Alignment of international standards for carbon dioxide removal (CDR) using Carbon Capture and Storage (CCS): Comparative analysis of the EU Carbon Removal and Carbon Farming (CRCF) Regulation against the Integrity Council for the Voluntary Carbon Market (ICVCM) and Article 6.4 of the Paris Agreement

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Dec 24, 2025, 1:26:02 PM (2 days ago) Dec 24
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https://research-information.bris.ac.uk/en/publications/alignment-of-international-standards-for-carbon-dioxide-removal-c/

Authors: Natasha Martirosian, Murali A Thoppil, Evangelos Mouchos, Joanna House, Julian Smart, Injy Johnstone, Luka Štrubelj, Isabela Butnar

11 December 2025

Abstract
Achieving net-zero climate goals requires carbon dioxide removal (CDR). Doing this with credibility and trust requires robust standards for measuring reporting and verification of removals. In the UK context, the UK government has commissioned the British Standards Institution (BSI) to develop standards for Bioenergy with Carbon Capture and Storage (BioCCS) and Direct Air Capture with CCS (DACCS), with detailed methodological approaches under development. To inform this process, this report critically compares three international protocols: The Carbon Removal and Carbon Farming (CRCF) Regulation EU 2024/3012 (and related regulations) is assessed against the the Integrity Council for the Voluntary Carbon Market (ICVCM) Core Carbon Principles and Article 6.4 of the Paris Agreement. The analysis focuses on four key criteria: additionality, baselines, leakage, and permanence.
CRCF’s assumptions of zero-baseline approach and use of the cascading biomass principle to support sustainable use of biomass simplifies methodological approaches, for example by avoiding the needs to calculate baselines and leakage (Including indirect land-use change). However, it lacks transparency and rigorous justification. For BioCCS it may risk sustainable with potential future scale-up, and may also limit scalability. Permanence provisions broadly align but lack detailed risk management and compensatory mechanisms. ICVCM and Article 6.4 embed more robust practices, including conservative baseline setting, explicit leakage deductions, and structured reversal risk tools.
Recommendations include adopting project-specific baselines, comprehensive leakage evaluation, clearly defined monitoring periods, and explicit reversal risk compensation methods (e.g., buffer pools, insurance). Regular review processes and harmonised data-sharing frameworks are essential to ensure comparability and high integrity across CDR technologies. While CRCF prioritises pragmatism for early deployment, integrating best practices from ICVCM and Article 6.4 would strengthen credibility and future-proof standards for global interoperability.

Source: University of Bristol 
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