The topic of the workshop was the proposal for the Union certification framework for carbon removals, which was published by the European Commission on 30 November 2022.

1. REPORT
ClieNFarms informal policy workshop:
European Union certification framework
for carbon removals
24 January 2023, Brussels
Authors: Lisa Sinnhuber (IFOAM Organics Europe), Bram Moeskops (IFOAM Organics Europe)
Contributor: Daniel Zimmer (Climate-KIC)
ClieNFarms has received funding from the European Union’s Horizon 2020 research and innovation
programme under grant agreement No 101036822. This communication only reflects the author’s
view. The Research Executive Agency is not responsible for any use that may be made of the
information provided.

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Table of Contents
Introduction ........................................................................................................................................3
Objectives ...........................................................................................................................................3
Participants .........................................................................................................................................3
Presentations and informal discussion...............................................................................................3
Presentation of ClieNFarms ............................................................................................................3
Presentation of the proposal for a Union certification framework for carbon removals ..............4
Discussion on the proposal for a Union certification framework for carbon removals .................4
Conclusions .........................................................................................................................................7
Annex ..................................................................................................................................................9
Agenda ............................................................................................................................................9
Presentation: Feedback from ClieNFarms on the proposal for a Union certification framework for
carbon removals .............................................................................................................................9

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Introduction
On 24 January 2023, the Horizon 2020 project ClieNFarms organised an informal policy workshop to
discuss the proposal for a Union certification framework for carbon removals (“proposal” or
“framework” in the further text) in a group of invited policy makers and stakeholders. This proposal
was published by the European Commission on 30 November 2022 and aims to improve the EU’s
capacity to quantify, monitor and verify carbon removals in a reliable and harmonised way across the
EU and to establish a framework for carbon certificates. Carbon farming is included in the framework
(together with permanent storage and carbon storage in products) and several challenges in this
regard must be addressed.
ClieNFarms tests solutions for climate-neutral farms and attaches great importance to ensuring strong
connections between the project and EU policies. Therefore, it organises regular informal exchanges
between the project, relevant policy makers and stakeholders.
Objectives
The inclusion of carbon farming in the framework raises several issues: how to deal with the non-
permanence of carbon stocks in soils, how to put in place reliable sustainability criteria, how to reward
farmers fairly for carbon removal activities or how recognise the efforts of frontrunners who are
already improving carbon stocks. In this informal policy workshop, a group of invited policy makers
and stakeholders discussed the proposal and the controversies it triggers. The focus was on the
QU.A.L.ITY criteria (QUantification, Additionality, Long-term storage and sustainabil-ITY) proposed by
the framework.
The workshop was held under the Chatham House Rule, i.e. “participants [were] free to use the
information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other
participant, may be revealed.”1
. Therefore, a free discussion among participants was encouraged.
Participants
27 participants attended workshop. They were representatives of the European Commission (DG
CLIMA, DG AGRI and DG ENV), of Permanent Representations of EU Member States, advisors of the
political groups of the European Parliament, representatives of European umbrella organisations
working in the area of agriculture and environment as well as ClieNFarms project partners.
Presentations and informal discussion
Presentation of ClieNFarms
ClieNFarms aims to co-develop and upscale systemic locally relevant solutions (organisational,
financial, technical) to reach climate-neutral and climate-resilient sustainable farms across Europe. It
is a 4-year project with 33 partners in 14 countries that started in January 2022. ClieNFarms is based
on the creation of I3Ss - Innovative Systemic Solution Spaces. An I3S consists of different components
and actors who will test and disseminate tailored solutions to achieve climate-neutral farms within
supply chains and local territories. ClieNFarms follows a holistic approach to climate-neutral and
climate-resilient farming. The I3S network is structured around key production parameters: livestock
(e.g. feed management), crops (e.g. soil management), carbon sequestration, low carbon energy
production and consumption, integral environmental sustainability as well as other approaches (e.g.
circular organisation, governance).
1
https://www.chathamhouse.org/about-us/chatham-house-rule

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The framework for the certification of carbon removals is important for ClieNFarms as the project is
developing a carbon allowance platform. ClieNFarms is ready to support the expert group of the
European Commission in developing the certification methodologies of the QU.A.L.ITY criteria.
Presentation of the proposal for a Union certification framework for carbon removals
The EU Climate Law sets the goal to achieve climate neutrality by 2050. Consequently, the Land Use,
Land Use Change and Forestry (LULUCF) Regulation was revised and sets now the target of -310 Mt
net carbon removals through soils, forests, wood products and peatland rewetting by 2030. Moreover,
the European Commission published the Communication on Sustainable Carbon Cycles. It includes
carbon farming, which should contribute to the LULUCF targets, and announced the regulatory
framework for carbon removals.
The proposal for the certification framework distinguishes three different carbon removal activities:
permanent storage (e.g. Bioenergy with Carbon Capture and Storage (BECCS)), carbon storage in
products (e.g. use of wood-based products in construction) and carbon farming (e.g. soil carbon
sequestration). In this workshop, only carbon farming was addressed. The certification of carbon
removals aims to incentivise high-quality carbon removals, to fight greenwashing and build trust, to
harmonise market conditions as well as to offer tailored certification methodologies for different
carbon removal activities. The proposal defines four QU.A.L.ITY criteria for carbon removals:
• QUantification: Carbon removal activities are measured accurately and deliver unambiguous
benefits for climate.
• Additionality: Carbon removal activities go beyond market practices and what is legally
required. Therefore, the removal activities will be compared to a standardised baseline.
• Long-term storage: Certificates clearly account for the duration of carbon storage and
distinguish permanent from temporary storage.
• sustainabil-ITY: Carbon removal activities do not harm the environment or even contribute to
other environmental objectives.
The certification methodologies for the QU.A.L.ITY criteria will be developed by an expert group and
implemented by delegated acts. The expert group has had its kick-off meeting on 7 March 2023. The
certifications will require third-party verification, reliable certification schemes and public registries of
carbon removals to avoid double-counting. The carbon certificates can be used for public support to
achieve climate targets (e.g. in the LULUCF sector) or for private financing, but there is no link to the
EU Emission Trading System.
Discussion on the proposal for a Union certification framework for carbon removals
The development of a framework was welcomed by many because there is a need for clear European
certification rules for carbon removals. However, the framework remains rather general and many
details still have to be clarified by the expert group. This makes it difficult to give more than generic
suggestions for improvements at this stage.
During the workshop, the feedback on the proposal from ClieNFarms and the informal discussion
mainly focussed on the QU.A.L.ITY criteria QUantification, Additionality, Long-term storage and
sustainabl-ITY as well as on rewarding and trading carbon removal certificates. A summary of the
discussed points can be found below.

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QUantification
The baseline shall correspond to the standard carbon removal performance of comparable activities in
similar social, economic, environmental and technological circumstances and take into account the
geographical context. (Article 4(5))
Some participants agreed on the regional approach for calculating the baseline in the proposal. This
enables to recognise frontrunners and reward them for the best practices they already apply.
However, it was stressed that data for the calculation of standardised, regional baselines is generally
lacking and that the proposal is missing details on the principles for baseline computation. The
quantification of the baseline will depend either on measurements or modelling. Both approaches
cause a lot of work. Taking measurements is time consuming and requires a lot of resources. Research
into the use of sensors might make measurements and data collection more feasible. Some people
warned that we should not rely too much on remote sensing as it cannot give information about
carbon in deeper layers of the soil. Developing baselines through modelling demands a lot of data,
which can partially be overcome by machine learning. Satellite images can help to get accurate data.
However, if Artificial Intelligence (AI) is used, the quality of source data is important. Furthermore, an
open data policy is required to ensure interoperability of data systems. The expert group will be tasked
with the development of the baseline, it will define how farmers will be classified and clustered.
Furthermore, soil carbon sequestration is a slow process which makes its quantification and
certification difficult. It was called to raise the level of ambition for the baseline in order to reach key
requirements established under the Paris Agreement according to which the baseline should go
beyond business-as-usual. A standardised baseline could undermine integrity if it is understood as the
average performance in the sector. It could imply that farmers doing better than the average could
claim removal certificates for their standard practices without having implemented additional removal
practices. Beyond this it is not recommended to use carbon certificates based on a regional baseline
as proposed in the framework for offsetting purposes, given that emission offsets should be based on
verified emission reductions.
Moreover, it was criticised that the definition of carbon removal includes carbon storage but also the
reduction of carbon release2
. Including emission reduction will make it difficult to use the framework
to determine climate-neutrality by 2050, when carbon removals and emission must at least be equal.
This can also lead to double counting.
Some disapproved that the framework does not account for reduction in N2O and CH4 emissions.
Consequently, this might disincentivise farmers to reduce these emissions. However, the proposal
does count N2O and CH4 emission reductions as co-benefits of carbon removals and accounts for the
increase of N2O and CH4 emissions if caused by carbon farming practices in order to avoid perverse
effects (e.g., achieving carbon sequestration via increased use of fertiliser). Several participants agreed
with this approach. Moreover, voluntary schemes like the Label Bas Carbone can continue to account
for non-CO2 emissions.
2
‘carbon removal’ means either the storage of atmospheric or biogenic carbon within geological carbon pools,
biogenic carbon pools, long-lasting products and materials, and the marine environment, or the reduction of
carbon release from a biogenic carbon pool to the atmosphere; (Article 2(1))

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Additionality
A carbon removal activity shall be additional. To that end, the carbon removal activity shall meet both
of the following criteria:
(a) it goes beyond Union and national statutory requirements;
(b) it takes place due to the incentive effect of the certification. (Article 5(1))
Concerning the Additionality criterion in the proposal some wondered what happens if a carbon
removal activity currently qualified as additional, becomes obligatory because of a change in EU or
national statutory requirements. Moreover, it is often hard to prove that a carbon activity removal
takes place only due to the incentive effect of the certification.
It was pointed out that it is important to recognise the efforts that first movers did concerning carbon
farming. However, this does not go together with the criterion Additionality according to which an
activity “takes place due to the incentive effect of the certification” (Art. 5(1)). This means, removals
that are already occurring are non-additional as they are not caused by the framework. It was clarified
that Additionality does not mean that farmers have to do something new to be rewarded, but better
than the regional average.
Additionally, the certificates have to account for possible leakages, e.g. in case of a lower or changed
output due to a change in the crop rotation or if some practices attract carbon sources from other
sectors (e.g. energy or waste). Therefore, a holistic carbon approach is important.
Long-term storage
For carbon farming and carbon storage in products, the carbon stored by a carbon removal activity
shall be considered released to the atmosphere at the end of the monitoring period. (Article 6(3))
It was not clear for some participants why the carbon stored in the soil is considered as lost after the
monitoring period under the criterion Long-term storage. In reality, not all carbon will be lost after the
monitoring period. Moreover, safeguards or liability mechanisms are needed after the monitoring
period to ensure that the stored carbon remains in the soil.
The importance of long-term management and maintenance of carbon stocks in the soil were
highlighted during the discussion. These can be rewarded by the Common Agricultural Policy (CAP).
Moreover, farmers that apply carbon farming practices will benefit from them in the long-term and
continue with them. Therefore, certification can also be a way to increase awareness.
It was stressed that single measures have only a small effect on carbon removals on farms whereas
packages of measures are much more efficient. Therefore, research on how different measures work
in packages is needed.

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Sustainabil-ITY
A carbon removal activity shall have a neutral impact on or generate co-benefits for all […]
sustainability objectives [listed in the proposal]. (Article 7(1))
Some approved the “do no harm” approach concerning sustainability objectives. Other did not
consider it as sufficient. A healthy ecosystem is more likely to sequester carbon and it is more resilient.
Therefore, quantitative monitoring of biodiversity indicators (above and below ground), a
positive/negative list of actions, transparency requirements as well as training and advisory of farmers
are needed. However, there was a consensus that co-benefits are hard to measure (time consuming,
need of the right indicators, need of a lot of resources).
Furthermore, it was highlighted that it is difficult to manage farmers in a top-down approach. Instead,
we have to trust and empower them. Clear and manageable key performance indicators (KPIs) are
needed. The regenerative and organic agriculture movements, which are led by the farmers
themselves, could serve as positive examples.
Rewarding and trading carbon removal certificates
It was discussed whether farmers should be rewarded for carbon removals on a result- or on a
practice-based approach. Some support a result-based approach as they think that carbon removals
can be reliably estimated and that additionality can be proven. Others stress that quantifying carbon
in soil is uncertain and additionality is hard to prove. According to these participants practices with
known co-benefits should be rewarded instead of absolute carbon removals. Yet, others are in favour
of a hybrid scheme in which public financing rewards actions practices whereas private funds reward
concrete carbon removals. In general, there seemed to be consensus that public financing will not be
sufficient and that private financing will be needed as well to scale up carbon farming.
There were different opinions on offsetting carbon emissions with carbon removal certificates. Some
emphasise that offsetting should in any case only be allowed if the “offsetter” has made sufficient
efforts to avoid and reduce emissions in their own production system. But many also think that carbon
neutrality should first be aimed at within the food sector itself (i.e. through insetting approaches),
allowing private food supply chain actors to increase the speed of transition of the sector. In their
view, offsetting, i.e. compensation of emissions across sectors, should be discouraged. Some are very
critical to offsetting and insetting altogether because of the uncertainties in quantifying the soil carbon
content.
Conclusions
This informal policy workshop on the European Commission’s proposal for a Union certification
framework for carbon removals pointed out strengths of the proposed framework but also
weaknesses and aspects to be clarified regarding carbon farming. The discussion has highlighted a
series of points which need to be further addressed by the European Commission and the expert
group, including the following:
For calculating the net carbon removal and its associated benefits a high quantity of data will have to
be collected and the quality of data is crucial. Without reliable data the calculations will not be correct.
There are different possibilities to collect data for the baseline either through measurements, sensors

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or satellite images or a combination of these. Each of these methods has their advantages and
disadvantages. These have to be evaluated when defining sound methods for collecting reliable data.
Soil organic carbon stocks are reversible which makes it important to maintain and protect them for a
long time period. Therefore, good management practices have to be applied in order to prevent the
loss of sequestered carbon to the atmosphere. The framework is neither clear on what will happen to
the carbon removal certificate after the monitoring period nor defines any safeguards. Measures are
needed to ensure that carbon is stored in the soil on the long-term and is not lost after the monitoring
period.
The climate and biodiversity crisis are interconnected. A healthy ecosystem is a prerequisite for carbon
sequestration. Thus, the framework has to ensure that carbon farming and biodiversity protection go
hand in hand.
The framework does not lay down how the carbon removal certificates can be used. It is
controversially discussed if offsetting should be possible or not because of the non-permanence of
carbon in soils and the difficulties to measure soil carbon accurately. If certificates are used for
offsetting, the conditions for it have to be defined. Therefore, a discussion on how certificates for
carbon farming are used and traded is highly needed.

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Annex
Agenda
First, the ClieNFarms project and its contributions to climate neutral farming were presented. Then
the Commission’s proposal for a certification framework for carbon removals was explained. After
that, ClieNFarms presented their feedback on the Commission’s proposal. Finally, an informal
discussion on the proposal took place with all participants. The detailed agenda is shown below.
10:00 – 10:15 Coffee and registration
10:15 – 10:30 Introduction and presentation of ClieNFarms
10:30 – 10:50 Presentation of the proposal of legislative framework for the certification of
carbon removals
10:50 – 11:05 Feedback from ClieNFarms on the proposal of legislative framework for the
certification of carbon removals
11:05 – 12:05 Informal discussion on the proposal of legislative framework for the
certification of carbon removals
all participants
12:05 – 12:15 Wrap-up and conclusions
12:15 – 13:15 Lunch
Presentation: Feedback from ClieNFarms on the proposal for a Union certification framework
for carbon removals

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This project has received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement No 101036822
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11. https://clienfarms.eu
This project has received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement No 101036822
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12. https://clienfarms.eu
This project has received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement No 101036822
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13. https://clienfarms.eu
This project has received funding from the European Union’s Horizon 2020
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