CRCF requirements

This page lists all the additional requirements mentioned in the methodology, that apply for projects seeking certification under the European Commission's CRCF.

Project Developers shall also follow all requirements in the Rainbow Procedures Manual on CRCF.

Eligibility and scope

🇪🇺CRCF requirement: Confirmation of the origin of the CO₂ stream

If the facility at which the CRCF-project captures CO₂ is not subject to monitoring of the biogenic CO₂ amount under the EU Emission Trading System (EU-ETS), Project Developers shall provide access, immediately at request, to representatives of the VVB, Rainbow or relevant national authorities to allow unannounced C14 testing of the CO₂ stream leaving the facility, and if relevant, prior to being mixed with any separately captured fossil CO₂ stream. If the biogenic origin cannot be confirmed, then no credits shall be issued for the corresponding monitoring period.

🇪🇺 CRCF requirement: Eligible storage

For CRCF-projects, the capture facility shall be located in the European Union and the storage site(s) shall be permitted under the ​Directive (EU) 2009/31/EC on the geological storage of carbon dioxide.

Principles & requirements

🇪🇺 CRCF requirement: Biomass sustainability

In addition to meeting all requirements outlined above, Projects seeking certification under the CRCF shall also comply with the following:

RED-certified biomass

Project shall use biomass that is compliant with the EU's Renewable Energy Directive (RED) III. Specifically, this means that

• biomass shall be compliant with the sustainability requirements set out in Article 29 of the RED for the purposes referred to in Article 29, Paragraph 1 (a), (b) and (c), even if the project does not generate renewable energy that is taken into account under the RED.

• the requirements on GHG savings set out in Article 29, Paragraph 10 shall only be met if the CO₂ is captured at a facility producing heat, electricity or a biofuel, bioliquid or biogas. The GHG savings criteria apply to the product of the facility.

• biomass from waste or residues from agricultural, aquaculture, fisheries and forestry residues are subject to the sustainability requirements set out in Article 29, Paragraphs 2 to 7. Other biomass types are not subject to the requirements in these paragraphs.

Compliance shall be demonstrated by certification of the biomass from

• voluntary schemes approved by the Commission in accordance with Article 30, Paragraph 4 of RED, or

• national schemes recognized by the Commission in accordance with Article 30, Paragraph 6 of RED, or

• schemes recognized by the competent national authority in the state where the BioCCS capture facility is located.

Additional biomass sustainability requirements

Project Developers shall also demonstrate that

• biomass is not identified as being produced from a high indirect land use change risk feedstock, as defined in the Delegated Regulation 2019/807 to the RED.

• if biomass is sourced from areas designated by the national competent authority for

  conservation, including areas covered by the national restoration plan established under

  Regulation (EU) 2024/1991, or in habitats that are protected, the sourcing shall be in

  accordance with the conservation and restoration objectives for those areas.

CO₂ captured from energy production covered under RED

If CO₂ is captured from an energy production process covered by the RED, Project Developers shall demonstrate that

• the national implementation of that directive applies to the operator of the energy production process and that the operator complies with this national implementation.

• the operator complies with any measures in that national implementation that ensure that woody biomass is used according to the list of priorities established in Article 3, Paragraph 3 of the RED, including any derogations introduced by Member States under Article 3, Paragraph 3 (a), if the operator benefits from a relevant support scheme for energy production.

• the operator does not receive direct financial support from Member States for the use of saw logs, veneer logs, industrial grade roundwood, stumps and roots to produce energy, in line with Article 3, Paragraph 3 (c)

Facilities regulated under the RED undergo periodic assessment of compliance with the sustainability requirements by Member State competent authorities. This periodic assessment shall not prevent the compliance assessment conducted by the VVB for approval of credit issuance. In practice, this means that the VVB does not need to wait for the completion of an ongoing RED assessment of compliance before assessing the BioCCS project and approving credit issuance. However, if the Member State assessment results in any non-conformity with Article 29 of the RED, Project Developers shall notify Rainbow and the VVB immediately.

Voluntary compensation of biomass

To support the regeneration of natural carbon stocks used for the generation of permanent carbon removals, Project Developers may purchase carbon farming sequestration units and report the amount in the monitoring report.

🇪🇺 CRCF requirement: Risk assessment

Project Developers seeking compliance with the EU's CRCF shall additionally evaluate and address the following risks.

Climate change adaptation

To comply with the do-no-significant-harm to climate change adaptation criteria, Project Developers shall identify the physical climate risks that are material to the project from those listed in Section II of Appendix A to Annex 1 of the Commission Delegated Regulation (EU) 2021/2139 and perform a robust climate risk and vulnerability assessment following the steps outlined in Section I of that same appendix.

Sustainable use and protection of water and marine resources

Any potential risks due to the project to the good status or the good ecological potential of bodies of water, including surface water and groundwater, or to the good environmental status of marine waters. In the case that pollutants that are scrubbed from flue gases in order to reduce air pollution may be released to a body of water, the air pollution benefit and the availability of alternative discharge strategies shall be taken into consideration when evaluating the impact on water quality.

Addressing the following Minimum environmental and social risks defined in the Rainbow Standard Rules is equivalent to addressing this risk:

• Minimize pollutant discharges to water, noise and vibration

• Avoid and/or minimize negative impacts on terrestrial and marine biodiversity and ecosystems

• Minimize water consumption and stress in the project

Circular economy, efficient use of sustainably sourced bio-based materials

Any potential risks to the circular economy objectives from the projects, considering

• the project leads to significant inefficiencies in the use of materials or in the direct or indirect use of natural resources such as non-renewable energy sources, raw materials, water and land at one or more stages of the life cycle of products, including in terms of durability, reparability, upgradability, reusability or recyclability of products

• the project leads to a significant increase in the generation, incineration or disposal of waste, with the exception of the incineration of non-recyclable hazardous waste

• the long-term disposal of waste may cause significant and long-term harm to the environment

Pollution prevention and control

Any potential risks to generate a significant increase in the emissions of pollutants to air, water or land from the project. Where facilities are within the scope of Directive 2010/75/EU they shall comply with all requirements arising from that Directive.

Where facilities are not in the scope of that Directive, addressing the following Minimum environmental and social risks defined in the Rainbow Standard Rules is equivalent to addressing this risk.

• Minimize pollutant emissions to air

• Minimize pollutant discharges to water, noise and vibration

• Minimize generation of waste and release of hazardous materials, chemical pesticides and fertilizers

Protection and restoration of biodiversity and ecosystems

Any potential risks from the project to the good condition or resilience of ecosystems or to the conservation status of habitats and species, including those of Union interest or to the achievement of targets or obligations set out in national restoration plans established under Regulation (EU) 2024/1991.

Addressing the following Minimum environmental and social risks defined in the Rainbow Standard Rules is equivalent to addressing this risk. Note that any potential risk to targets or obligations in national restoration plans shall be addressed separately.

• Avoid and/or minimize negative impacts on terrestrial and marine biodiversity and ecosystems

• Protect the habitats of rare, threatened, and endangered species, including areas needed for habitat connectivity

• Do not convert natural forests, grasslands, wetlands, or high conservation value habitats

• Minimize soil degradation and soil erosion

• Minimize water consumption and stress in the project

GHG Quantification

🇪🇺 CRCF requirement: Data sources

In addition to the data listed in the table above, Project Developers of CRCF-projects shall additionally monitor and update the fraction of injected CO₂ dedicated for carbon removals under the CRCF, $F_{CRCF}$.

🇪🇺 CRCF requirement: Recognition under different schemes

Project Developers can choose to credit part of net carbon removal under a scheme other than the CRCF. In this case, the fraction credited under the CRCF, $F_{CRCF}$ shall be applied to the net removal calculation in Eq. 1 .

🇪🇺 CRCF requirement: Emission factors biomass production

For CRCF-compliant projects, Project Developers shall follow the hierarchical list below for selecting biomass production emission factors:

1. RED III disaggregated default values for term e_ec,

2. Default values at regional level (NUTS2),

3. Calculate averages based on local farming practices based on e.g. data of a group of farms, as an alternative to using a single actual value

Note that the use of representative emissions factors from other databases or literature is not allowed under the CRCF.

🇪🇺 CRCF requirement: Discount factor

For CRCF-projects, the discount factor is applied to the gross GHG removals, $R_{project}$.

🇪🇺 CRCF requirement: Parasitic load approach

Project Developers seeking certification under the EU CRCF shall only use the full approach (biomass-based calculation) to determine emissions from parasitic load demand.

Sampling and measurements

🇪🇺 CRCF requirement: Measurements of CO₂ stream

In addition to following the requirements set out in this section, CRCF projects shall ensure measurements of the CO₂ stream are taken in accordance with Articles 40-46 and Article 49 of the European Commission's Implementing Regulation 2018/2066.