A new Article 9c turns the European Commission into a central buyer of permanent removals — a 250 Mt, price-supported demand signal for BioCCS and DACCS over 2031–2040. Here is the mechanism, the money, and the market it creates.
The EU Emissions Trading System has always been a market for emissions. With the 17 July 2026 review, it becomes — for the first time — a buyer of carbon removals. A new Article 9c instructs the European Commission to purchase permanent, engineered removals and fold them into the cap, turning residual emission space for the hardest-to-abate sectors into a guaranteed, publicly-funded demand signal for the removals industry.
Only two removal types qualify at the outset: bioenergy with carbon capture and storage (BioCCS) and direct air capture with storage (DACCS), each certified under the EU’s carbon-removal certification framework, Regulation (EU) 2024/3012 (the CRCF). Temporary and nature-based removals are, for now, left outside the ETS.
The design is deliberately indirect, to protect the price signal. Rather than letting operators surrender removal credits against their emissions, the Commission buys centrally:
| Step | What happens |
|---|---|
| 1. Raise the cap | +250 million allowances over 2031–2040; the linear reduction factor does not apply to them. |
| 2. Auction | The Commission auctions those allowances; the revenue is external assigned funding. |
| 3. Buy removals | It buys an equivalent 250 Mt of CRCF-certified BioCCS and DACCS units — pay-on-delivery, cost-effective, high-integrity portfolio. |
| 4. Cancel | The units are cancelled — no re-sale, no re-use, no double counting. |
Worth remembering
The result is a net target: gross emissions minus the removals bought. Operators keep trading only EU allowances; the removals sit behind the cap. A further 10 million allowances are reserved to cover the price gap, and auctioning ramps to roughly 48 million in 2040.
The volume is fixed by the regulation: 250 Mt of permanent removals over 2031–2040, scaling to a ~48 Mt-per-year run-rate by 2040, plus the 10 Mt buffer. The value is not fixed — it depends on where BioCCS and DACCS prices land.
| Blended removal price | 250 Mt programme (2031–40) | ~48 Mt/yr by 2040 |
|---|---|---|
| €150/t | ≈ €38 bn | ≈ €7 bn/yr |
| €250/t | ≈ €63 bn | ≈ €12 bn/yr |
| €350/t | ≈ €88 bn | ≈ €17 bn/yr |
In short: a €38–88 billion cumulative procurement this decade, or roughly €7–17 billion a year of removal buying by the end of the 2030s.
We help developers structure CRCF-certified supply and model the ETS, voluntary and Industrial Decarbonisation Bank demand channels.
Crucially, the programme is self-funded: the Commission buys removals only with the proceeds of auctioning the set-aside allowances (250 Mt, plus up to 10 Mt more if needed) — recycled EU ETS revenue, not new money. So what is fixed is the volume (a 250 Mt target and a defined allowance envelope); the euros float with the EUA price across the decade.
That creates a structural tension. Auctioning ~260 Mt at today’s ~€80 EUA price raises only about €21 billion — well short of the €38–88 billion that 250 Mt of removals would cost. The +10 Mt buffer adds barely 4% more revenue, so the arithmetic only closes if EUA prices climb toward removal costs through the 2030s (a tightening cap points that way) and DACCS costs fall as it scales.
The budget, not the target, is the binding limit
If that convergence doesn’t materialise, the Commission can’t spend money it hasn’t raised — and with an explicit mandate to “limit fiscal exposure” and pay on delivery, the volume it actually buys flexes down to whatever the auction revenue affords. The 250 Mt is the nominal target; the recycled allowance revenue is the real ceiling.
There is one route for operators to touch removals directly. Under Article 14(1a), an operator, shipping company or aircraft operator that generates its own CRCF-certified BioCCS can use it to compensate its own fossil emissions — but only down to zero. It cannot create negative emissions, and it cannot mint tradable allowances. Every tonne used this way is cancelled and reduces the Commission’s purchase pool one-for-one. So a BioCCS generator has a genuine choice for each tonne: self-use it, sell it to the Commission’s programme, or sell it into the voluntary market — but never more than once.
The initial design is, in effect, a monopsony — one public buyer, buying and retiring. That is a deliberate transitional choice for a novel instrument, but the proposal writes in an exit. Before 31 December 2034, the Commission must report on removal supply and prices and assess whether to transition “from an integration managed by the Commission towards a direct integration by operators, beyond own use” — i.e. whether to let operators buy and surrender removal units themselves. The same review will weigh bringing in nature-based and carbon-farming removals. That 2034 review is the moment the addressable buyer base could widen from one to thousands.
The Commission’s 250 Mt programme is the compliance-backed anchor, but not the EU’s only demand channel. The Industrial Decarbonisation Bank — €100 billion from 2028, with a 2028–2031 ‘Investment Booster’ reserving 400 million allowances — funds industrial decarbonisation that can also generate permanent removals, and the Innovation Fund continues to back first-of-a-kind capture. Running alongside is the voluntary market, where corporates buy CRCF-grade durable removals, often at a premium to a cost-minimising public tender. For a developer, the real task is portfolio construction: which tonnes go to the Commission, which to voluntary buyers, and which to self-use.
The take
For BioCCS and DACCS developers in Europe, this is the most concrete demand signal yet — a sovereign buyer, a defined 250 Mt, and payment on delivery. But it is quality-gated by CRCF certification and cost-disciplined by design: a competitive procurement, not a feed-in tariff. The winners will prove permanence and deliver at a price that survives a Commission mandated to limit fiscal exposure. The bigger prize is Phase 2 — if the 2034 review opens direct operator purchasing, the removals market inside the ETS stops being one buyer and becomes the whole compliance sector.
Primary sources for the figures and rules cited above.
From removals positioning to CRCF certification and the voluntary-market interplay, Climate Decode helps developers and buyers navigate the new EU removals market.
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