The CRCF's biochar methodology is here — what it actually changes

For two years, every conversation about biochar and European regulation ended the same way: the framework exists, the methodology is coming. It has now come. On 3 February 2026 the Commission adopted Delegated Regulation (EU) 2026/285, establishing the certification methodologies for permanent carbon removals — direct air capture, BioCCS, and biochar. It was published in the Official Journal on 17 April and entered into force on 7 May 2026 [1].

This is the document that decides whether a tonne of biochar carbon is a certified removal in European law. It rewards operators who instrumented their process from the beginning and punishes those who planned to assemble the evidence afterwards. Below is what it actually says — and what a buyer should now be asking any supplier who mentions the CRCF.

The gate: H/C _org ≤ 0.7, measured per batch

Start with the provision that admits no negotiation. The methodology requires that the H/C_org ratio of each batch of biochar be measured, and states that no carbon removal units may be issued for any batch measured above a ratio of 0.7 [1]. Not averaged across a month. Not inferred from reactor temperature. Measured, per batch, in a laboratory.

The hydrogen-to-organic-carbon ratio is the standard proxy for how thoroughly the plant carbon has been condensed into the fused aromatic structures that resist decomposition — the chemistry we cover in why biochar lasts. A high ratio means volatiles remain and the carbon is not durable. The EU has simply made the chemistry a legal condition, and drawn the line where the EBC already drew it.

Two ways to prove permanence — and you may not mix them

The methodology allows exactly two routes to a permanence fraction, and a batch must use one or the other [1].

Two things are worth noticing. First, the reflectance route is a genuine physical measurement of the carbon structure, which is the method we built our chain of proof around — it does not ask you to trust a curve. Second, the horizon written into the decay route is 200 years. That is the number European law now attaches to permanent biochar storage. It is also, not coincidentally, the durability class Puro.earth moved to in 2025. When we say “several centuries” on this site rather than “a thousand years”, this is why.

Where the carbon may go — and where it may not

The methodology restricts eligible storage, and the restriction is sharper than most suppliers have absorbed. For soils: agricultural, forest and greenhouse soils, urban soils and growing media, landscaping. For materials, the text is explicit that only activities incorporating biochar into cement, concrete or asphalt are eligible for certification [1].

That single sentence settles an argument the industry has been having with itself. Activated carbon for filtration is an attractive product business — and it is not a certified removal under the CRCF, because spent filter media is typically reactivated or incinerated and the carbon is destroyed. Metallurgical bio-carbon is the same story with a different ending. We separate these on our own value ladder for exactly this reason: an application where the carbon does not survive is a product, not a credit, and conflating the two is how a supplier ends up selling a tonne it cannot defend.

There is also a quiet operational constraint that anyone modelling soil application should note: total application to agricultural and forest soils is capped at 50 tonnes per hectare cumulatively over time — including any biochar applied before certification, which means you need geographically specific records of ground you may not have surveyed [1].

The part that is really about data

Strip away the chemistry and the CRCF biochar methodology is, in practice, a data mandate. Operators must test every production batch in a laboratory, reporting organic carbon, the H/C_org ratio, energy density and contaminant compliance. All batches must be sampled, under a protocol written into a monitoring plan and reviewed at audit. The monitoring plan must list the laboratories used, describe the data flow and IT systems, and state the accuracy and monitoring frequency for each parameter [1].

And then there is the provision that tells you what the drafters actually expect: one-litre retention samples, taken every day biochar is produced, stored for at least two years and available on request to the certification body, the scheme or the national authority [1]. That is not a reporting requirement. That is a physical audit trail — the regulatory equivalent of saying we may come and check.

A producer running on spreadsheets and monthly composite samples cannot retrofit this. The evidence either accumulated at the moment of production or it did not exist, and the certification body will be able to tell the difference. This is the whole argument for building the measurement layer before the first tonne is sold, and it is why our infrastructure treats a batch as an evidence record rather than a production log.

What is still missing

Two honest caveats, because the enthusiasm around this regulation is running ahead of the facts.

No CRCF units exist yet. Entry into force starts the machinery: the Commission must recognise certification schemes, certification bodies must be accredited, and operators must be audited. The Union registry itself is not due until 2028; until then recognised schemes maintain their own interoperable registries [2]. First units are a late-2026 possibility and a 2027 probability. Nobody — including us — holds a CRCF-certified tonne today, and any supplier implying otherwise is worth a second look.

There is no long-term liability mechanism. Unlike geological storage, biochar carries no buffer pool and no post-application monitoring: the methodology reasons that reversal risk is captured up front in the permanence fraction, and that reversals cannot practically be observed once the material is in the ground [1]. That is a defensible position and it has been criticised by credible people [3]. Buyers should understand it, because it means the integrity of a CRCF biochar tonne rests almost entirely on the quality of the measurement at production — which is precisely the thing a buyer cannot see, and precisely the thing we built the company around making visible.

This article is an explanation, not legal advice. Provisions summarised here were read from the Official Journal text cited above; verify against the primary source before relying on it for procurement or compliance decisions. Terms are defined in the glossary.