For most of the past decade, "is this a real carbon removal?" was a question every buyer had to answer privately, with their own diligence, against a shifting set of voluntary standards. In November 2024 the European Union answered it in law. The Carbon Removals and Carbon Farming Regulation — Regulation (EU) 2024/3012, usually shortened to CRCF — establishes the first Union-wide certification framework for carbon removals [1].
It is worth being precise about what that does and does not mean, because both the enthusiasm and the scepticism around it tend to overshoot. The CRCF is a voluntary certification framework: it defines what a credible removal is, who may verify it, and how it is recorded. It does not create a compliance market, and it does not by itself let a company subtract a purchased removal from its emissions target. What it does is end the argument about definitions — and in a market whose core problem is trust, that is the more valuable thing.
The four tests: QU.A.L.ITY
The regulation's substance sits in four criteria, which the Commission packages under the acronym QU.A.L.ITY. Every certified unit has to satisfy all four [1].
Fig. 1 — The QU.A.L.ITY criteria — all four must hold
Read them as a checklist and they look bureaucratic. Read them as failure modes and they are exactly the four ways a carbon claim goes wrong: the tonne was mis-measured; it would have happened anyway; it did not stay put; or it was bought at the cost of a forest, a water table or a community. The CRCF is, in effect, the market's known failure modes written into law.
What the regulation covers — and where biochar sits
The CRCF does not treat all carbon the same. It recognises distinct activity types with different storage expectations, which is the honest way to handle a subject where a wooden beam and a geological reservoir are not the same promise [1].
Fig. 2 — Activity types under the CRCF
| Activity type | Examples | Storage expectation |
|---|---|---|
| Permanent carbon removal | BioCCS, DACCS | Several centuries |
| Carbon storage in products | Long-lasting wood construction products | At least 35 years, monitored |
| Carbon farming | Soil carbon, agroforestry, restoration | Temporary; monitored, reversible |
| Soil emission reduction | Reduced N₂O and soil-carbon losses | Reduction, not removal |
Biochar is the interesting case, and its status changed decisively in 2026. The regulation set the frame; the operational detail — the certification methodology each activity must follow — arrived separately, by delegated act. For biochar that act now exists: Commission Delegated Regulation (EU) 2026/285, adopted 3 February 2026, published in the Official Journal on 17 April and in force since 7 May 2026. It establishes the certification methodologies for permanent carbon removals — DACCS, BioCCS and biochar carbon removal [5]. We have written a dedicated piece on what it requires: the CRCF's biochar methodology, in detail.
The short version: biochar qualifies as a permanent removal, storage is restricted to soils and to cement, concrete or asphalt, and no unit may be issued for any batch whose molar H/Corgratio exceeds 0.7. Until schemes are recognised and the first units issue — realistically late 2026 at the earliest — biochar removals in Europe continue to be certified under established voluntary standards: the EBC and Carbon Standards International's C-Sink route, and Puro.earth [3][4]. That is the practical bridge, and it is the one we build to.
What happens next, and when
The regulation entered into force in December 2024, and the first methodologies in May 2026. What remains is machinery: certification schemes recognised by the Commission, third-party certification bodies accredited to audit against them, and an EU registry to record certified units and prevent double-counting — the latter due within four years of the regulation, so by 2028 [1]. The direction is settled; the exact calendar of each step is set by the Commission and has moved before, so treat the sequence below as the order of events rather than a set of dates to plan a contract around.
Fig. 3 — Sequence of implementation (order of events; timing set by the Commission)
What a supplier should do about it now
The temptation is to wait for the methodologies and then comply. That is the wrong move, for a simple reason: most CRCF evidence is data you either collected at the time or you did not. Additionality arguments, batch-level mass and carbon records, lifecycle emissions, storage monitoring, chain of custody — none of it can be reconstructed convincingly two years after the fact. A supplier who instrumented their operation from the first batch can certify against whatever the methodology turns out to require. A supplier who kept spreadsheets will be re-doing their history, and auditors will notice.
That is why our digital infrastructure exists, and why we treat every batch as an evidence record rather than a production log. The four QU.A.L.ITY criteria map cleanly onto data we are building to hold anyway: quantification onto our sensor and laboratory chain, long-term storage onto direct measurement of carbon structure, sustainability onto residue sourcing and the safety panel, additionality onto the project record. Building to the strictest reading of the framework costs discipline now; it is far cheaper than discovering, at audit, that the tonnes you sold cannot be proved.
Common questions
Is the CRCF mandatory? Do I have to buy CRCF-certified removals?
No. The CRCF establishes a voluntary Union certification framework — it does not oblige anyone to buy removals, and it does not by itself let removals count against a company's emissions target. Its function is to define what a credible removal is in EU law, so that quality stops being a matter of each buyer's private judgement.
Does the CRCF replace Puro.earth, the EBC or C-Sink?
Not directly. Voluntary standards keep operating, and they can apply to be recognised as certification schemes under the CRCF once methodologies are adopted. The realistic outcome for suppliers is convergence: build to the strictest reading of both, so that a removal certified today under a voluntary standard can carry into the EU framework rather than be redone.
What does the CRCF change for a buyer, in practice?
It gives you a legal reference point. Instead of arguing about whether a supplier's permanence claim is credible, you can ask whether their quantification, additionality, storage duration and sustainability evidence satisfies the QU.A.L.ITY criteria — and eventually, whether their units appear in an EU registry. It raises the floor and makes weak claims harder to sell.
References
- Regulation (EU) 2024/3012 establishing a Union certification framework for permanent carbon removals, carbon farming and carbon storage in products
- European Commission — Carbon Removals and Carbon Farming (CRCF): implementation and expert group
- European Biochar Certificate (EBC) — Guidelines for a Sustainable Production of Biochar
- Carbon Standards International — Global C-Sink / C-Sink Biochar standard
- Puro.earth — Biochar Methodology (CORC issuance)
- Commission Delegated Regulation (EU) 2026/285 of 3 February 2026 — certification methodologies for permanent carbon removal activities (OJ L, 2026/285, 17.4.2026)
This article is an explanation, not legal advice. Updated July 2026 to reflect Delegated Regulation (EU) 2026/285; verify current status against the primary sources above before relying on it for procurement or compliance decisions. Terms are defined in the glossary.
