KSLA Comments on Certification of carbon removals – EU rules

KSLA shares the Commission’s view on the value of integrating carbon sequestration into EU climate policy. We are positive about using innovative solutions to separate, recycle, store carbon dioxide and increase the amount of carbon dioxide in plants in agriculture and forestry through methods for increased growth.


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Initiative: Certification of carbon removals – EU rules
Feedback reference: F3251251
Submitted on: 28 April 2022


KSLA shares the Commission’s view on the value of integrating carbon sequestration into EU climate policy. We are positive about using innovative solutions to separate, recycle, store carbon dioxide and increase the amount of carbon dioxide in plants in agriculture and forestry through methods for increased growth.

The Academy finds it positive that EU is developing a standardized certification system that regulates incorrectly claimed climate benefits. KSLA sees certification as a system with good development potential, even though knowledge is still lacking for a long-term useful certification system based on science.

The proposal mainly points to agriculture’s possibility of carbon storage, but KSLA agrees that forest and marine systems are also mentioned. KSLA believes, however, that it is important that the impact statement clarifies the differences between the different systems. KSLA agrees that agricultural cultivation systems, which result in increased carbon storage, can be a basis for certification. KSLA would like to emphasize, however, that even more knowledge is needed to achieve satisfactory production and good profitability for agriculture, when the mentioned cultivation systems are used, and that geographical differences are considered.

KSLA is currently working on a development project focusing on reduced tillage for increased fertility, biodiversity, and carbon storage. It is important to consider the time perspective in certification systems for agriculture and forestry as the answers may seem completely different as measures that give results in the short term can be counterproductive in the long term.

KSLA believes that it is important that the certification system is built up considering the work that users already do today and that this related to the rules that exist in each country. In addition to carbon dioxide, it is also mentioned that methane and nitrous oxide can be included in the certification system. However, KSLA emphasizes that the measurement of these gases is so complex that it complicates the usefulness of a certification system in the long run. It is important that the financial aspect for users is considered when developing a certification system. It needs to be easy to administer to avoid unnecessary costs.

KSLA is doubtful that the EU itself should work with the practicalities of certification. An alternative is to apply the same solution used by the UN aviation agency ICAO for certification of compensation measures within the aviation’s global climate compensation program CORSIA, i. e. that instead of building its own detailed certification system, it is possible for independent certification programs to, based on a number of basic requirements, to be approved for use under CORSIA – a ”certification of certifications”.

It is important to note that it is the growth (photosynthesis) that creates the opportunities, and that the certification does not reward measures that reduce growth, which will result in a negative climate impact in the long run. It is important that the forest products (substitution) are included because the forest is special as the product (the tree) is also a warehouse. Increasing the stock too much reduces the possibilities for sustainable substitution. KSLA wants to emphasize that the role of the forest in the carbon balance is greater than the agricultural carbon sequestration in the soil. This means that the forest’s function regarding the pursuit of net zero has a greater significance compared with agriculture. The certification should be linked to the products, i. e. that the farmer or forestry gets paid better for the product if they also manage to bind an increased amount of carbon.

KSLA finds it positive that a committee is appointed to work further with possible ways to achieve a long-term stable certification system. KSLA is happy to contribute with science and proven experience in the upcoming work.


To KSLA’s feedback on the internet: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13172-Certification-of-carbon-removals-EU-rules/F3251251_en