Orejen Carbon’s Guide to Europe’s New Carbon Removal Rulebook - CRCF, Compliance and the Future of CDR

The EU has adopted a new rulebook for carbon removals.

With the Carbon Removals and Carbon Farming (CRCF) Regulation (EU) 2024/3012 now in force, and the first Implementing Regulation (EU) 2025/2358 adopted in November 2025, Europe has created the first EU-wide voluntary framework for certifying:

• permanent carbon removals,
• carbon farming activities, and
• carbon storage in long-lived products.

For the carbon removal ecosystem — and for biochar carbon removal (BCR) in particular — this marks a turning point: voluntary-market practice is beginning to align with EU-grade certification rules.

Below, we explain why CRCF exists, what it actually does, how biochar fits in, and how Orejen Carbon is building for this future today.

Why the EU cares so much about carbon removals

The EU Climate Law sets a legally binding objective of climate neutrality by 2050. On 10 December 2025, the European Parliament and the Council reached a provisional agreement to amend the Climate Law, introducing a binding intermediate target of –90% net greenhouse gas emissions by 2040, compared to 1990 levels. The agreement also allows for up to 5% of that target to be met through high-quality international carbon credits from 2036 onwards — corresponding to domestic reductions of 85% by 2040.

Reaching that target is no longer credible through emissions reductions alone.

Under the EU's Industrial Carbon Management strategy, the Commission estimates that:

• CO₂ capture must scale to ~280 Mt/year by 2040 and ~450 Mt/year by 2050, and
• carbon removals (biogenic removals and DACCS) will need to account for close to half of captured CO₂ by 2040, rising to over 50% by 2050.

At the same time, Europe's natural carbon sink is weakening.

Recent EU data and scientific assessments show that European forests absorbed around 332 Mt CO₂ per year in 2020–2022, down from roughly 457 Mt CO₂ per year in 2010–2014 — a ~27% decline in just over a decade. Historically, forests absorbed around 10% of EU anthropogenic emissions, but that contribution is falling as climate stress, fires, pests and harvesting pressures intensify.

The implication is clear: the EU cannot meet its climate targets without scaling high-integrity carbon removals.

CRCF is one of the EU's central responses — not a subsidy scheme, but a quality, integrity and transparency framework designed to make carbon removals credible, comparable and investable.

What CRCF actually does

Scope and activity types

Regulation (EU) 2024/3012 establishes a voluntary Union certification framework covering three activity categories:

1. Permanent carbon removals

Human activities that remove CO₂ from the atmosphere and store it securely for several centuries, including:

• Direct Air Capture with Carbon Storage (DACCS),
• Biogenic emissions capture with storage (BioCCS / BioCSS),
• Biochar carbon removal (BCR),
• Enhanced rock weathering, ocean alkalinity enhancement and similar approaches.

2. Carbon farming

Land-based activities that increase carbon stocks or reduce soil emissions, such as agroforestry, peatland rewetting, reforestation and improved nutrient management.

3. Carbon storage in products

Long-lived bio-based materials (e.g. timber used in buildings).

CRCF applies to activities within the EU, and certified units may only contribute to EU climate targets and the EU's NDC, not to other countries' NDCs or international compliance schemes — a deliberate design choice to avoid double counting.

While CRCF distinguishes between different unit types (e.g. permanent removal units versus carbon-farming units), quality criteria and certification principles are harmonised at EU level.

The QU.A.L.ITY criteria

All certified activities must meet the four QU.A.L.ITY criteria embedded in the regulation:

• Quantification – conservative, baseline-based accounting of net climate benefit;
• Additionality – activities must go beyond legal requirements and common practice;
• Long-term storage – robust rules for permanence, monitoring, reversal risk and liability;
• Sustainability – safeguards for biodiversity, soil, water, pollution prevention, circularity and other environmental objectives.

Together, these criteria codify what "high-quality carbon removal" means in EU climate policy.

Voluntary — but with hard edges

CRCF is voluntary. No project developer or certification scheme is forced to participate.

But participation comes with clear boundaries:

• Harmonised definitions and quality thresholds,
• EU-level recognition of certification schemes,
• A Union-wide CRCF registry, to be operational by 27 December 2028,
• Mandatory transparency, auditability and public information.

The regulation also requires a formal review by 31 July 2026, including assessment of how CRCF aligns with Paris Agreement Article 6 and evolving international best practice.

The first Implementing Regulation: how schemes and audits must work

On 20 November 2025, the Commission adopted Implementing Regulation (EU) 2025/2358, setting out detailed rules for certification schemes, certification bodies and audits under CRCF.

Key elements include:

• Governance and integrity requirements for certification schemes, including complaint handling, documentation control and transparent fee structures;
• Harmonised audit rules and accreditation requirements for certification bodies;
• Explicit provisions to prevent "scheme hopping" — where a project rejected under one scheme immediately applies under another — reinforcing that CRCF is designed for quality, not convenience;
• Five-year validity for scheme recognition, subject to ongoing compliance.

According to the Commission, the first calls for scheme applications are expected in early 2026, with initial CRCF units likely to be issued from 2026 onward, once certification methodologies are formally adopted.

What's coming next: Delegated Acts, Buyers' Club and demand signals

Several developments significantly strengthen the CRCF story — and are easily overlooked.

Delegated Acts: methodologies are coming

The Commission is finalising two Delegated Regulations setting out certification methodologies:

• One for permanent carbon removals, explicitly covering DACCS, BioCSS and biochar carbon removal, and
• One for carbon farming activities.

According to the Commission's Christian Holzleitner, the draft methodologies for DACCS, BioCCS and biochar are now considered "very mature." The permanent removals methodology is expected to be formally adopted in early 2026, with carbon farming methodologies following by April 2026.

Built-in safeguards for biochar: The Commission has confirmed that all CRCF methodologies will undergo review at least every four years, informed by ongoing data-sharing and scientific developments. For biochar specifically, the methodology includes a conservatism factor for measuring permanent removals in biochar samples — a signal that the EU is taking permanence seriously while building in room for methodological refinement as science evolves.‍

Long activity periods for investor confidence: For BioCCS and DACCS projects, the Commission has extended the activity period to 15 years (previously 10), explicitly designed to give investors the predictability they need to finance large-scale carbon removal infrastructure.

The EU Buyers' Club: demand made visible

To kick-start demand for CRCF-certified units, the Commission has announced the creation of an EU Buyers' Club — a voluntary initiative bringing together public and private buyers to send a clear demand signal for high-integrity carbon removals and carbon farming under CRCF. The Commission will host workshops in the first half of 2026 to further develop this initiative.

This is a crucial step: CRCF is no longer just a regulatory framework — it is becoming a market-shaping instrument.

Registry readiness: leading standards are already aligning

While the formal EU recognition process won't launch until early 2026, leading carbon registries are already positioning for CRCF alignment.

Isometric — one of the registries Orejen Carbon works with — has explicitly stated that its protocols for Direct Air Capture (DAC), Bio-CCS and Biochar already meet or exceed the EU's draft methodologies and the quality thresholds (such as 200+ years of durability) set out in the CRCF regulation.

Importantly, no registry has yet received formal CRCF approval from the European Commission — that process begins in 2026 with a formal call for certification scheme applications, followed by evaluation against CRCF criteria and five-year recognition decisions for successful applicants.

However, Isometric has already secured endorsements from the three major independent accreditation bodies in the voluntary carbon market:

• ICVCM (Integrity Council for the Voluntary Carbon Market): Approved as a Carbon Crediting Program (CCP-Eligible), able to issue credits with the Core Carbon Principles (CCP) label — widely viewed by buyers as a marker of trustworthiness and high integrity.
• CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation): Conditional approval to issue eligible emissions units.
• ICROA (International Carbon Reduction and Offset Alliance): Conditional endorsement.

For project developers, this matters. Working with registries that are already aligned with CRCF-grade quality thresholds — and recognised by ICVCM, CORSIA and ICROA — means your tonnes are positioned for EU demand before formal CRCF recognition even begins.

The Empowering Consumers Directive: why corporates will care

This section replaces the previous Green Claims Directive section]

A major near-term demand driver is the Empowering Consumers for the Green Transition Directive (ECGT), which entered into force in March 2024 and will apply across the EU from September 2026.

The ECGT introduces specific prohibitions that will reshape how companies communicate climate performance:

• Generic environmental claims (e.g. "eco-friendly," "green," "climate friendly") will be banned unless backed by recognised excellent environmental performance.
• Offset-based product claims — any claim that a product has a "neutral, reduced or positive impact in terms of greenhouse gas emissions" based on offsetting — will be flatly prohibited.

For companies that have relied on offset-based "climate neutral" product labels, September 2026 marks a hard deadline. CRCF-aligned carbon removal units — which represent genuine, additional, permanent removals rather than offsets — are increasingly viewed as the credible alternative for substantiating corporate climate claims.

Note: The EU's proposed Green Claims Directive, which would have introduced additional substantiation and verification requirements, was paused in June 2025 amid political concerns about administrative burden. The Commission announced its intention to withdraw the proposal on 20 June 2025, and negotiations were suspended. However, the ECGT remains in force and will apply regardless of the Green Claims Directive's fate.

Why your biochar project should get CRCF-ready — wherever it is

Legally, CRCF applies to activities within the EU and units that count towards EU targets.

Practically, its influence could reshape carbon removal markets globally — including across Southeast Asia and India, where Orejen Carbon operates.

The EU market pathway is real, but limited

The 2040 climate target agreement allows up to 5% of EU emissions reductions to come from high-quality international carbon credits from 2036 onwards. For projects in the Global South, this creates a direct pathway to European compliance demand — but the volumes will be capped and competition for that allocation will be intense.

The bigger story: CRCF as the global benchmark

The more significant dynamic is that CRCF could become the de facto quality standard for carbon removals worldwide — regardless of where credits are ultimately retired.

This follows a pattern the EU has established before. Just as GDPR became the global reference point for data privacy and REACH shaped chemical safety standards internationally, CRCF is positioning itself as the benchmark that defines what "high-quality carbon removal" means. The EU's market size, regulatory sophistication and first-mover status on removal certification give it outsized influence on how quality is defined in many regions.

For projects in Southeast Asia and India, this matters in several concrete ways:

1. Voluntary market convergence

Leading registries — including Isometric, Puro.earth, EBC/WBC and CSI — are already aligning their protocols to ensure they meet or exceed CRCF draft methodologies.

2. Corporate buyer expectations

European corporates subject to the Empowering Consumers Directive (applying from September 2026) will need removal-based solutions rather than offsets. But it's not just European buyers — multinational corporates headquartered anywhere are increasingly adopting EU-aligned standards for their global supply chains. A biochar project in Vietnam or India selling to a US-headquartered company with European operations could face CRCF-grade expectations.

3. Article 6 alignment

The EU must assess CRCF's alignment with Paris Agreement Article 6 by 31 July 2026. If CRCF criteria become the reference point for what qualifies as a high-integrity removal under Article 6.4, projects not built to that standard could find themselves excluded from sovereign-to-sovereign carbon trading mechanisms.

4. Institutional capital requirements

Climate funds, development finance institutions and impact investors are coalescing around common quality frameworks. CRCF's QU.A.L.ITY criteria — quantification, additionality, long-term storage, sustainability — are becoming the checklist that capital providers use to assess project bankability. Projects that can demonstrate CRCF-grade MRV and permanence may have an easier path to finance.

5. Future-proofing against regulatory spread

As more countries develop domestic carbon removal frameworks, they'll potentially look to CRCF as a template — just as many data protection regimes drew on GDPR.

The bottom line for SEA and India projects

CRCF-readiness isn't primarily about accessing the EU market directly (though that pathway exists). It's about positioning for a world where CRCF-grade quality becomes table stakes for or significantly influences premium buyers, institutional capital and future compliance markets — wherever they're located.

Projects that treat CRCF as "an EU regulation that doesn't apply to us" may find themselves competing on price in a commoditised market. Projects that build to CRCF-grade standards now may improve their access to the buyers, capital and policy frameworks that define the high-integrity end of the market.

For biochar projects across Southeast Asia and India, we believe the choice is compelling: build for where the market is heading, not where it was.

Orejen Carbon's perspective: build for CRCF now

For Orejen Carbon, CRCF is not abstract policy.

It is the rulebook our partners may ultimately be measured against.

Orejen Carbon supports high-integrity biochar carbon removal with digital MRV (dMRV) infrastructure and project expertise, enabling:

• Automated baseline and additionality tracking,
• Chain-of-custody traceability from biomass residue sourcing to durable carbon storage,
• Audit-ready data pipelines aligned with QU.A.L.ITY requirements,
• Integration with leading standards and certifications including Isometric, Puro.earth, EBC/WBC and CSI.

Our alignment with Isometric — whose protocols already meet or exceed CRCF draft methodology thresholds and carry ICVCM Core Carbon Principles approval — means projects we support are positioned for EU buyer demand today, not just when formal CRCF recognition concludes.

Our approach is simple:

Design as if CRCF-grade MRV is already mandatory.

Projects that are CRCF-ready today are better positioned for EU buyers, institutional capital and future Article 6 pathways — regardless of geography.

→ Work with Orejen Carbon to make your biochar pipeline CRCF-ready from day one.

Why Isometric alignment matters

Isometric's biochar protocol already meets or exceeds CRCF draft methodology requirements, including 200+ year durability thresholds. While formal EU recognition begins in 2026, Isometric has secured approval from ICVCM (Core Carbon Principles), CORSIA and ICROA — several of the voluntary market's leading integrity benchmarks. For Orejen Carbon partners, this means your tonnes carry credibility with EU buyers today.

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Sources:

European Council press release, 10 December 2025; European Parliament press release, 10 December 2025.

Carbon Gap CRCF Tracker.

European Commission press release, 1 December 2025.

Bellona EU report on CRCF Expert Group meeting, 17 November 2025.

Senken analysis of Green Claims Directive and ECGT, December 2025; Hogan Lovells legal analysis, June 2025.

Latham & Watkins legal analysis, June 2025; EU Commission statements.