Carbon Removal & Carbon Farming: Feedback and Proposals Regarding Afforestation — Nature+ Coalition Response to the CRCF Consultation

The Nature+ Coalition brings together organisations and operators committed to promoting high-integrity Nature-based Solutions (NbS) to fight climate change and biodiversity loss through forest restoration, sustainable management and conservation. This paper is our response to the European Commission's consultation on the afforestation methodology under the Carbon Removals and Carbon Farming (CRCF) certification framework, established by Regulation (EU) 2024/3012.

In brief

• We welcome the newest draft methodology: it improves considerably on the late-2024 version on ecosystem preservation (soil and water) and biodiversity requirements.
• We propose aligning duration, baseline and audit rules with the international standards that currently serve as quality frameworks.
• We ask that reversal liability be left to contracts between parties rather than fixed in the methodology.
• We call for other forestry methodologies (restoration, conservation, improved forest management) to be delivered quickly.

What we support in the draft methodology

The previous version, "tree planting on unused and highly degraded land", was unsatisfactory on key aspects that would have thwarted its impact. The new draft addresses them. We support in particular:

• the guarantee of tree diversity within afforestation activities: mixed species, with a prevalence of native ones where still adequate, and the possibility to introduce non-native species if justified;
• mandatory monitoring of water and soil health through enhanced management practices;
• a clear list of indicators and expected biodiversity co-benefits that project operators are explicitly encouraged to report on.

We nonetheless see two areas for improvement, so that the future CRCF carbon removal units are attractive given current trends in carbon markets.

1. Align key methodological aspects with the major international standards

Duration

The draft sets the project activity at 30 years and its monitoring, reporting and verification (MRV) at 40 years. For clarity and consistency, the Nature+ Coalition recommends aligning both the activity duration and the MRV period at 40 years, as do the international afforestation methodologies of Verra and ACR, both approved under the ICVCM Core Carbon Principles.

Baseline

Where the draft uses a standardised baseline equal to zero, we recommend a dynamic, project-specific baseline that takes into account the key geological characteristics of each area covered by project activities.

Auditing

The draft plans audits every five years for all projects. We suggest some flexibility, with the possibility of a shorter period when relevant (in line with Verra's afforestation methodology), while keeping five years as the maximum.

The Commission should also introduce a way to highlight the projects that deliver the most co-benefits on biodiversity, soil and water, based on their assessment and on the indicators the draft promotes (sections 5.1, 5.2 and 5.3), at a time when many buyers want to shift toward high-integrity carbon credits.

2. Leave contractual matters to the contracting parties

This applies in particular to the rules on liability for the risk of reversal. The methodology currently states that the operator is "fully liable" in case of "evitable reversal", and that if a project ends before the expected period the reversal is considered "total".

These aspects are contractual: they should be discussed and agreed between contracting parties, not fixed in the methodology. Contracts may for instance include a force majeure provision, so that a duly justified premature end of a project does not amount to total reversal, and the contracting parties should be the ones allocating responsibility for the risk of reversal.

Parties could also be encouraged to consider pre-payments at the start of projects. They create an incentive for smallholders and landowners, who represent the vast majority of the EU's forest owners, are more sensitive to administrative costs, and may be reluctant to engage in structural actions if they have to wait five years or more to be rewarded. The future Buyers' Club could help define best practices here, together with project developers.

Other forestry methodologies are needed quickly

Finally, the Nature+ Coalition re-emphasises the need to deliver other forestry methodologies quickly, most notably forest restoration and conservation, and sustainable or improved forest management. Afforestation projects alone will have only a limited impact on the EU's environmental commitments, from climate targets to the Nature Restoration Law.

The coalition's members remain at the disposal of the Commission to detail these recommendations, provide input for future forestry methodologies and share their expertise. Related reading: our recommendations on the SBTi Corporate Net-Zero Standard. Organisations working on Nature-based Solutions can join the coalition.