The EU ETS Draft Excludes Biochar Carbon Removal - And It's Not Too Late to Fix It

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We have been successful in integrating BCR into the EU Carbon Removal and Carbon Farming Certification Framework (CRCF). Now, the inclusion of carbon removals into the compliance market is under discussion.

The European Commission's draft revision of the EU Emissions Trading System (ETS), published today, proposes to recognise carbon removals for compliance purposes – but only via CCS-based pathways (DACCS and BioCCS). Biochar Carbon Removal (BCR) would be excluded, even though it is already certified as a permanent removal activity under the CRCF. This is a real risk for the biochar sector, and a policy inconsistency the EU can still fix – but only if national decision-makers hear from industry now, while the file is being negotiated.

The Commission's proposal now moves into the ordinary legislative procedure, where the European Parliament and the Council of the EU (representing national governments) each negotiate and adopt their own position before entering trilogue negotiations to agree on a final text. In other words, the Commission's exclusion of BCR is not final: Parliament and Council are still decisive, and national representatives can still shape the outcome – which is exactly why reaching them now, early in the process, matters.

CONTEXT

• All three permanent removal pathways – DACCS, BioCCS and BCR – are already CRCF-certified. Excluding only BCR from the ETS creates an unjustified inconsistency between two flagship EU climate instruments.
• BCR is deployable today, at TRL 8–9, already operating at commercial scale – unlike pathways still dependent on future infrastructure build-out.
• A CCS-only ETS unnecessarily narrows the compliance market, raises costs for ETS-obligated companies, and concentrates deployment risk instead of rewarding a diversified, competitive removals portfolio.
• Biochar and pyrolysis are part of the EU's "Made in Europe" bioeconomy and industrial strategy.
• The scientific case for BCR's permanence is well established and is the same evidence base the Commission already relied on to certify BCR under the CRCF.

YOUR PART IN THIS

Please reach out to your national representatives – your MEPs, your national ministry contacts working on ETS/climate files, or your national industry association – and ask them to push for technology-neutral treatment of permanent carbon removals in the ETS trilogue. Feel free to use the linked position paper directly, or draw on the key points above in your own words.

Reach out to your established contacts first. If you don't already have relevant contacts, you'll find a list of your EU representatives on right side of this page. And if you'd like support figuring out who to approach, feel free to get in touch with us.

Every voice from industry, especially from companies already active in carbon removals or affected by the ETS, adds weight. If you'd like a shorter template letter to send directly to your representative, or want to compare notes on who to approach in your country, just let us know – we're happy to help coordinate.

Thank you for your support on this.

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