Take on a podcast episode from The CDR Policy Scoop, originally published Mon, 06 Ju. Listen: https://shows.acast.com/the-cdr-policy-scoop/episodes/what-do-we-need-to-get-right-in-the-cdr-integration-into-the

TL;DR

  • The European Commission is reportedly leaning toward a public authority as intermediary for CDR procurement into the EU ETS — from public statements, not leaks. Significant if it survives co-decision.
  • Carbon Gap’s position: integrate removals below the cap (“one in, one out”) for the first review period, revisit later. Hedges against mitigation deterrence.
  • The “cap reaching zero” premise is shifting — Commission signaled in May that allowances will be issued well into the 2040s under a -90% by 2040 framing.
  • Numbers to watch on 17 July: the 75 Mt central estimate for 2040 removals, a floated 100 Mt figure, and Carbon Gap’s ~21% of ETS emissions analysis.
  • Only direct air carbon capture and storage (DACCS) and bio-CCS expected at launch; the mechanism for adding biochar and enhanced weathering matters more than the initial list. Useful framing.

Eve Tamme hosts Louis Uzor (Policy Director) and Francesca Battersby (Associate Policy Lead) of Carbon Gap on The CDR Policy Scoop, recorded 6 July — eleven days before the Commission’s expected EU Emissions Trading System (ETS) review proposal. It’s a pre-game analysis of how carbon dioxide removal (CDR) gets wired into the world’s largest compliance carbon market.

Two claims stand out. First, the public authority model is apparently the Commission’s preferred scenario, per public statements. Uzor argues it could become “a central home for CDR” — governing credit quality, linking to the Carbon Removal Certification Framework (CRCF), even handling temporary removals outside the ETS. He also makes a practical case for piloting it pre-2030: not for volume, but to work out registry infrastructure and developer access, drawing an apt parallel to Article 6 transactions where “it’s not around the single ton, it’s around getting the whole framework up and running.” The unresolved vintage question — whether a credit bought in 2028 counts in 2032 — is one buyers should track closely.

Second, the below-vs-above-cap debate has a new wrinkle: there may be no zero cap to be above. The Commission’s May signal that allowances will continue into the 2040s (consistent with -90% economy-wide by 2040) means the reference point for “above the cap” is itself undefined. Carbon Gap wants below-the-cap integration “to the extent possible” for the first ~15-year window, precautionary against mitigation deterrence — though Battersby notes the UK has explicitly flagged an eventual switch once CDR supply volumes are predictable enough to inform cap-setting. On the price gap between EU allowances and DACCS/bio-CCS costs, the worst case is integration in name only: market access without top-up support. Options floated include an EU-level Contract for Difference (CfD) — which Battersby says she hasn’t actually heard discussed — mandated member-state ETS revenue recycling, and state aid reform.

For adjacent context: Carbon Gap published its “Integrating CDR into the EU ETS” analysis in June 2025, and Battersby references prior work finding roughly 21% of 2040 EU ETS emissions would need a removal compliance obligation to cover total EU CDR needs. The CRCF discussion is worth noting for method developers — Uzor is candid that DG Clima is starting with CCS-based methods because “it’s more natural to them,” and that CRCF permanence certification won’t automatically confer ETS eligibility. The structured process for admitting biochar and enhanced weathering will land in implementing regulation, not the July proposal.

Most useful for durable CDR developers targeting EU compliance demand, and policy teams who need the pre-proposal state of play before the 17 July text drops.