Take on a podcast episode from The CDR Policy Scoop, originally published Wed, 22 Ju. Listen: https://shows.acast.com/the-cdr-policy-scoop/episodes/removals-enters-the-eu-ets-what-brussels-actually-proposes-w

TL;DR

  • The European Commission confirms a commitment to buy 250 Mt of permanent, domestic removals (bioenergy with carbon capture / direct air capture) for the EU Emissions Trading System — with a 2034 review clause.
  • Commission cost modeling assumes no national subsidies layered on top. Given Nordic BECCS economics today, that looks optimistic.
  • ETS operators can use certified removals for their own compliance from 2031 — no volume cap beyond deduction from the 250 Mt.
  • Pay-on-delivery is the default, but Quinn signals openness to prepayment and offtake structures via Innovation/Modernisation Fund mechanics. Details unwritten.
  • Commission’s own supply projection: ~48 Mt/year by 2040. The gap to the headline target is the real story.

Eve Tamme and Sebastian Manhart got Mette Quinn — Deputy Director for Carbon Markets and Clean Mobility at DG CLIMA, and the official who led the ETS revision — on The CDR Policy Scoop five days after the Commission published the proposal. This is the closest thing to primary-source commentary you’ll get on the removals provisions right now.

The headline is settled: Quinn confirms the 250 Mt is a purchase promise, not an aspiration — funded by auctioning matching allowances plus a “top-up” reserve to bridge the gap between removal costs and the EU Allowance (EUA) price, with the review clause triggering in 2034 if volumes don’t materialize. The purchasing facility will run something like carbon contracts for difference, with bidding on deliverable price. Two design details matter for developers: compliance use of Carbon Removal Certification Framework (CRCF)-certified removals opens immediately in 2031 with no separate volume cap, and the facility can’t commit funds before 2031 either — so nothing here de-risks a final investment decision taken in 2027.

The two exchanges worth your hour: first, Manhart presses on whether the Commission’s cost projections implicitly assume member-state subsidies (the mechanism that makes current Nordic BECCS prices work for corporate buyers). Quinn’s answer — “we have certainly not taken extra subsidies into account” — means the modeling assumes technology costs alone converge toward EUA parity “somewhere after ‘35.” That’s a load-bearing assumption with thin evidence behind it. Second, the supply math: Tamme cites realistic EU supply of ~4 Mt/year by 2030 rising to 15–25 Mt around 2035; Quinn volunteers the Commission’s own figure of 48 Mt in 2040. Neither trajectory obviously reaches 250 Mt cumulative on schedule, which is presumably why the review clause exists. On technology mix, Quinn is blunt: ~90% BECCS, no other pathways currently envisaged, with CRCF certification as the future gateway for anything else. Direct air capture is explicitly expected to stay above the carbon price through the 2030s.

For context: this proposal effectively creates the first compliance-market demand floor for durable removals anywhere, and it lands while the voluntary market — Frontier-style offtakes, Microsoft’s BECCS deals — remains the only functioning revenue source for European projects. Quinn openly acknowledges the facility will “have to see how we can compete with the VCM,” and Tamme’s warning is sharp: a strict pay-on-delivery model would push developers back to voluntary buyers, since BECCS today doesn’t finance on delivery-only terms. Also flagged: a separate November proposal on international credits (up to 260 Mt, assessment gate in 2033, use from 2036).

Useful for anyone building or financing European BECCS/direct air carbon capture and storage (DACCS) supply, or modeling post-2030 compliance demand — this is the primary source, lightly filtered.