Regulatory frameworkWhat is Carbon Removal & Carbon Farming?

The European Union’s Carbon Removal and Carbon Farming (CRCF) framework is a regulatory initiative aimed at establishing a common European approach for certifying carbon removal and carbon farming activities. Its primary objective is to introduce consistent definitions, methodologies, and quality requirements for how these activities are measured, monitored, and verified across different sectors and geographies in Europe.

The CRCF does not create a separate carbon market different from the Voluntary Carbon Market, nor does it regulate the trading of carbon credits. Instead, it focuses on certification, providing a structured set of rules and unified data sets for emission factors, under which carbon removal outcomes can be recognized within a unified European framework.

The CRCF mainly leans on the brand new GHG Protocol on Land Use and Removals Standard to be effectively used from 2027 onwards. By introducing more rigorous and standardized requirements, the CRCF contributes to improving transparency, comparability, and credibility of carbon removal and carbon farming activities. It reflects a broader shift in climate policy, where increasing emphasis is placed on measurable, durable, and verifiable climate impact.

By defining which activities fall within its scope, the CRCF provides a structured reference point for project development and certification. It guides the market toward solutions that not only generate measurable climate impact, but also align with evolving expectations around permanence, transparency, and environmental integrity.

From a corporate perspective, the implications are significant. Companies are operating in an environment where climate commitments are increasingly scrutinized by investors, regulators, and other stakeholders. In this context, the credibility of climate strategies depends not only on own emission reduction efforts, but also on how residual emissions are addressed. Carbon removals that align with emerging frameworks such as the CRCF are therefore becoming an important component of long-term auditable net-zero strategies for corporates following Science Based target initiatives (SBTi) or similar decarbonization schemes.

CRCF

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Market implicationsWhat are the 3 pillars of EU CRCF architecture?

The CRCF framework categorizes corporate climate action into three distinct operational pillars. The regulatory positioning of each pillar defines its compliance eligibility, financial valuation and market monetization pathways.

3 pillars of crcf

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Carbon removals

The first pillar encompasses technological carbon removal solutions that achieve multi-century, irreversible physical isolation of CO2 from the global carbon cycle. Because geological storage effectively eliminates atmospheric re-entry risks, the EU grants this pillar direct access to the high-value compliance market.

 

biochar
Biochar

Biochar is a stable, carbon-rich charcoal produced through the thermo chemical conversion of organic biomass in an oxygen-deprived environment.​

DACCS
DACCS

Direct Air Capture with Carbon Storage is a carbon removal solution capturing atmospheric CO2 and achieving permanent, irreversible physical isolation of CO2 from the carbon cycle.

beccs
Bio-CCS/BECCS

Bioenergy production or Waste-to-energy solutions facilitating harness biogenic material to generate heat of electricity while capturing and storing biogenic CO2.

Carbon farming

The second pillar covers biological, land-based carbon sequestration activities executed across agricultural soils, forestry systems, and natural ecosystem restoration projects.

 

agroforestry
Agriculture & Agroforestry

Adopting sustainable agricultural land management practices such as cover cropping, no/low-tillage farming and agroforestry to build up soil organic carbon stocks, retain water and combat erosion.

rewetting
Peatland Rewetting & Wetland Restoration​

Restoring natural hydrology in degraded peatlands to prevent peat oxidation, and in drained wetlands for modern agriculture to their original state to halt soil carbon mineralization​.

afforestation
Afforestation & Reforestation​

Establishing new forests on land that was previously non-forested or re-establishing tree cover in degraded or cleared forest areas. This locks away carbon long-term in living tree biomass, deadwood, and forest soils.​

Bio-based construction materials

This pillar encompasses long-duration carbon storage physically embedded within the built environment using organic construction materials.

 

managed timber
Managed Timber

Managed timber operations maintain ecosystem balance in forests while ensuring continuous yield of wood and preserving the long-term health and carbon storage capacity (often FSC or PEFC certified).​

bio-insulations
Bio-insulations

Thermal and acoustic insulation products made from rapidly renewable organic resources (plant fibers or animal wool) rather than fossil fuels (polystyrene) or energy-intensive minerals (fiberglass).​

bio-concrete
Bio-concrete & Bio-composites

Composite concrete and other structural building materials formed by natural fibers designed to replace carbon-heavy and energy-intensive raw materials with low-carbon, renewable bio-alternatives.​

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fleet electrification know-how
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OUR PROTECTED KNOW-HOWS

Explore our solutions

360° service for carbon credit generation, registry, and trading with mitigia’s third-party verified Digital MRV.

OUR PARTNERS

They are already benefiting from carbon credits generated by their green investments

THEY ARE ALREADY IMPROVING THEIR E-MOBILITY INVESTMENTS' ROI

Our Clients

Four main obstacles hinder the spreading of electrification:

the renewable energy production challenge,
the energy storage challenge,
the charging challenge
and last, the EV challenge.


We target all of them with methodologies that built upon each-other.

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Quality assuranceWhat are the 3 pillars of QU.A.L.ITY assurance?

quality assurance

Wondering whether your projects fall within the EU CRCF scope?

We assess project types against emerging European certification requirements.

EU ETS integration pathwayOnly permanent technological removals adopted into the Compliance market

The ongoing revisions to the EU ETS Directive (2003/87/EC) and the newly introduced Electrification Act establish a legal compliance bridge to the EU Carbon Removal Certification Framework (EU CRCF 2024/3012) for the 2031–2035 trading period. Based on emerging regulatory architecture, this integration establishes a strict, two-speed carbon market in Europe. It exclusively integrates permanent technological removals with verified physical geological storage, while excluding biochar, carbon farming assets and bio-construction materials due to biological reversal risks and/or pending technical methodologies.

To prevent the devaluation of primary industrial decarbonization incentives while supporting hard-to-abate sectors, the European Commission introduced a capped 250 Mt Removal Flexibility Cap . This mechanism allows heavy emitters in sectors such as steel, cement, chemicals, and waste-to-energy to substitute a defined portion of their fossil EU Allowances (EUAs) with CRCF certified permanent removal unit if meeting eligibility criteria. First, one to one parity means that exactly one metric ton of certified permanent biogenic or atmospheric CO₂ removal directly offsets one EU Allowance. Second, all removal projects must be physically executed within EU boundaries and locked via permanent geological or mineral storage governed by the EU Geological Storage Directive (2009/31/EC ). Finally, project must be verified against QU.A.L.ITY Standards to ensure that all units demonstrate net-negative atmospheric impact, strict financial additionality, robust monitoring protocols, and full compliance with the Renewable Energy Directive (RED).

 

3 pillars table

Our methodologies complement each other

...and cover the whole of the electrification ecosystem from renewable energy production to fleet electrification projects.

The four mitigia methods complement each other

MONETIZE YOUR EMISSIONS REDUCTIONS

What is a carbon credit?

mitigia | what is a carbon credit?
CARBON GAIN

When you replace a CO2 intense technology with a more climate friendly or even a net zero one, you "spare" CO2 emissions. Thus, you, as an economic entity, realise a so called carbon gain. By comparing the two technologies, the volume of this carbon gain can be precisely measured, verified and reported, and exchanged into Verified Emission Reduction (VER) or Voluntary Carbon Unit (VCU).  

LARGE EMITTERS

What appears as a „spared" or "negative emission” on the green investors' side is sought after by net emitters whose emission volumes exceed the regulatory limits (and cannot avoid or reduce by themselves). These emitters either pay a penalty fee or buy carbon credits in exchange for their emissions. By choosing the second option they turn their ESG obligations into an opportunity to invest in green investments.

OUR SOLUTION

mitigia helps green investors originate and register carbon credits based on their electrification investments, and sell such carbon credits to large emitters.

Our know-how is compliant with the requirements of the VCM, thus the carbon credits originated through mitigia’s methodology qualify as high integrity carbon credits.

These credits represent a higher quality for the buyers, who are willing to pay a higher price for the reliability and transparency of the underlying projects the credits were originated from.

THEY HELP US WITH THEIR UNIQUE EXPERTISE

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Common questions
Answer to key questions

How does CRCF define high-integrity projects?

The CRCF framework places a strong emphasis on ensuring that certified activities deliver high-integrity climate outcomes. This is achieved through a set of clearly defined criteria that address how carbon removals are quantified, monitored, and maintained over time.

  1. Additionality is key. One of the central principles is additionality, requiring that certified activities deliver carbon removals beyond what would have occurred under standard practices or existing regulatory requirements. This ensures that the climate impact is not only measurable, but also genuinely incremental.
  2. MRV is required. The framework also introduces strict requirements for monitoring, reporting, and verification. Project outcomes must be tracked over time using consistent methodologies, allowing for transparent and comparable assessment of performance. This is complemented by independent verification processes delivered by a Validation & Verification Body accredited by the EU, which provide assurance that reported results accurately reflect the underlying activities.
  3. Emission factors are critical. All emission factors must be spatially defined closest to the Land Management Unit; no global averages fit the methodology anymore. Full GHG footprint calculation is required, meaning biomass-only, CO₂-only emission factors are insufficient. Allocation is no longer a modelling choice; it has become a consistency requirement. Biogenic CO₂ emission factors are required to use; if the biogenic emission factor isn’t there, the emissions do not disappear, they are just simply missing from the calculation. Finally, all emission factors must meet measurement-grade evidence thresholds. If removals are reported, carbon stock changes must be empirically supported; underlying data must be periodically re-measured or recalibrated at least every 5 years, and representativeness across variability must be demonstrated.

Taken together, these elements define a more rigorous approach to carbon project quality. Rather than relying on broad claims, the CRCF establishes a framework in which climate impact must be demonstrable, traceable, and maintained over time.

How does the EU ETS–CRCF integration impact corporate Scope 3 strategies?

The integration establishes a clear regulatory boundary between compliance carbon offsets and corporate Scope 3 value chain interventions. While compliance entities utilize permanent technological removals (DACCS and BECCS) for direct ETS offset obligations, non-compliance corporations must deploy Digital MRV (dMRV) platforms to verify and transfer offsets across agricultural and industrial value chains under CSRD reporting rules.

Why is Carbon Farming omitted from direct EU ETS compliance integration?

The main reason for the omission of Carbon Farming from CRCF to EU ETS integration is the irreversible risk associated with carbon dioxide storage and its lack of permanence (reversal risk). While geological storage isolates the gas from the atmosphere for millennia, biological carbon dioxide storage (soil, forest biomass) is merely temporary:

(1) Natural and climate risks: A forest fire, a period of drought, the emergence of pests, or a change in land use can release the sequestered carbon dioxide back into the atmosphere in a matter of weeks or months.

(2) Violation of the “Like-for-Like” Principle: Emissions of fossil carbon dioxide permanently increase the amount of carbon dioxide in the atmosphere. Fossil emissions cannot be permanently offset by temporary biological removal without worsening the climate balance in the long term.

(3) Limitations on oversight and liability: It is legally impractical to hold a farmer or landowner legally and financially liable for 100 years for any potential decrease in soil carbon content.

What is the future of Carbon Farming after omitting from CRCF to EU ETS integration?

Excluding Carbon Farming from the EU ETS does not mean leaving the land sector entirely to its own devices. The European Commission (EC) has recognized that climate neutrality by 2050 is unattainable without incentives for decarbonization in the agriculture and forestry sectors. Therefore, the EC explicitly supports Carbon Farming projects within the framework of the CRCF regulations and has proposed a comprehensive support and market framework for credits excluded from the EU ETS-CRCF integration, which is based on several pillars:

(1) EU Buyers Club. To bolster demand for Carbon Farming and the resulting nature-based CRCF credits that remain outside the EU ETS, the European Union is officially launching an initiative called the “EU Buyers Club.” This is an institutionalized, EU-coordinated procurement platform whose main functions are as follows: pooling the voluntary demand of large corporations; regional standardization (since the EU Buyers Club purchases only European CRCF certified Carbon Farming units); and supporting value chain offsetting (buyers can use the credits they purchase to offset Scope 3 emissions in their own supply chains within the framework of the CSRD directive.

(2) Common Agricultural Policy (CAP) funding: The EC proposes directly linking CAP funding for so-called “eco-schemes” and rural development to CRCF certification. Farmers who produce certified CRCF Carbon Farming units will be eligible for priority area-based and investment support.

(3) Agricultural ETS: This is a rather vague proposal for the creation of a sectoral market. The EC has promised to prepare a sectoral trading system, set to launch after 2035, designed specifically for agriculture and land use. In this envisioned “Green ETS,” agricultural operators would be able to trade Carbon Farming credits among themselves.

What is the function of the EU Buyers Club?

The EU Buyers Club is an EU-coordinated institutional procurement mechanism designed to consolidate voluntary corporate demand for non-ETS integrated carbon farming credits. It allows enterprise buyers, particularly in the food, beverage, and consumer goods sectors, to purchase CRCF-certified nature-based credits to neutralize Scope 3 supply chain footprints under CSRD mandates.

What is the Removal Flexibility Cap under the revised EU ETS Directive?

The Removal Flexibility Cap is a regulatory ceiling established by the European Commission, capped at an aggregate 250 Mt permanent removal capacity for the 2031–2035 trading period. It dictates the maximum volume of certified permanent carbon removals that regulated compliance entities can use to substitute their fossil EU Allowances (EUAs).

How does the Electrification Act complement the EU ETS overhaul?

The Electrification Act is a parallel legislative initiative designed to accelerate the direct electrification of heavy industry and transport across Europe. It grants grid priority, administrative streamlining, and fee exemptions to industrial operators replacing fossil heat with clean electricity, working alongside the EU ETS to drive primary decarbonization before residual emissions are addressed via CRCF removals.

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