Policy Positions

We believe in openness and transparency. This is why you will find below all the policy positions produced by the Negative Emissions Platform and representing the views of our members.

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EU Policy Positions

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National Policy Positions

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Global Policy Positions

Central EU Strategy

Make Carbon Removals a Strategic Pillar with Separate Targets for a Competitive, Net Zero Europe


  • 2040 Climate Targets

    The 2021 European Climate Law demands that the 2040 Climate Targets will need to put the EU on track for achieving climate neutrality by 2050.

    On 6 February, the European Commission published its Industrial Carbon Management Strategy. This strategy outlines how carbon capture and storage (CCS) and carbon dioxide removal (CDR) technologies could help reduce emissions by 90% by 2040, and achieve climate neutrality by 2050.

    Reaction

    Industrial Carbon Management Strategy Position Paper

    Feedback on the 2040 Climate Targets

  • Boosting EU Competitiveness through Carbon Removals

    This paper discusses the important role carbon dioxide removal (CDR) technologies can play in enhancing the EU's competitiveness, highlighting the sector’s economic potential, and what policies are needed to realise this potential. The EU has the chance to lead in carbon dioxide removal (CDR) by adopting forward-thinking policies and investing in the sector, which could boost jobs and competitiveness. However, it faces global competition from the US and China. Key policies like the Clean Industrial Deal and a CDR Strategy are needed to drive innovation. Significant public and private funding, through programs like the Innovation Fund and tax incentives, is essential to meet climate goals and scale up CDR.

Clear Demand

Establish Clear and Stable Demand for CDR through Carbon Markets


  • EU Compliance Market Position

    In the EU, there has been increasing discussion about establishing a compliance market for carbon removals with the European Commission required to evaluate how carbon removals could be integrated into emissions trading by 2026. The need for a compliance market is underscored by discussions on setting a potential target for carbon removals in the revision of the EU Climate Law, with the Commission expected to put forward a legislative proposal next year.

    This paper makes the case for establishing an EU compliance market for carbon removals, outlining the necessary criteria to be considered. NEP intends to come forward with a more detailed position on the desired architecture for a compliance market.

  • Green Claims Directive

    The Green Claims Directive proposed by the European Commission is crucial for combating greenwashing and promoting investment in permanent carbon removal. This directive would require companies to substantiate and communicate their environmental claims, including guidelines on using carbon credits.

    Trialogue Position

    Joint Letter

    Open Letter

  • Scenic landscape with rolling hills, wind turbines, and a mix of trees and farm buildings under a partly cloudy sky.

    SBTI Corporate Net Zero Standard

    SBTi’s revised draft Corporate Net-Zero Standard (CNZS 2.0) moves in the right direction by aiming to tighten net-zero integrity and introducing a framework to recognise companies that take early action on ongoing emissions with removals. NEP Reaction_SBTi Updated CNZS …

    However, NEP is concerned the draft still doesn’t provide the clear, timely and investable demand signal needed to scale high-quality, permanent carbon removals. We also flag risks that could unintentionally weaken corporate action and slow market development — including proposed co-claiming restrictions that may disrupt blended finance models, durability guidance that is not science-aligned and does not embed a like-for-like approach for fossil residuals, and an implementation timeline that makes action on ongoing emissions with removals mandatory only from 2035.

  • EU ETS - CDR Integration

    The Negative Emissions Platform (NEP) calls for the integration of permanent carbon dioxide removals (CDR) into the EU Emissions Trading System (ETS) through a phased approach. This would support the EU’s path to net-zero by creating long-term demand and revenue certainty for the CDR sector, while maintaining the environmental integrity of the ETS. NEP proposes starting with public funding and intermediary-led procurement, followed by gradual integration of certified permanent CDRs without increasing the ETS cap. The paper stresses the need for separate targets for CDR in EU climate law, alignment with the CRCF, and safeguards to ensure only high-integrity, permanent removals are eligible

Archive


  • Carbon Removal Certification Mechanism - Our response

    Negative Emissions Platform has responded to the survey launched by the EC-funded consortium tasked with assessing options for certification of removals. We encourage classification of removal methods based on nature and durability of storage and call for exclusion of fossil based carbon capture and short/medium-term CCU from the mechanism. We believe that the number of removal certificates issued should be adjusted according to the likely permanence of the solution and that the certificates should be equipped with additional descriptions to demonstrate certain co-benefits (i.e catalysing innovation) and adherence to sustainability criteria in line with relevant EU regulations (LULUCF, REDII). Download our full response to learn more.

    15 September 2021

  • A factory smokestack emitting thick white smoke into a clear blue sky.

    Reaction to the draft of the EU ETS Directive

    Following the publication of draft EU ETS directive we reached out to the European Commission to address the plan to include the GHG emissions pertaining to the EU ETS under the regulatory framework for the certification of carbon removals. We clarify that the scientifically accepted definition of carbon removal includes only atmospheric and biogenic sources of CO2/carbon. Conflation of carbon removals and emission reductions/avoidance will hinder creation of a level-playing field for large-scale deployment of negative emission technologies versus fossil-based CCU methods with permanent storage.

    8 July 2021

  • A tall electrical transmission tower and large metallic pipes against a clear blue sky.

    Response to the Trans-European Networks for Energy (TEN-E) proposal

    The Trans-European Networks for Energy (TEN-E) proposal in its current form is not fit to support the achievement of the climate neutrality objective. We shared our feedback on the revised version of the TEN-E Regulation with reference to the exclusion of CO2 storage and CO2 transport modalities other than pipelines from its scope. Despite ongoing efforts by a number of stakeholder groups the proposal from the European Commission does not include these two key elements. As the representatives of an emerging carbon dioxide removal industry we have joined the calls of NGOs and industry and urged the Commission, the European Parliament and Member States representatives to introduce relevant amendments during the upcoming negotiations of the dossier.

    8 March 2021

  • Solar panels and wind turbines on a grassy field at sunrise or sunset, with a truck labeled 'Energy' in the background.

    Input into the consultation on the renewable energy directive

    Negative Emissions Platform responded to the relevant sections of the consultation on Renewable Energy Directive review. We welcome a clear distinction between renewable and recycled fuels and an open discussion about atmospheric vs. fossil CO2. We believe that all types of renewable energy need to be supported, not only renewable electricity. Revised RED II needs to contribute to sector coupling and sector integration and renewable fuels of non biological origin (RFNBO) can play an important part in this. Overall, the target for renewable energy should be more than 14 percent. Fuels produced from hydrogen, generated by renewable electricity, and CO2 taken directly from the atmosphere or from processes using sustainable biomass (to achieve a closed CO2 cycle) will play an important part. The aviation and maritime sector will also benefit from this approach, because value chains and technologies are largely overlapping. The EU is already planning sustainable aviation fuel (SAF) shares from 5% in 2030 and a ramp-up to 20% in 2035, 63% in 2050. According to Dena from 2030 onwards, point sources will not provide enough CO2 to cover the demand to produce renewable fuels - a substantial amount of CO2 needs to come from the atmosphere through direct air capture already in 2030. Therefore, certification of fuels must be supported by a full LCA methodology that accurately measures total GHG reductions, ultimately measuring the net flow of CO2 into the atmosphere from the entire system. The use of CO2 point sources should be limited to industrial emissions in the EU ETS, such as cement industries, and should be limited in volumes and in timeframes, so as not to delay application of CCS technologies that exist today to decarbonise these sectors.

    9 February 2021

  • A forest trail surrounded by tall trees and lush green plants with sunlight streaming through the canopy.

    Regulation on the inclusion of greenhouse gas emissions and removals from land use, land use change and forestry (LULUCF)

    Negative Emissions Platform responded to the public consultation on LULUCF. It is forecasted that the EU removals will need to almost double from their current levels to up to 500 Mt CO2eq./yr by 2050 to be in line with the goal of a climate-neutral EU. However, the European forests, by far the largest carbon sink in the LULUCF sector, are projected to store increasingly less CO2 in the next decade due to ageing and events such as droughts, forest fires and pest outbreaks which are caused or exacerbated by climate change. In addition, the Communication on increasing the EU’s 2030 climate ambition indicates that non-CO2 emissions from the agricultural sector will constitute the largest share of the residual emissions in 2050, as they are difficult to completely eliminate with existing technology and practices.  This assessment calls for a rapid initiative to introduce a separate policy framework encompassing the nature-based, technological and hybrid removals that will be deployed EU-wide to tackle agricultural and all land use-related emissions. This framework should take into account the synergies between the LULUCF sector and other land-related sectors in particular the carbon farming initiative announced in the Farm to Fork Strategy, as well as the certification of carbon removals announced in the Circular Economy Action Plan.  We call for closing off the LULUCF loophole in the ESR Regulation, and for keeping the promotion of natural and technological sinks separate from emission reduction efforts. We support the option of a new policy strand covering emissions from the land sector (agriculture, forestry and other land use) and call for a separate EU-wide target to be delivered by a combination of land-based and technological removals.

    5 February 2021

  • An aerial nighttime view of a container ship docked at a port, illuminated with colorful lights, with cranes and a docked train beside the ship.

    Input into the consultation on the translation of increased EU 2030 targets to upgraded EU ETS

    Negative Emissions Platform responded to the public consultation on how to translate the increased EU 2030 emissions reduction ambition into an upgraded EU ETS. We call for an increased target going beyond of what the potential for cost-efficient reductions would indicate in order to stimulate innovation of current EU ETS sectors. A number of measures should be applied to strengthen the system such as an increase of the linear reduction factor an its one-off reduction, combined with cancellation of allowances held in the Market Stability Reserve and an increase of its feeding rate. In our view the inclusion of new sectors (except maritime) such as building or transport would have negative consequences for the stability of the EU ETS while displacing more effective decarbonisation incentives in the concerned sectors. Finally, we call for an increase of the size and the maximum funding rate of the Innovation Fund - one of key tools to reinforce EU clean energy technology leadership.

    5 February 2021

  • Multiple parked military aircraft on an airstrip during sunset.

    Input into the public consultation on the carbon offsetting and reduction scheme for international aviation (CORSIA)

    Negative Emission Platform responded to the public consultation on the update of rules for aviation considering ways to implement CORSIA - Carbon Offsetting and Reduction Scheme for International Aviation- through the EU ETS Directive. In our view, the Commission should analyse the impact of a 'combined' option whereby the EU ETS price would continue to apply to all intra-EU/EFTA flights and would be added for emissions from flights departing from or arriving in the EU/EFTA up to an operatorsʼ 2020 levels for those flights, with CORSIA covering the emissions above the 2020 levels for flights departing from or arriving in the EU/EFTA. We also advocate for a phase-out of free allocation for aviation sector. The revenues generated by eliminating around 32.3 million tonnes of free allowances per year could be used to finance contracts for difference (CfD) supporting the use of sustainable alternative fuels (SAF) or direct support to negative emissions technologies such as DACCS and BECCS.

    14 January 2021

  • Three European Union flags flying in front of a modern glass building with horizontal blinds.

    Letter to the EU Commission’s Vice-President on sustainable finance taxonomy

    In a follow-up to our input to the public consultation on Sustainable Finance taxonomy we would like to bring our main concerns and recommendations directly to the attention of the Commission’s Vice-President for the Green Deal and relevant Commissioners.  In our view, the Commission should urgently address the issue of exclusion of Direct Air Capture technology from the draft Delegated Regulation establishing technical screening criteria of the EU sustainable finance taxonomy. We urge the Commission to reinstate the section covering Direct Air Capture in line with the recommendation of the final report by the EU Technical Expert Group (TEG) on Sustainable Finance from March 2020. We are also calling for recognition of development of  BECCS and biochar as sustainable activities. 

    23 December 2020

  • Close-up of a white structure with large blue letters and numbers 'H2' and a small yellow warning label that says 'Danger exploit atmosphere'.

    Incentivising the uptake of e-fuels based on renewable hydrogen and air-captured CO2

    In order to address the environmental footprint of aviation in line with the European Green Deal objectives and EU’s climate ambition, the European Commission is developing policy options to promote the production and uptake of sustainable aviation fuels. Negative Emissions Platform has responded to the public consultation and provided additional input focusing on the ways to incentivise the uptake of e-fuels based on renewable hydrogen and air-captured CO2 in the context of the ReFuelEU Aviation policy initiative.

    26 October 2020

  • Close-up of multiple stacked dominoes with black dots on white tiles.

    Comments on Verra’s public consultation on the proposal for scaling voluntary carbon markets and avoiding double counting of carbon credits post-2020

    We have provide comments to the public consultation by Verra on the Proposal for Scaling Voluntary Carbon Markets and Avoiding Double Counting Post-2020 concerning the application of ‘corresponding adjustment’ (CA) by the offset project host country in line with (pending) Article 6 of the Paris Agreement. In the absence of separate targets for carbon removals in national jurisdictions, voluntary carbon markets will remain a key driver for climate action in this area. Therefore, we propose a transitional period when both the corporate actor could claim the credit towards their voluntary commitement, and the host country could count it towards their NDC target. At a target date, after administrative capabilities and certification methods have been built up, the countries should be required to provide CAs and phase-out double-claiming of credits, so as not to hinder the long-term climate mitigation ambition of voluntary markets.

    17 October 2020

  • Three wind turbines on a body of water under a cloudy sky.

    Input into the EU Commission’s consultation on the renewable energy directive, REDII

    We have responded to the Commission’s consultation on the review of Renewable Energy Directive (REDII). We welcome the initiative to streamline the provisions of REDII with recent initiatives to increase the 2030 target, promote hydrogen and sector integration. We call for an increase of a sub-target in transport sector and introduction of a quota for e-fuels together with an obligation on producers to source an increasing share of CO2 from the atmosphere to reduce carbon intensity. We call for a development of a robust terminology for all renewable and low-carbon fuels differentiating between various origins of CO2, and introduction of clear labels/ certification schemes to help consumers make informed choices.

    21 September 2020

  • Three European Union flags flying in front of a modern glass building with horizontal louvers.

    Response to the European Parliament’s environment committee report on the EU climate law

    Ahead of the vote on the report on Climate Law in the Environment Committee we have shared our input with the Committee members.

    We welcome the Rapporteur’s amendments on the EU carbon budget, sectoral roadmaps and negative emissions objective post-2050. We also fully support the inclusion of a concept of a separate target for removals by some Members of the Committee, which we believe requires further scoping in the final text. We bring the MEPs attention to our considerations concerning the Commission's scenarios, targets setting and structure, and the choice of legislative procedure. 

    10 September 2020

  • A factory chimney emitting a large plume of white smoke into the blue sky with scattered clouds.

    Response to the public consultation on the EU 2030 target plan 

    Negative Emissions Platform has submitted an additional response to the public consultation concerning the 2030 Target Plan by the European Commission. We support the highest proposed target of 55%, while fully welcoming the European Parliament’s proposal to increase the ambition to up to 65%. We highlight the need to disaggregate the 2030 target into separate target for emissions reduction and carbon removals, both nature based and technological. This would enable a clear assessment of the practicality of each element including technological, financial and regulatory gaps to be addressed. We welcome the idea to establish and EU-wide methodology to certify removals, and call for consideration of a carbon take-back obligation scheme as a framework to scale up the market for removal credits.

    24 June 2020