The review of the EU ETS presents our best opportunity to act on CDR, creating the demand driver that Europe’s nascent CDR industry needs whilst delivering on the industrial transition.
To achieve this, the NCRA supports integrating permanent, high-quality CDR credits into the ETS as soon as possible, with 2030 as a target date and a pre-compliance phase beginning before then. Integration must serve to scale the European CDR industry, whilst preserving the ability of the ETS to incentivize continued emission reductions.
Integration eligibility should be based on CRCF as the quality gateway, and the proposal should come with a clear mechanism to fund purchases of significant volumes of high-quality carbon removals. The ETS cap should remain ambitious – CDR should complement emissions reductions, not act as a substitute for them.
The NCRA is open to different approaches, including direct or indirect integration of CDR in the ETS, as long as the chosen model sends a strong, long-term market signal that unlocks private investment at scale. Indirect linkage is preferred, since it would provide clarity on expected volumes, procurement criteria, and available funding to market participants ahead of time. Voluntary early action by ETS operators should be encouraged, with purchases counting toward future compliance obligations without issuing new allowances or undermining the cap.
The full NCRA position on the EU ETS is available here: Nordic Carbon Removal Association ETS Position – Strengthening the ETS and building the European carbon removal industry – January 2026 Final