Working Paper
Carbon Dioxide Removal: Climbing up the
EU Climate Policy Agenda
Felix Schenuit, Oliver Geden
Since the adoption of the Paris Agreement and the publication of the IPCC’s Special Report
on 1.5°C Global Warming (IPCC 2018), net zero emission targets have diffused rapidly
across almost all political levels. While their scope varies and is often ambiguous (Rogelj et
al. 2021), the concept of counterbalancing residual emissions with carbon dioxide removal
(CDR) is emerging as a new organizing principle of climate policymaking. In the EU, net zero
greenhouse gas (GHG) emissions developed from a long-term aspirational pledge in the
context of the European Green Deal into a component of EU climate legislation in the socalled EU Climate Law (Regulation (EU) 2021/1119).
Modelling facilitated by the European Commission for its draft EU long-term climate strategy (Commission 2018b) as well as national modelling efforts (e.g. for the UK, CCC 2019 or
Germany, Prognos et al. 2021) indicate that achieving net zero GHG emissions by 2050 or
earlier requires significant amounts of CDR. The rapidly growing scientific literature on
CDR identifies numerous methods to remove CO2 from the atmosphere (for an overview,
see Babiker et al. 2022), ranging from already established afforestation to more speculative
direct air capture combined with carbon capture and storage (DACCS) (for details, see section 2). The need to deploy a portfolio of these methods to counter-balance hard-to-abate
emissions e.g. from agriculture, industry, or long-haul transport, raises important questions
about the operationalization of the net zero target within EU legislation. Although there are
numerous political challenges in the process of accelerating a transition towards net zero
GHG emissions, CDR stands out due to its potential to challenge the prevailing public policy
paradigm in EU climate policy (Geden et al. 2018). Therefore, it is key to explore how removals are and will be integrated in the climate policy mix, how related politics play out,
and how other aspects of climate policy will be affected.
There are three key reasons why a better understanding of how the EU is addressing CDR
politically is required. First, the EU and its representatives perceive themselves and are being perceived as frontrunners in international climate policy. The way the EU is starting to
regulate CDR can therefore be anticipated to have an impact on the international debate
and governance under the UNFCCC, other fora for international cooperation, and climaterelated regulation in other countries. Secondly, OECD countries with their large shares of
historic emissions are (in the academic literature, at least) generally expected to implement
large amounts of CDR (Lee et al. 2021; Pozo et al. 2020). Thirdly, the issue will get more
attention when the time period beyond 2050 comes to be addressed in climate policy. As
already stipulated in the EU Climate Law, after achieving net zero in 2050 the EU will need
to achieve net-negative GHG emissions.
CDR policymaking is a rapidly emerging component of climate policy (Schenuit et al. 2021).
In order to trace its struggle onto and up the EU climate policy agenda, we start by providing
a brief overview of CDR-related aspects of the EU’s 2030 Climate and Energy Framework as
adopted in 2018 and show that CO2 removal is not entirely new to EU climate policymaking.
We then turn to more recent developments, in particular the EU Climate Law and the new
‘Fit for 55’ package under the Green Deal to explore relevant actors in EU climate policymaking and their (evolving) political positioning towards CDR. On this basis, we conclude
with an outlook on plausible future developments in CDR policy