2 December 2022
Updates

While European forest owners would have a key role in the possible implementation, their first analysis has identified some important considerations to be addressed in the future discussions to set the details of this Regulation. Based on evidence and practical knowledge from the field we offer the following main messages to the EU institutions in the future work.

  1. Foster voluntary and market-based solutions and build on existing schemes. CEPF welcomes the proposed approach that the EU carbon removal certification would be based on voluntary, market-based measures. This means that there is no need for the EU to establish a new market platform or a new standard since the quality of already existing schemes are getting better all the time. However, we are open to EU defining minimum rules for certification in order to increase transparency.  Some concerns arise due to the fact that detailed rules are not defined yet and are left for future delegated or implementing acts that could hamper needed flexibility for forest-based solutions.
  2. Build transparent rules to monitor, report and verify carbon removals. To build trust to any carbon removal system, it needs to be based on robust systems to monitor, report and verify carbon removals. This means that the cross-compliance with LULUCF- bookkeeping should be robust. Monitoring, reporting and verifying for carbon credits should be created with as little bureaucratic burden as possible.
  3. Carbon removal certification needs to have a holistic approach and not only focus on additionality. European forest owners have some doubts that the proposed EU carbon removal certification focuses too much on the additionality. Regarding this issue, the different points of departure for different types of carbon removals should be well defined to prevent setting unbearable burden on forests owners. The EU needs to also consider that the additionality and permanence in forest management are complex concepts, since the carbon removals fluctuate depending on different practises, lifecycle stages and natural disturbances. In addition, the certification should not be based only on certain management practices but take into account all relevant practices resulting in carbon removals.  Overall, additionality should be based on a legally and practically possible baseline which allows enough flexibility among Member States and different forest management practices.
  4. More efforts are needed to provide better financial incentives for carbon storage in wood products and sustainable forest management. In addition to carbon sinks in forests, the Commission should ensure that all relevant bio-based product categories are included in a robust and coherent framework of carbon removals and develop a methodology to account for the positive substitution effects of bio-based products. The new Regulation should also consider sustainable forest management as a nature-based solution that has already been delivering the long-term contribution to climate change mitigation by increasing the carbon uptake and growth in forests.
  5. The carbon markets need to be visible and profitable for forest owners. The carbon markets should encourage in long-term forest management where forest owners have possibility to gain credits from their climate sequestration efforts. Therefore, all voluntary carbon market measures should be registered and their contribution to climate efforts well noted.  To do that, the EU should establish bookkeeping rules for EU-based nature-based solutions, including projects privately funded and voluntarily established. The market needs to be a clear possibility to diversify sources of income and not an obligatory target-based initiative.
  6. Interlinkages to other policy files should be minimised. The carbon removal certification development should focus on its main objectives. European forest owners have concerns that putting in place additional requirements , e.g. objectives from Taxonomy and Nature Restoration Law, would bring too much complexity and may hamper the climate efforts needed. Therefore, links to other policy files could be considered at a later stage when having more information about the actual implementation of carbon removal certification and more information about the final provisions of these other files.

CEPF is looking forward to working together with the Commission in the expert group developing the future legislative acts.