Five European carbon dioxide removal associations are pressing the European Commission to harden its EU ETS revision with a binding delivery obligation, arguing the current proposal finances permanent CDR at scale but does not compel anyone to deliver it.

The joint statement comes from DVNE (Germany), NEP (Europe), AFEN (France), NCRA (Denmark, Norway, Sweden, Finland and Iceland) and RIRC (Italy). Together they represent more than 170 companies and organizations across the permanent removals value chain.

The policy trigger is the Commission's July 2026 revision of the EU Emissions Trading System, which opened the way for a European market in permanent carbon dioxide removal. The design of that market now determines whether Europe gets the volumes it needs, the associations argue. Their stated benchmark: 250 million tonnes of permanent CDR delivered by 2040.

How the Commission's mechanism works

Under the proposal, the EU would finance permanent CDR at scale through the ETS for the first time. Between 2031 and 2040, the Commission plans to auction 250 million additional allowances and use the proceeds to procure an equivalent volume of permanent CDR centrally. Annual procurement would ramp up toward 48 million tonnes by 2040.

The associations' core objection is structural. Auctioning 250 million allowances, they point out, creates revenue — not a legal obligation to deliver 250 million tonnes of removals. If the procurement machinery underdelivers, nothing in the current text forces a correction.

The four changes on the table

First, write the 250-million-tonne figure into law as a binding delivery obligation by 2040.

Second, close the CDR funding gap. DVNE proposes making carbon removal eligible for Carbon Contracts for Difference under the proposed Industrial Decarbonization Bank.

Third, sign long-term offtake agreements no later than 2029.

Fourth, allow ETS operators to purchase permanent CDR directly.

The associations frame CDR integration into the ETS as a potential game-changer for European industry, and they lay out the full reasoning behind the four changes in the detailed statement.

What to track

The numbers are large and the calendar is tight. Auctions begin in 2031 under the proposal. Long-term offtake agreements would need to be executed by 2029 — two years before the first auctioned allowance funds a tonne of removal — to give project developers the bankability to build storage and mineralization capacity at the pace the 2040 target implies. An average of roughly 28 million tonnes per year across the 2031–2040 window, rising to 48 million tonnes annually at the end, would demand a procurement pipeline far beyond anything the EU has operated to date.

The decision point is legislative. The European Parliament and Council must now amend — or decline to amend — the ETS revision. Whether the 250-million-tonne figure becomes a delivery obligation written into law, and whether Carbon Contracts for Difference open to removals under the Industrial Decarbonization Bank, will determine whether the Commission's market design converts auction revenue into verified tonnes in the ground.