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The 250 Mt figure settles how much, not which tonnes or whether they arrive
Carbon Gap’s explainer on the EU Emissions Trading System (ETS) puts a single number in front of European removal suppliers: the European Commission plans to fund 250 million tonnes of carbon removal through the ETS by 2040 (Carbon Gap on LinkedIn). The plan itself traces back to the Commission’s July legislative proposal for the ETS review, so the volume is not new. What Carbon Gap adds is the framing. The post says the rules now have to answer two questions: will they make sure the removals happen, and which removals will count (same post). I think that framing is right, and it changes how suppliers should read the number. 250 Mt is a ceiling on possible demand. It is not a commitment to any method.
The mechanism is a compliance market opening a door to permanent removals
The ETS is a cap-and-trade system. Covered emitters must surrender one allowance per tonne of CO2 they emit, and the total allowance supply shrinks on a fixed schedule. The July proposal, as Carbon Gap describes it, brings permanent carbon dioxide removal into that system. That word, permanent, is the scoping term the whole debate hangs on, and it is the one most likely to be read past.
The design that has been described publicly is a Commission-run purchase programme for removals funded through the ETS, rather than a free-for-all where any removal credit can be surrendered in place of an allowance. The distinction matters. A purchase programme means a public buyer sets the specification: durability threshold, storage type, verification standard, and contract terms. Those specifications do not exist yet in published, binding form. Until they do, the fence around “permanent” is drawn in pencil.
The market consequence is that the buyer is a rulebook, not a company
In the voluntary market, a supplier sells to a corporate buyer who can accept whatever storage duration suits its own claims. Under the ETS plan, the buyer is a programme bound by eligibility text. A 250 Mt cumulative target over roughly fourteen years averages under 20 Mt per year, and the real profile will be back-loaded because supply is small now. So the near-term money is modest and the late-2030s money is large, and the late-2030s money goes to whichever pathways the rulebook admits.
For suppliers, that makes the unit economics a function of two variables they do not control. First, whether their storage counts as permanent under the final definition. Second, whether they can physically deliver tonnes at the volumes a public buyer will contract for. Direct air capture (DAC) and bioenergy with carbon capture and storage (BECCS) both depend on geological storage, which means they depend on CO2 transport and injection capacity that is not yet built at scale across Europe. I have covered the DAC side of that constraint before (How Can Direct Air Capture Scale to Deliver Real Carbon Removal).
The regulatory open items are the durability line and the delivery safeguards
Two pieces of text decide the outcome. The first is the definition of permanent removal and any durability threshold attached to it. Methods with storage measured in centuries or millennia sit comfortably inside the term. Methods whose storage is shorter, or whose measurement, reporting and verification (MRV) carries wider uncertainty, sit near the line, and where that line falls is not yet published in binding form. I have seen no clause or article number in the material in front of me that fixes it, so I will not invent one.
The second is the delivery side. Carbon Gap’s Policy Summit write-up asks how captured CO2 gets to storage and who gets left behind if the network serves only the biggest players (Carbon Gap Policy Summit takeaways). That question is the “will removals happen” half of the ETS problem for every geologically stored tonne. A purchase programme that contracts 250 Mt but cannot see those tonnes into a well has funded paper, not removal. Transport access rules, storage capacity timelines, and contract penalties for non-delivery are therefore part of the ETS design whether or not they sit inside the ETS directive itself.
Supporters say the ETS needs removals to work at all
The supplier-side rationale is laid out by the Negative Emissions Platform, which argues that the ETS needs removals to work (Negative Emissions Platform, undated). The logic is that as the allowance cap heads toward zero, some covered emitters will have residual emissions they cannot abate, and the system needs a supply of genuine removals to balance them. That is a reasonable position, and it is also the position that the 250 Mt plan has now turned into an eligibility-drafting exercise.
The qualifier I would attach is the one the ETS plan should itself attach: removals inside the compliance system exist to net out residual emissions that remain after abatement, not to lower the cost of continuing to emit. The cap does that work. Removals should not loosen it.
Skeptics will say a tight permanence line is a feature, not a flaw
The counter-argument to a broad eligibility fence is simple. A compliance market cannot afford reversal risk. If a tonne surrendered against an allowance leaks back into the atmosphere in forty years, the ETS has issued a free allowance with a delay. On that view, limiting the programme to geological storage and the most durable mineralisation is the prudent default, and suppliers of shorter-lived storage should look to other instruments.
The other skeptical line targets delivery. A purchase programme with a 250 Mt target and no transport network is a target in search of pipes. Skeptics would argue the Commission should sequence storage infrastructure ahead of contracting volume, or risk paying for capacity that cannot inject.
Verdict: treat 250 Mt as demand potential gated by two unpublished definitions
The volume is real as a plan. Its value to any specific supplier is zero until two things are published in binding form: the definition of permanent removal the programme will buy, and the delivery safeguards that decide whether contracted tonnes can reach storage. Suppliers should model the ETS as a ceiling and plan on the voluntary market until the text lands. The thing to watch is Commission consultation material or legislative text that names eligible removal types and non-delivery terms. Carbon Gap’s follow-up posts are a practical place to track that detail as it appears.
Which tonnes count is the whole story.
Citations
- LinkedIn — Carbon Gap on LinkedIn — LinkedIn post
- LinkedIn — Carbon Gap Policy Summit takeaways — LinkedIn post
- Negative Emissions — Negative Emissions Platform, undated