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The question: who buys a removed tonne, and where do they live?
Canada and the EU now give opposite answers. On 2026-09-24 Canada said it will develop a carbon removal policy framework under Article 6 of the Paris Agreement, the article that lets countries cooperate on their national climate targets, according to Reuters. The European Commission’s proposal to bring permanent removals into the EU Emissions Trading System (ETS) predates that announcement. What landed alongside the Canadian news was a joint statement from five European removal associations welcoming the proposal and pushing for design changes (Carbon Herald). So these are not two governments moving in step. One is announcing intent, the other is already arguing over clauses. The direction still contrasts cleanly: Ottawa treats removals as an export, Brussels as a domestic compliance input.
Canada is drawing the export pipe before the plants exist
Canada’s framework does not yet exist, and its tonnes would be defined by Article 6 accounting at the moment they cross a border. The intended customers are foreign governments and buyers, and Reuters notes that several Asian countries have signaled interest in cross-border removal supply. The supply side is thin. Discovery Alert’s own tally, not a government figure, puts planned Canadian capacity at 11.7 million tonnes against roughly 98 thousand tonnes built (Discovery Alert), which is under 1% of plan. A foreign buyer pool matters to Ottawa precisely because domestic demand alone cannot pull that much capacity into being.
The EU is building a compliance sink while the rules are still wet
The EU already has a carbon removal certification framework, per Reuters, known as the CRCF. The Commission’s proposal would let permanent removals count inside the ETS, so buyers would be European compliance entities. Rainbow points out that the ETS revision details, the remaining CRCF delegated acts and public procurement programs are “still taking shape” (Rainbow). The Negative Emissions Platform frames the core problem as permanent removal still costing more than an EU allowance, with the gap shrinking as the sector scales (Negative Emissions Platform).
Five dimensions, two designs
| Dimension | Canada | EU |
|---|---|---|
| Source of demand | Foreign governments and buyers via Article 6 | European compliance entities inside the ETS |
| Policy maturity | Stated intent to build a framework | Commission proposal under industry negotiation |
| Rulebook defining a tonne | Article 6 accounting | CRCF certification plus ETS rules |
| Price reference | None built in; bilateral deals set it | The EU allowance price |
| Supply status | ~98K t built vs 11.7M t planned (Discovery Alert tally) | Demand designed first, supply expected to follow |
Where they converge: neither says who the buyer must be
Katharine Hayhoe (@katharinehayhoe.com on Bluesky) wrote about a cattle paper: “The paper states it’s impossible for the cattle industry to reach zero emissions through mitigation. The only way it could do so is via substantial offsets.” She was describing agriculture, not CDR policy. But that sentence is the textbook justification for removals: a sector that cannot mitigate to zero. Nothing in the reporting on either design restricts buyers to that kind of sector. An ETS compliance entity can be a fossil-fired power plant. An Article 6 counterparty can be any government with a target. Both jurisdictions have specified the pipe without specifying what is allowed to flow through it.
The second convergence is structural. The EU is building demand first and waiting for supply. Canada is lining up demand for supply it has barely started. Each design quietly assumes the other kind of market exists somewhere else.
Where they diverge: one has a price benchmark, the other has a handshake
The EU model gives developers a public reference point. The allowance price is not yet a number a project can be financed against, since the Negative Emissions Platform’s whole point is that the gap to it still has to be closed. But it is visible, daily, and shared by every buyer. Canada’s export model has no equivalent. A Canadian tonne sold abroad is priced by whatever a specific foreign buyer agrees to pay, under Article 6 accounting rather than CRCF certification. A developer eyeing both markets faces two eligibility tests, two accounting systems, and two answers to “what is this worth.” Measurement, reporting and verification (MRV) choices made now for one route may not carry over to the other.
So what: the compliance sink matters more, for now
For sector trajectory, the EU design matters more today because it creates a buyer with a legal obligation and a price signal, even an imperfect one. Canada’s design matters more if cross-border removal trade becomes real, and Reuters’ note on Asian interest suggests the two routes could end up competing for the same North American projects. In the meantime, private long-dated deals like the Tapestry and Climeworks 10-year partnership are doing the demand work neither policy has finished.
Two details will settle whether these models are complementary or separate: whether Canada’s draft framework addresses CRCF compatibility, and whether the final ETS text leaves any room for internationally sourced removals. Both governments should also write down what neither has yet: that removals bought through these channels cover residual emissions, not delayed phase-out.
Citations
- Reuters — Reuters
- Carbon Herald — Carbon Herald
- Discoveryalert — Discovery Alert
- LinkedIn — Rainbow — LinkedIn post
- LinkedIn — Negative Emissions Platform — LinkedIn post
- Bluesky — @katharinehayhoe.com on Bluesky — Bluesky post