Published on
February 5, 2026
Victoria Harvey
Head of CDR
14
min read

Digging into the EU CRCF CDR Methodologies

The first chapters of the EU’s Permanent Carbon Removal rulebook are finally here – and it’s a page-turner

A significant milestone for carbon removals in Europe just landed. The European Commission has adopted the first set of certification methodologies under the EU Carbon Removals and Carbon Farming (CRCF) regulation, covering Direct Air Capture and Carbon Storage (DACCS), Biogenic Emissions Capture with Carbon Storage (BioCCS), and Biochar.

This is one of those announcements that sounds technical – and is – but also deeply consequential. For anyone who does due diligence for a living, the publication of an 86-page methodology document on carbon dioxide removal (CDR) by EU policymakers feels a bit like Christmas morning. An excellent present.

It's the first time we've been able to compare what the EU is saying with the methodologies we know so well from the VCM. 

So rather than just celebrating the update, the ClimeFi team went straight to the text. Here’s what stood out.

Why this is more than just another EU CRCF announcement

First of all, this is real policy. The methodologies are explicit, prescriptive, and, crucially, agreed upon. That alone is a big step forward in a market often defined by interpretive ambiguity.

Second, the framework is cross-pathway but internally consistent. For now, only three pathways qualify as permanent CDRs in the EU – Biochar, DACCS, and BioCCS. While many suppliers are pushing for broader eligibility, there is a positive signal in how these first three are treated. 

For example, activity periods and application limits differ by removal pathway, but the core logic does not: accounting rules, durability definitions, and monitoring expectations are aligned. That fungibility matters. Without it, Europe would be laying the groundwork for three siloed systems, not a CDR market that can scale with credibility.

Lastly, it gives suppliers and CDR market makers something concrete to work towards. Developers and Standards Bodies can now see where their current methodologies exceed or fall short of what EU integration would require. Even for projects outside Europe, this is a directional signal.

The smallprint that actually matters

These are just some of the highlights we found most interesting. For those inclined, the full methodology text is where the real detail lives.

Topic What the document says Why it matters
Who can operate projects
Only capture facilities can operate DACCS and BioCCS activities. Biochar activities must be run by a single legal entity across all plants using the same technology. This limits fragmentation and arbitrage. The EU is clearly signalling that accountability sits with the entity controlling the physical process – not a loosely affiliated project special purpose vehicle (SPV).
Location, location, location
All activities must be located in the Union: capture facilities for DACCS/BioCCS, and both production and storage for Biochar. This is about policy control. If the EU is going to stand behind these removals, it wants jurisdictional oversight across the full value chain.
Additionality by design
All three pathways assume a standardised baseline of 0 tCO₂e – making activities additional by default under CRCF rules. This simplifies eligibility, but shifts the burden to design assumptions. At ClimeFi, we continue to interrogate project financials and counterfactual analysis – particularly for biomass pathways. This tension will only grow as Biochar and BioCCS scale.
Carbon accounting that actually accounts
Full cradle-to-grave life cycle assessments (LCAs) are required, including capital emissions, energy use, fugitives, and venting. Detailed mass-balance rules apply for shared CO₂ transport and storage infrastructure. Shared infrastructure is inevitable at scale. Without clear allocation rules, accounting integrity would unravel fast. This addresses a major loophole early.
Durability is nailed down
DACCS and BECCS must use geological storage permitted under the EU CCS Directive, inheriting its leakage-liability regime. For Biochar, only the stable fraction storing carbon for “at least several centuries” qualifies, with limited post-application monitoring. The EU is drawing a hard line on permanence. Biochar is explicitly positioned as century-level durability – not geological, but clearly permanent in regulatory terms.
Deployment limits and biomass safeguards
Biomass must follow the cascading use principle and RED II definitions, with strict limits when Biochar is the primary product or when BioCCS plants expand capacity. Biomass overuse is a form of leakage. These constraints are an attempt to scale removals without shifting emissions elsewhere.
Timelines and audits
Crediting periods are capped (15 years for DACCS/BioCCS and 5 years for Biochar), with annual audit periods across all pathways. Monitoring timelines are pathway-specific: for DACCS and BioCCS, monitoring continues until storage responsibility is transferred back to the Union; for Biochar, it runs until the material is demonstrably applied at its final storage location. These pathways are fundamentally different, and the timelines are designed to reflect that variability. Regular checkpoints reduce long-term lock-in to outdated assumptions and force methodologies to keep pace with operational reality.
Standards Bodies: the missing piece
Certification is to be carried out by recognised “certification schemes” under Regulation 2024/3012. Though no Standards Body has yet been approved. This is the next bottleneck, and arguably the most important one. Without recognised schemes, the framework exists on paper, but not yet in practice.

Reviewing the document through a VCM methodologies lens, there are clear points of alignment with existing approaches from Puro.earth, Isometric, Gold Standard, and others. Some tweaks will almost certainly be required – much like the refinements needed to achieve CCP approval by the ICVCM – but the foundations largely rhyme. Taken together, this suggests a credible path toward convergence rather than a wholesale rethink.

So, what comes next?

These methodologies tell us which projects, and indirectly which Standards Bodies and methodologies, are plausibly on a path toward EU integration. They are also a clear forward step toward embedding CDR into EU policy tools, potentially even the EU Emissions Trading System.

Are we there yet? Absolutely not. Registries, market interfaces, and governance questions remain wide open. But this is a credible, serious path forward – and that alone is a positive signal for CDR in Europe.

The hard part starts now: translating methodology into market reality.

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