY” criteria (Quantification, Additionality, Long-term storage, Sustainability), expected baseline/monitoring rules, and liability mechanisms.
• Prepare for signing long-term offtake agreements with relevant CRCF credits from projects already advancing through methodologies currently in delegated acts.

Appendix – Sources and Further Reading:

1. EU Climate Action – Carbon Removals & Farming Overview (Dec 2024) https://climate.ec.europa.eu/eu-action/carbon-removals-and-carbon-farming_en

2. Official Journal – Regulation (EU) 2024/3012 text (Dec 2024) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R3012

3. European Parliament – Legislative Train: Carbon Removal Certification (Jan 2025) https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-carbon-removal-certification

4. Carbon Market Watch – CRCF Methodologies Among Lowest Quality (Jun 2025) https://carbonmarketwatch.org/2025/06/02/carbon-certification-removal-framework-crcf-methodologies-among-lowest-quality-analysis/

5. Carbon Gap Tracker – EU CRCF Policy Tracker (updated Jul 2025) https://tracker.carbongap.org/policy/crcf/

6. Zero Emissions Platform – Recommendations for CRCF Delegated Acts (Oct 2024) https://zeroemissionsplatform.eu/publication/recommendations-for-the-certification-of-carbon-removals/

7. Jones Day – New Carbon Removal Certification Framework in Europe (Mar 2025) https://www.jonesday.com/en/insights/2025/03/new-carbon-removal-certification-framework-in-europe

8. DevelopmentAid – Scaling CDR – What to Expect from EU CRCF (Jul 2025) https://www.developmentaid.org/news-stream/post/197764/scaling-carbon-dioxide-removal

9. Financial Times – Governments Will Be Key to Fixing Carbon Credit Market (Jun 2025) https://www.ft.com/content/199d8e79-61e1-4260-b185-cf2152278dcb

10. Carbon Pulse – Price of Nature‑Based CDR Doubled in H1 2025 (Jul 2025) https://carbon-pulse.com/420252/