Take on a podcast episode from The CDR Policy Scoop, originally published Mon, 27 Ju. Listen: https://shows.acast.com/the-cdr-policy-scoop/episodes/the-eu-ets-scoop-verdict-our-honest-take-on-brussels-proposa

TL;DR

  • Eve Tamme and Sebastian Manhart disagree on whether the EU ETS removals proposal is a compliance market or a purchasing programme funded by one. The distinction shapes everything downstream.
  • The cost assumptions look broken: €38/t transport and storage for bioenergy with carbon capture and storage (BECCS), €18/t for direct air capture (DAC). Developers privately say off by 2x+.
  • The 250 Mt figure: Commission says target, proposal text reads more like an auction commitment. The rapporteurs will have to nail this down.
  • Contingency asymmetry: non-delivered removals after allowances are auctioned have no backstop — unlike international credits, which trigger linear reduction factor adjustment.
  • Biochar praised in the impact assessment, absent from the proposal. Nature-based solutions got a review clause; biochar didn’t.

Eve Tamme and Sebastian Manhart use this debrief episode of The CDR Policy Scoop to say what they couldn’t in their earlier interview with the Commission’s Mette Quinn: their unfiltered read of Brussels’ proposal to bring carbon removals into the EU Emissions Trading System (ETS). It’s two policy insiders arguing productively, which is more useful than either of their LinkedIn posts alone.

The most consequential segment is Manhart’s teardown of the impact assessment’s cost modeling. The BECCS numbers rest on a 2025 Ramboll study (which only runs to 2035 and used subsidized costs sourced partly from CDR.fyi) plus the NeGEM expert elicitation — yielding transport and storage assumptions of €38/t for BECCS and €18/t for DAC. Manhart put these to Europe’s largest BioCCS developers in a room last week and got silence; off the record, they say the figures are off by a factor of two, but reverse-auction competition means nobody will publish corrected numbers. Tamme, wearing her carbon management hat, concurs: “at least a factor of two.” His framing of the stakes is right: 10-20% error is noise, 100-150% error changes whether the mechanism functions at all. Biochar gets the inverse treatment — global commodity prices imported into a European industrial context, producing €37-60/t assumptions well below the cutoff where operators would rather sell into non-CDR uses.

The second load-bearing issue is delivery risk architecture. Tamme flags a genuine gap: if international credits go unpurchased in 2033, the linear reduction factor tightens automatically. But if allowances are auctioned for removals that then fail to deliver, there’s no equivalent backstop. Layer on the impact assessment’s floated 25% upfront payment for offtakes and unknown future carbon prices, and “who takes the risk” is an open question the September offtake-structuring guidance needs to answer. There’s also the arithmetic problem: a 48 Mt auction target in 2039 doesn’t square with 250 Mt of removals delivered by decade’s end, whatever the Commission’s stated intent. And per Robert Höglund’s observation, this is arguably the first major policy treating permanent removals as functionally equivalent to reductions — a break from SBTi-style separation that could ripple into other frameworks.

For prior context, the interview with Mette Quinn on this same feed is the primary source this episode annotates; Peter Liese (EPP rapporteur) has already signaled biochar amendments are coming, and Manhart promises a deeper published teardown of the cost assumptions in coming weeks — worth watching for.

If you’re a durable CDR supplier modeling EU ETS revenue, or a buyer wondering whether voluntary market demand survives this proposal (Tamme’s answer: yes, for years), the hour pays for itself.