ERCST Reflection Note – The CRCF trilogues and the Industrial Carbon Management strategy: where are we headed?

Since the adoption of the CCS Directive in 2009, regulatory development for CCUS and CDR technologies in the EU has been limited. However, renewed momentum emerged in 2021, and key regulations have been put forward since then.

This paper focuses on the recent publication of the Industrial Carbon Management Strategy (ICMS) and the provisional agreement reached between the Parliament and the Council on the proposal for a Carbon Removal Certification Framework (CRCF), as they are pivotal in shaping the future of CCUS and CDR technologies within the EU. Despite progress, clarity and specificity in these regulations remain lacking, raising concerns about policy uncertainties and potential discrepancies among Member States, as well as not being fit for purpose to support the EU in its pathways towards achieving the Paris Agreement’s target.