Policy Analysis · Part 2 of 2
Carbon Removals · CCS EU CRCF · Clean Fuels Analysis · October 2026

Canada as a Global Hub for Carbon Removals

Canada has the geology, wells and clean power to produce durable removals at scale while Europe has the demand, and Article 6 can connect the two provided that Ottawa writes the authorization rules and the EU opens its certification framework to recognized third-country storage.

By Vaibhav Jain · Managing Director, Climate Decode · · 9 min read

REMOVALS · SUPPLY VS. DEMAND Mt CO₂ 0.1REMOVED 11.9IN PIPELINE ~25EU / YEAR Canada today vs. EU purchase (250 Mt over 2031–2040) SASKATCHEWAN STORAGE >150 Gt Carbon Removal Canada FIRST CERTIFIED DAC JUNE 2026 Deep Sky Alpha · Alberta EU DOOR FOR CANADA NOT YET OPEN CRCF · Article 6 from 2036 STORAGE IN CANADA · DEMAND IN EUROPE

At a Glance · Where Things Stand

Canada’s edge

STORAGE & SKILLS

Canada combines storage geology, an oil and gas injection workforce, clean power and biomass, and issued North America’s first certified direct air capture credits.

EU demand

250 Mt + 260 Mt

The EU ETS proposal would buy 250 Mt of certified removals over 2031–2040 and up to 260 Mt of Article 6 credits over 2036–2040.

EU eligibility

NOT YET ELIGIBLE

EU removal purchases require CRCF certification, which keeps units out of third countries’ targets, so that Canada needs recognition or the 2036 Article 6 window.

Our View

Of the activities within scope of ECCC’s Article 6 framework, durable removals are those in which Canada has the clearest advantage as a seller, Canada authorizing the transfer and applying a corresponding adjustment so that the buyer, and not Canada, claims the removal.

The EU has proposed to purchase 250 Mt of permanent removals and up to 260 Mt of Article 6 credits over the next decade, while Europe’s own storage build-out is still at an early stage. The opportunity depends on Ottawa settling which tonnes it will authorize for export, how they stack with the Clean Fuel Regulations, and how Canadian storage is recognized under the EU’s certification rules, the policy groundwork and the 2035 target question being set out in Part 1.

1

Removal Capacity

Canada’s case as a removals exporter rests on geology, skills, power, fiscal support and delivered tonnes that other countries cannot easily replicate, as set out in Table 1.

AdvantageEvidence
Storage geologyDeep saline formations across the Western Canada Sedimentary Basin; Saskatchewan alone is credited with more than 150 billion tonnes of storage capacity. Alberta has selected 24 storage hub proposals (6 in the Industrial Heartland, 18 elsewhere) for evaluation.
Injection experienceDecades of CO₂ injection, monitoring and well work from oil and gas, and operating CCS projects in Alberta and Saskatchewan.
Clean power and biomassLow-carbon grids in several provinces for energy-hungry direct air capture, and forestry and agricultural residues for BECCS and biochar.
Fiscal supportFederal investment tax credits of 50% for capture equipment and 37.5% for transport and storage, extended through 2035 under the July 2026 Pathways agreement.
First delivered tonnesDeep Sky Alpha in Innisfail, Alberta delivered North America’s first certified direct air capture removal credits in June 2026, verified by Isometric, with Microsoft and RBC among buyers.

Table 1 · Canada’s removal advantages. Sources: Carbon Removal Canada via Climate Tech Canada; Government of Alberta; Pathways agreement reporting; Deep Sky.

Carbon Removal Canada’s tracker recorded about 101,000 tonnes removed to date against 11.9 Mt of projects in development in September 2025, and an estimated 35 Mt needed to meet Canada’s climate goals, so that the gap between promise and delivery remains wide. Early offtakes, such as those of Microsoft and RBC with Deep Sky, are voluntary-market purchases, and Article 6 offers the route by which that pipeline can reach compliance-grade, government-backed demand.

Canada’s Removal Pipeline vs. Need (Mt CO₂) Removed to date0.1 Mt In development11.9 Mt Needed for climate goals ~35 Mt

Figure 1 · Canadian carbon removal, removed to date versus projects in development and estimated need. Source: Carbon Removal Canada data via Climate Tech Canada, September 2025.

Recommended sequence

  • The authorization list should begin with durable, geologically stored removals (DACCS and BECCS), where Canada’s advantage is greatest and the integrity case is most straightforward.
  • A host-country share should be published, setting out how much of each project’s output may be exported and how much is retained for the 2035 target, since an authorized removal counts toward the buyer’s target and not Canada’s, and such a rule gives developers certainty while protecting the NDC.
  • The registry and MRV should be built now, since buyers will not sign forward offtakes against a framework without a registry, and Japan’s lead under its Joint Crediting Mechanism came from building this infrastructure first.
  • Host agreements should be signed with the active buyers, Singapore, Japan, Switzerland and South Korea already purchasing and the EU becoming a major buyer from 2031 for removals and from 2036 for Article 6 credits.

Every authorized export also bears on Canada’s own 2035 target, which current projections do not reach, and that tension, together with the reasons the export case still holds, is set out in Part 1: Canada’s Article 6 framework.

Climate Decode advises Canadian removal, CCS and low-carbon fuel developers on which Article 6 buyers fit a project and what authorization will require.

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2

EU Demand, CRCF and Storage

Under the July 17, 2026 EU ETS review proposal, the Commission would raise the cap by an initial 250 million allowances, auctioned over 2031–2040, and use the revenue to purchase an equivalent volume of permanent removals, which are the kind of removals Canada is best placed to produce. Only BioCCS and DACCS qualify at the outset, both requiring certification under the EU’s Carbon Removals and Carbon Farming Regulation, Regulation (EU) 2024/3012 (the CRCF), and the Commission adopted the CRCF certification methods for DACCS, BioCCS and biochar on February 3, 2026, as examined in the Climate Decode analysis of the EU ETS removals mechanism.

Third-country eligibility

The CRCF provides that certified units should not count toward third countries’ NDCs or international compliance schemes, and the ETS proposal, as summarized by ICAP, does not address third-country removals, so that Canadian removals cannot enter the EU purchase at present. Some legal readings expect any opening to be tied to countries with an ETS linked to the EU’s, a route better suited to the UK than to Canada, while the separate Article 6 window is open to international credits only from 2036.

Storage availability

Europe’s injection capacity is still being built against the Net-Zero Industry Act’s goal of 50 Mt a year of CO₂ storage capacity by 2030, and much of that capacity will be taken by industrial CCS before removals. By contrast, Canada has storage in operation and in evaluation, the well-drilling and injection workforce of a major oil and gas producer, and provincial regimes that already regulate long-term storage liability, and since shipping CO₂ across the Atlantic is impractical, the trade would be in certified tonnes.

The EU’s Removal and Article 6 Demand, 2026–2040 20262028203020322034203620382040 CRCF methods (Feb 2026) ETS proposal (Jul 2026) Union CRCF registry Commission report −90% target 250 Mt BioCCS + DACCS removals bought centrally (CRCF) Up to 260 Mt Article 6 Removal purchases open to EU-certified (CRCF) units; the Article 6 window is the route open to Canadian tonnes today.

Figure 2 · EU demand for removals and Article 6 credits. Sources: EU ETS review proposal (July 2026) via ICAP and EPRS; CRCF Regulation (EU) 2024/3012; Carbon Gap; Taylor Wessing.

Path for Canadian removals into EU demandWhat it requiresTiming
Article 6 credit windowCanada authorizes removal ITMOs with corresponding adjustments; tonnes meet the EU’s still-to-be-written quality criteriaPurchases from 2036
CRCF recognition of Canadian storageAn EU–Canada arrangement that recognizes provincial storage regimes as equivalent on monitoring, reversal liability and permanenceNegotiable now; the Commission reports on the removals mechanism by end-2034
Deeper carbon market cooperationBuilds on the 2023 EU–Canada Green Alliance and both parties’ membership of the Open Coalition on Compliance Carbon Markets launched at COP30Ongoing

Table 2 · Routes into EU removal demand. Sources: EU ETS review proposal (July 2026), ICAP, CRCF, COP30 Presidency; Climate Decode analysis.

EU arrangement

Canada’s request in any EU arrangement should be narrow and technical, covering recognition of Canadian geological storage and its monitoring and liability rules as equivalent under the CRCF, and an agreed Article 6 authorization template for removals sold into the EU’s 2036 window, since storage and well availability are the scarce input in Europe’s removal plan.

3

Clean Fuels

The most bankable removal tonnes in Canada are likely to come from biogenic CO₂ that is already being separated, namely fermentation CO₂ from ethanol plants and process CO₂ from renewable natural gas upgrading, renewable diesel, SAF and biogenic hydrogen. Capturing and storing that CO₂ costs less than direct air capture, and it corresponds to the BioCCS pathway that the EU proposes to purchase from the outset.

These plants already fall within the Clean Fuel Regulations, under which CCS added to low-carbon fuel production lowers the fuel’s lifecycle carbon intensity, potentially below zero, and generates Compliance Category 2 credits, while CCS on fossil fuel production earns Category 1 credits; CFR credits traded at an average of $358.18 in June 2026. The CFR does not reward a standalone removal tonne, such as a DAC credit, which has no fuel to attach to, and the pathways are set out in the Climate Decode CFR and CCS guide.

Article 6 and clean fuel economics

  • A biofuel plant with CCS could earn CFR credits on its fuel and, if Ottawa allows it, sell an authorized removal unit to a foreign buyer, and that second revenue line is what could turn marginal CCS retrofits on ethanol and RNG plants into financeable projects.
  • CCS lowers the carbon intensity of fuels destined for markets with their own standards, from SAF for CORSIA-covered airlines to fuels sold into Europe.
  • Biogenic CO₂ volumes help fill the storage hubs being developed in Alberta and Saskatchewan, reducing per-tonne storage costs for every user.
Stacking rule

Whether the same stored tonne can lower a fuel’s CFR carbon intensity and also be sold abroad as an adjusted removal remains undecided, and since buyers will reject anything resembling double claiming and an exported removal belongs to the buyer’s target, a clear stacking rule is required. Splitting the fuel attribute from the removal attribute, or capping the exportable share, are two possible designs, and settling the question would be the most useful single step the framework could take for clean fuel developers.

Fuels Market Watch

The benchmark review, provincial offset rules and Article 6 authorization will move on different timelines, and Fuels Market Watch, Climate Decode’s market intelligence platform, follows both the compliance and the clean fuel side in one place.

Fuels Market Watch • Compliance
Canadian carbon markets

The Ontario EPS supply, demand and price outlook is live today, together with compliance updates across Canada’s provincial systems and the federal benchmark review.

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Fuels Market Watch • Fuels
North American clean fuels

Canada CFR and BC LCFS credit market outlooks are live today for obligated suppliers and credit developers, with US low-carbon fuel programs to follow.

Open Market Watch →

A guided walkthrough can be arranged by booking a demo.

4

Outlook to 2027

  • ECCC’s authorization list will show whether durable, geologically stored removals come first and what host-country share Canada retains.
  • Parliament and Council will decide in the EU ETS negotiation whether the 250 Mt removals purchase remains domestic or opens to recognized third-country storage.
  • A CFR stacking rule will determine whether a stored tonne can lower a fuel’s carbon intensity and also be sold abroad as a removal.
  • Singapore’s second-stage tender, for at least 12 million ITMOs with carbon removal eligible, will be an early test of whether removal projects can compete in a sovereign tender.
  • Alberta’s storage hubs will show which of the 24 proposals move from evaluation to sequestration agreements, and how much capacity they make available to removal projects.

Canada has its first certified removal tonnes in geological storage and a buyer in Europe designing its purchases, and whether this becomes an export industry depends on the authorization, stacking and storage-recognition rules written over the next year.

Part 1 of 2
Canada’s Article 6 Framework: Provinces, Buyers and the 2035 Target

The ECCC announcement, the provincial role on offsets, the operation of Swiss, Singapore and Japanese buyers, and the distance between Canada and its 2035 target.

Read Part 1 →

Climate Decode · Advisory

Positioning Canadian projects for Article 6 demand

Climate Decode supports buyer mapping, authorization readiness, and CRCF and CFR stacking from start to finish.

Fuels Market Watch • Compliance
Every compliance market, one screen
Compliance Market Watch — Ontario EPS and India CCTS live, North America next week.
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About the Author

Vaibhav Jain — Managing Director, Climate Decode

Vaibhav Jain

Managing Director, Climate Decode

12+ years in carbon markets and climate finance across four continents. Leads the Canopy product and aligned advisory services in corporate sustainability. 79+ projects delivered across 25 countries. Formerly South Pole · Yes Bank · PwC.

Speak to Vaibhav → Meet the team →

© 2026 Climate Decode · Policy Analysis · Reference CD-CCP-A6-2026

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