Our feedback to the EU carbon removals certification framework

210 feedback letters were submitted to the European Commission regarding the Carbon Removal Certification Framework, and TREEO was one of them!

The European Commission is in the process of establishing guidelines for carbon dioxide removals (CDR) certifications. As a German-based company in the CDR sector, we agree that this framework is indeed a necessary step forward and we thank the European Commission for being open to feedback. However, as a German-based company with offices in countries outside the EU, we also believe this framework will have a wider impact and must contemplate the social and environmental factors at play in other regions of the world. It would not be the first instance in which a EU directive has an impact on other regions as well. As a company working in the Global South we believe we can provide valuable insights.

What we think at TREEO:

At TREEO we strongly believe that consistency in terminology is necessary in this sector. For instance, keeping the definition of what makes a Carbon Dioxide Removal in line with the IPCC definition of CDR, as well as a very clear definition of the durability thresholds.

The framework presents remote sensing as a solution for accuracy. However, although it is a wonderful tool for many sectors, it does not provide the accuracy and trust that in situ single-tree monitoring can bring to the carbon market. With the TREEO Technology we provide this accuracy and rely on remote sensing as a second step for verification only. Additionally, small land owners still face challenges in simply accessing quality remote sensing solutions. 

To read more about our feedback on quantification, additionality, long-term carbon storage, and CDR certification, read our full feedback statement here.