Response to the public consultation on the draft rules for verifying carbon removals under the CRCF

On 1 July 2025, the Zero Emissions Platform (ZEP) submitted its response to the EU public consultation on the draft Implementing Regulation laying down rules on certification schemes, certification bodies, and audits under the EU Carbon Removals and Carbon Farming Certification (CRCF) Regulation. ZEP supports the European Commission’s efforts to ensure robust, transparent, and harmonised certification of carbon removals and provides key recommendations.

Key recommendations include:

• Stronger governance rules to ensure balanced stakeholder representation and prevent dominant positions. This includes clearer safeguards against conflicts of interest (e.g.,  mandatory declarations, independent review panels, and procedures for recusal) and additional rules for decision-making quorums.

• Centralised EU-wide registry of disqualified and non-compliant operators to prevent “scheme hopping”, alongside a mandatory cross-scheme information exchange.

• Outcome-based metrics in the certification schemes’ annual reports, such as the volumes and characteristics of certified removals. This would improve transparency, facilitate cross-scheme comparisons, foster continuous improvement in certification quality, inform academic research, and support evidence-based policymaking.

• Higher required assurance levels of certification and re-certification audits, increasing from “reasonable” to “high” to ensure that claims are accurate, consistent, and verifiable over time. 

• Robust ex-ante and ex-post mechanisms to address the risk of reversals, including pro-rata attribution methodologies and compensation measures such as “buffer pools”.

• Stronger supervision of certification bodies by closing the loopholes left in the draft text, allowing them to: (i) select Member States with the most lenient oversight frameworks and (ii) conduct their supervision of their operations.

• Guidance and clarification regarding the interoperability of independent certification registries ahead of the Union registry’s launch in 2028, and the recognition of existing certification schemes.

• Robust system-level oversight, anchored in an independent authority tasked with continuously monitoring and aggregating data from all certification schemes, analysing trends, identifying anomalies, and detecting potential failures or abuses in the system to ensure its long-term integrity. 

ZEP’s full feedback is also available on the European Commission’s public consultation portal.