Envisioning a carbon removal strategy for Europe

With compounding crises vying for political attention comes the risk for climate action to be deprioritised just as it most urgently needs to be ramped up. 2023 was the hottest year ever recorded and impacts worsen as we near temperature thresholds set by the Paris Agreement. Swift action will be needed to counteract these negative trends. Bold policies are required to decarbonise the EU and global economy and address the remaining governance gaps that hamper progress toward a safe climate for all.

Severe and continued emissions cuts remain the primary means of reaching global and EU climate targets. However, carbon dioxide removal (CDR) will play a complementary and increasingly significant role in Europe’s plan to reach climate neutrality by 2050. Despite its key role, there is not yet a cohesive governance structure in place for CDR in the EU. The current legislative framework is fragmented, addressing CDR across several pieces of legislation. Leaving these policy gaps unattended risks the EU failing to deliver CDR at the volumes required by 2040, 2050 and beyond, thereby jeopardising Union-wide, legally binding climate objectives. Conversely, agreeing upon an EU framework to develop, deploy and scale CDR responsibly and, in time, would represent a major political achievement and a significant step towards reaching the 2050 EU climate target.

Against this backdrop, Carbon Gap calls for the development of an “EU Carbon Dioxide Removal Strategy”. Like other EU strategies, this blueprint could be put forward as a Commission communication, laying out a roadmap for CDR from now to 2050. The strategy would outline distinct, overlapping phases of policy support to meet the needs of the CDR sector on its journey to scale. Carbon Gap recommends that the scope of an EU CDR Strategy cover both enabling conditions (including the establishment of targets, rules governing the quality and use of carbon removal and physical CO₂ transport and storage infrastructure), as well as proactive measures to develop, scale and sustain carbon removal’s contribution to EU climate action.

In this document, Carbon Gap offers 18 actionable policy recommendations for how the EU could support CDR over the next thirty years as part of an EU CDR Strategy. The recommendations are spread across four key “pillars” that should be pursued collectively to deliver effective and just CDR. The foundational pillar of fair and inclusive governance and deployment cuts across the other three pillars, integrating justice provisions into the CDR sector. The other three pillars overlap and are phased across time, first prioritising research, development and innovation, then introducing dedicated deployment incentives and finally, solidifying an enduring policy framework comprised of binding targets, EU-level compliance mechanisms, and member state initiatives. The recommendations provided under each of these pillars would help grow the pool of potential CDR methods, test the viability of scaling promising, yet high-cost methods, and secure future demand for CDR.

The upcoming political cycle offers EU policymakers the opportunity to make CDR a political priority by launching a dedicated EU CDR Strategy. A holistic ambition for CDR could serve as the basis for widespread public engagement and discussion on CDR in Europe, whilst inspiring action in

 other jurisdictions beyond Europe. It would help set the direction of travel for CDR, clarify the EU’s overall CDR ambition and kickstart decades of concerted action to integrate CDR into ongoing mitigation efforts. Developing a dedicated EU CDR Strategy would therefore help ensure delivery on EU climate targets, cementing the position of the EU as a global leader on climate action.

1) Make a clear and significant financial commitment to EU RD&I on carbon removal, equalling around EUR 2.6 billion in the next Multiannual Financial Framework for 2028-2034 to cement the EU’s global leadership in the green transition and retain human capital and intellectual property.

2) Make carbon removal a research priority area in the next Framework Programme for R&I (FP10) and Multiannual Financial Framework.

3) Ensure that an overarching EU CDR Strategy outlines a long-term plan for CDR RD&I in Europe, including clear goals and a mapping of research gaps.

4) Modify the eligibility criteria and application processes for research funding to make them clear and easy to navigate.

5) Develop a centralised platform for EU-level RD&I funding for CDR to make it easier to find available EU funding options and track CDR funding flows.

6) By 2025, the Commission should kick-start the demand for CDR by launching a pilot procurement programme, or other comparable deployment incentive, for high-durability and high-cost CDR methods with dedicated EU funding.

7) Based on the success of the first pilot procurement programme, a second wave of procurement mixing public and private funding would significantly boost the scale-up of CDR supply and leverage private investments.

8) By 2030, a Carbon Clearing-house should be launched to enable the aggregation of demand and procurement of carbon removal at scale, setting the stage for an enduring EU policy framework for CDR.

9) Revise policies governing land management to halt the decline of, and hasten the restoration of, the land sink.

10) Embed removals across existing EU legislation, going beyond compensation to drive organic demand for a wide range of carbon removal.

11) Set a binding overall target for carbon removal with dedicated sub-targets, including for the LULUCF sector and higher-durability removals.

12) Integrate removals into an EU-wide compliance mechanism to enlist private entities in carbon removal scale-up, such as via direct integration of CDR into the ETS under strict guardrails, or the creation of a separate RTS.

13) Allocate the remainder of the binding removal targets to the member states using the ESR, sharing responsibility commensurately among member states to deliver the target domestically, or to financially contribute to the CDR Clearing-house to bridge the shortfall.

14) Boost the European Scientific Advisory Board’s capacity to advise EU policymakers on developing CDR in a just way.

15) Evaluate and monitor social and environmental impacts of CDR projects as part of EU funding criteria.

16) Earmark funding for research into the social and ethical dimensions of CDR.

17) Consider establishing a Carbon Removal Communities Initiative that empowers local actors to deploy CDR from the bottom-up.

18) Convene a CDR Forum and support the co-development of a Community Code of Conduct for CDR.