The Negative Emissions Platform calls for the integration of permanent carbon dioxide removals into the EU Emissions Trading System 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

This paper outlines four key measures to ensure the EU ETS can create the demand, funding and investment certainty needed to scale permanent carbon removal in Europe, while supporting the continent’s industrial transition.

Making Carbon Removal Work for Europe: A Scale-Up Strategy for 2026–2030 sets out how the EU can scale permanent carbon removals from today’s limited capacity to at least 5 million tonnes annually by 2030. The paper argues that Europe needs urgent action to create early demand, mobilise deployment funding, strengthen research and innovation, accelerate CRCF methodology development, and build the practical foundations for future integration of removals into compliance markets such as the EU ETS. It frames carbon removal as essential for industrial competitiveness, climate credibility, and Europe’s clean-tech leadership.

EU Climate Law Position Paper (July 2025) sets out the Negative Emissions Platform’s recommendations for strengthening the EU Climate Law revision so Europe can reach climate neutrality by 2050 while enabling a competitive permanent carbon dioxide removal (CDR) industry to invest and scale. It calls for a 90% net emissions reduction target by 2040, separate targets for gross emissions reductions, permanent CDR and LULUCF, and a holistic package of support measures beyond ETS integration. The paper also urges robust safeguards for any use of international credits and a portfolio approach to permanent CDR methods, aligned with the CRCF, to avoid narrowing support to only a few technologies and to ensure policy coherence across EU instruments.

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.

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Industrial Carbon Management Strategy Position Paper

Feedback on the 2040 Climate Targets

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.

A coalition of carbon market organisations, including NEP, welcomes the EU's decision to allow up to 5% international carbon credits toward the 2040 climate target — and calls on the Commission to ensure high-integrity carbon removal credits play an explicit role in that framework from the outset.

The paper sets out two core recommendations: that CDR credits be prioritised within the international credit mix from the start, with their share growing over time in line with science-based pathways; and that any pilot phase, beginning around 2031, explicitly include carbon removal credits to allow supply to scale and verification infrastructure to mature. The paper also makes the case for Europe's competitive advantage as the only jurisdiction with an operational CDR certification framework (the CRCF), the EU is well-placed to anchor global quality standards while building an industry projected to reach €940 billion annually by 2050.

NEP welcomes the draft Delegated Act as a milestone in implementing the Carbon Removal Certification Framework and calls for its rapid adoption. In its response, NEP stresses the need for:

• Longer activity periods (up to 15 years) to align with financing structures and ensure project viability.

• Broader recognition of operators, allowing both capture and storage actors to register activities and trigger issuance of units.

• Greater flexibility for DACCS, including annual temporal matching for first-mover projects, recognition of Guarantees of Origin for renewable electricity, and inclusivity for different sorbent processes.

• Consistency with RED for BioCCS, particularly on sustainability rules, cascade principle application, reporting requirements, and treatment of new or mothballed facilities.

• Practical rules for biochar (BCR), ensuring permanence is defined by stable carbon fractions, clarifying unit issuance for batches, and confirming soil application limits.

Overall, NEP supports a clear, consistent, and investment-friendly framework to enable the growth of permanent carbon removals in Europe

Durable carbon dioxide removal (CDR) contributes to climate and economic goals. With removal capacity urgently needing to scale up—in terms of technology development and the creation of lead markets—the window for timely, effective investment is closing. We believe that the European Investment Bank (EIB) Group is uniquely placed to provide the financial and technical assistance required to facilitate both research and innovation and deployment-level investments aligned with the scale of durable CDR needed in the EU.

The Negative Emissions Platform calls for the European Innovation Council (EIC) to launch dedicated funding calls for carbon dioxide removal (CDR) technologies. These technologies—crucial for meeting the EU’s 2040 and 2050 climate targets—require urgent research, development, and innovation (RD&I) support to scale up and ensure a reliable pipeline of high-integrity carbon removals. Despite growing investor interest, early-stage CDR companies face a significant funding gap, compounded by policy uncertainty and high technical risk. The EIC, with its deep-tech mandate and blended finance instruments, is well-positioned to fill this gap and accelerate breakthrough innovations, enabling the EU to lead in climate tech while generating jobs and industrial competitiveness.

The upcoming €100B Industrial Decarbonisation Bank (IDB) is a strategic opportunity to scale permanent carbon removal (CDR) and boost Europe’s industrial competitiveness.

In our latest paper, NEP calls on the European Commission to:

• Allocate 5% of IDB funds to CRCF-certified permanent CDR

• Use fit-for-purpose funding instruments like CfDs, offtakes, or fixed premiums to scale up carbon removals

• Provide hard-to-abate industries with preferential access to IDB-supported permanent CDR

 This is how the IDB can bridge innovation to market—scaling clean industry, cutting residual emissions, and delivering on the Clean Industrial Deal.

European startups are leading in developing permanent carbon dioxide removal (CDR) technologies but are nearing the “valley of death”. The EU is home to a vibrant scene of startups and scaleups delivering negative emissions, but they currently face significant barriers, particularly in financing.

The EU has an opportunity to safeguard critical industries and grow the nextgeneration of clean-tech startups by 2030 which requires urgent action. The Start-up and Scale-up Strategy presents an important opportunity to accelerate the next generation of clean technologies and achieve Europe’s climate and competitiveness goals.

NEP welcomes the European Commission’s initiative to develop a comprehensive ocean policy in the European Oceans Pact and appreciates the opportunity to provide input.

NEP calls on the European Commission to integrate marine carbon dioxide removal (CDR) into the EU’s ocean policy framework as an important contributor to the EU’s climate goals and to support climate mitigation efforts.

Open letter · 5 February 2025

44 organisations have signed a joint letter calling on the European Commission to ensure the Clean Industrial Deal supports investment, innovation, and deployment in carbon dioxide removal (CDR), a cornerstone of Europe’s path to climate neutrality.

The Net-Zero Industry Act (NZIA) creates a regulatory framework to boost the competitiveness of EU industry and technologies crucial for decarbonisation.

NEP advocated for the inclusion of carbon removals in the NZIA.

On 19 February 2024, the European Commission reached a provisional political agreement on the Carbon Removals and Carbon Farming Regulation (CRCF), a voluntary regulatory framework for the certification of permanent carbon removals, carbon farming and carbon storage in products. The framework has been developed to facilitate and speed up the deployment of permanent carbon removal, carbon farming and carbon storage in products activities, as a complement to sustained emission reductions, fight greenwashing and harmonise carbon removal market conditions.

The Negative Emissions Platform’s response to the EU Legislative Initiative on CO₂ Transportation Infrastructure and Markets (September 2025) outlines how Europe can build CO₂ transport and storage systems that are fit for both CCS and permanent carbon dioxide removal (CDR) at industrial scale. It calls for explicit inclusion of permanent CDR in infrastructure planning and market access rules, proposes launching two IPCEIs (one for CO₂ transport & storage and one for permanent CDR scale-up), and recommends an EU strategy for permanent CDR to align demand- and supply-side measures across EU and national policies—ensuring removals are not crowded out and that infrastructure becomes a backbone for net zero and net negative emissions.

Negative Emissions Platform supports the Commission’s initiative to design a Carbon Removal Certification Mechanism (CRC-M). We encourages the Commission to provide a framework that is robust, credible, implementable and establishes comprehensive and robust rules for each type of carbon removal, on top of a common EU minimum standard. A timely development of methodologies to enable policy support is critical. We call on the Commission to implement methodologies as soon as possible, i.e. when robust assessments are achieved. Difficulties in the assessment of certain CDR methods should not undermine progress towards implementation of approaches which are ready to be incentivized to scale in the short-term.

The UK is leading the way with assessing how GGRs can be integrated into the UK Emissions Trading Scheme (ETS). NEP expects that the UK’s decision on how to integrate GGRs in the ETS will have significant climate impacts as other countries and regions (like the EU) look for direction on adopting similar measures. 

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

This is a consultation from the Federal Ministry for Finance and the Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology on Austria’s upcoming Carbon Management Strategy. This is a critical opportunity to promote the adoption of carbon removal technologies in Austria, positioning the country to achieve its climate objectives in the upcoming decades.

The Negative Emissions Platform (NEP) applauds the publication of the draft CCUS Strategy developed jointly by the AGH University of Science and Technology and the WiseEuropa Foundation as part of the CCUS.pl project.National level action on carbon management will be critical in driving these climate critical technologies forward, and we are encouraged to see frontrunners in Poland already taking proactive measures in this domain. NEP is encouraged to see some carbon dioxide removal (CDR) technologies included in the draft CCUS Strategy. While this is undoubtedly a positive starting point, NEP strongly believes that the draft strategy could elevate Poland’s ambition and comprehensiveness in this regard. Effective CDR initiatives are essential for achieving long-term climate goals, and Poland is well-positioned to lead in this area.

SBTi’s updated draft Corporate Net-Zero Standard (CNZS 2.0) introduces useful concepts, but as written it risks falling short on what permanent carbon removals need: a clear, early, and predictable demand signal. NEP is particularly concerned about proposed co-claiming restrictions, non–science-aligned durability guidance (missing a like-for-like approach), and a timeline that makes action on removals mandatory too late—all of which could weaken net-zero credibility and slow scale-up.

With thousands of companies committing to science-based targets, the Science-Based Targets initiative (SBTi) plays a central role in shaping credible corporate climate strategies. Its upcoming revision of the Corporate Net-Zero Standard (CNZS 2.0) could significantly accelerate the growth of the permanent carbon removal (CDR) sector.

The update acknowledges that most companies will face unavoidable residual emissions on the path to net-zero — and will need to address these through carbon removals. Of the proposed approaches, only one creates a strong demand signal: interim targets for CDR purchases starting in 2030. To be effective, these must be annual (not cumulative), apply beyond Scope 1, and reflect the need for permanence when neutralising fossil-based emissions.

The Negative Emissions Platform welcomes the Article 6.4 Supervisory Body’s structured public consultation on removal activities. As the Supervisory Body gathers input, NEP would like to draw attention to some important elements it should consider regarding monitoring and reporting and addressing reversals.

The Negative Emissions Platform, alongside 7 prominent members in the CDR ecosystem, call on the UNFCCC to address the unbalanced representation of engineered carbon removal benefits, discrepancies in CO2 quantification, and misrepresentation of long-term storage benefits and its role.

Negative Emissions Platform has responded to the consultation by Verra concerning a “labeling” of Verified Carbon Units (VCUs/carbon credits). In its proposal, Verra is following much of the work and recommendations of the Taskforce Scaling Voluntary Carbon Markets (TSVCM) as regards the pending Core Carbon Principles that are likely issued very soon by the newly established Integrity Council. We encourage Verra to clearly differentiate carbon removals and reduction credits by establishing a new credit unit for carbon removal projects. We also encourage Verra to focus on capture method and storage timeframes to categorize removals.