Commission proposal on the certification of carbon removals leaves crucial questions unanswered

BRUSSELS, 30 NOVEMBER 2022 – The Commission’s proposal on the certification of carbon removals touches on important aspects like the need for carbon farming to contribute to multiple sustainability objectives. However, it fails to propose concrete safeguards, does not require a positive impact on all sustainability objectives and leaves crucial issues unanswered.

Jan Plagge, IFOAM Organics Europe’s President, said: “The Commission’s proposal on carbon certification should recognise the efforts of front-runners like organic farmers who are already improving carbon stocks. Soil health is a cornerstone of organic and organic farmers apply practices that enhance soil fertility and increase soil organic carbon stocks. The requirement for additionality* should not disadvantage farmers who are already operating under a certified sustainability scheme like the EU organic label. Organic certification ensures not only a contribution to climate mitigation, but also to climate adaptation, resilience and protection of biodiversity and natural resources.” 

Eric Gall, IFOAM Organics Europe’s Policy Manager, adds: “The climate and biodiversity crisis are interconnected and it is crucial that the certification framework ensures that “carbon farming” contributes to biodiversity and ecosystem protection. The legislation needs to be explicit on how to ensure carbon farming contributes to the proposal’s sustainability objectives, other than carbon sequestration. It should outline beneficial farming practices, which should be considered as carbon farming and exclude those that harm biodiversity and should not be eligible to certification. Carbon removals in the land sector should not undermine the protection of biodiversity and ecosystem integrity. Conversely, as they deliver multiple benefits for climate and biodiversity, organic farming and agroecological practices should be considered as eligible carbon farming practices.” 

Soil organic carbon stocks are highly reversible and susceptible to changes of agricultural practices, but they are also impacted by climate change the framework needs to ensure that soil organic carbon stocks are maintained and protected in the long run. The long-term nature of soil carbon sequestration and its reversibility require good management practices to be applied on the long-term so that soils do not lose the sequestered carbon to the atmosphere. Making carbon removals part of an agroecological transition would ensure long-term management and conservation of soil carbon stocks, contributing to climate mitigation and at the same time to soil health. 

The framework is unclear on financing carbon removals and leaves the door open to voluntary carbon markets. Organic farmers doubt that carbon markets are the right policy tool to provide fair and reliable funding for farmers to improve soil carbon sequestration. Moreover, the framework does not provide any safeguards to prevent land commodification and does not address the risk of land grabbing. Clear social and environmental safeguards are needed to prevent the certification of carbon removals to become a greenwashing tool.  

*Additionality is a defining concept of carbon removal projects. To qualify as a genuine carbon removal, the removals achieved by a project need to be ‘additional’ to what would have happened if the project had not been carried out (e.g., continued as business-as-usual) 


For more information please contact: 

Eric Gall, Policy Manager, +32 491 07 25 37, [email protected] 

Hanna Winkler, Policy Officer on Climate Change and Biodiversity, [email protected] 


Eva Berckmans, Communications Manager, +32 2 416 27 62, [email protected] 

or visit www.organicseurope.bio  

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