On June 16, 2026, ChrysaLabs joined ISCIA and more than 50 organisations across the carbon farming ecosystem in an open letter to the European Commission. The message: a certification framework is not a market, and the EU needs to build the demand side of CRCF before the supply side outruns it.
Here is the gap we are naming, why it matters, and what we are asking the Commission to do about it.
Why CRCF matters
The Carbon Removals and Carbon Farming Regulation (CRCF) is one of the only regulatory frameworks anywhere in the world built specifically to certify carbon farming outcomes: soil carbon, agroforestry, improved land management, and other practices that pull carbon out of the atmosphere and keep it there. For project developers, registries, and the farmers and land managers who do the actual work, CRCF promised something the carbon market badly needed: a common, auditable bar for what counts as a real, durable tonne.
That bar matters. It is also not, by itself, a market. A certification framework tells a buyer that a tonne is real. It says nothing about whether a buyer exists.
The gap: supply is outrunning demand
European supply of CRCF-eligible carbon farming units is projected to exceed 10 Mt CO2e per year by 2028. The Commission’s own Buyers’ Club, a useful first step toward building demand, is aiming for an offtake target of only 1 to 2 Mt CO2e by 2030.
That is not a rounding error. It is a market being asked to certify itself into existence with no one lined up to buy most of what it certifies. More than 20,000 farmers and land managers have already begun transitioning their practices under CRCF-aligned programmes, often on the expectation that certification translates into revenue. If the demand side does not catch up, that expectation breaks.
The 18-month window
Three legislative reviews converge over the next year and a half, and together they will decide whether CRCF gets a real role in compliance markets or stays a credential nobody activates:
- The Article 18 review of the CRCF Regulation, due by 31 July 2026
- The Q4 2026 revision of the LULUCF and Effort Sharing Regulations
- The EU ETS Phase 5 review
Each of these reviews touches a different lever the Commission could pull. Taken together, they are the only window in sight to connect a certification standard to an actual source of demand.
What we asked the Commission to do
The letter sets out five concrete asks:
- Recognise high-integrity CRCF units as effectively permanent, so buyers and registries are not stuck managing risk the certification process was supposed to have already resolved.
- Give CRCF a defined role in EU ETS compliance, so certified units have a clear path into the bloc’s largest carbon pricing mechanism.
- Connect CRCF to LULUCF and Effort Sharing flexibility, linking land-sector outcomes to the targets that already govern member states’ climate obligations.
- Open the door in national carbon tax flexibilities, sectoral offsetting, and public procurement, so demand can build at the member-state level as well as the EU level.
- Issue clear operational claims guidance, covering both inset and offset use cases, so buyers know what they are actually allowed to say once they hold a certified unit.
None of these asks change what CRCF certifies. They change whether anyone has a reason to buy it.
Why ChrysaLabs signed
ChrysaLabs works on the integrity side of this industry: measurement, monitoring, and the registries that make a tonne defensible to an auditor. That work is necessary, but it answers an auditor’s question, not a farmer’s question. The gap between those two questions is where developers start cutting corners on measurement, and where farmers transition their practices on a promise that never shows up as revenue.
“I spend most of my days looking at data that has to satisfy an auditor,” says Laurence Pelletier, ChrysaLabs’ Sustainable & Carbon Manager and the company’s representative on the ISCIA board. “Signing this letter was about the other half of the problem: making sure that data leads somewhere.”
What to watch next
- 31 July 2026: deadline for the Article 18 review of the CRCF Regulation
- Q4 2026: expected revision of the LULUCF and Effort Sharing Regulations
- Ongoing through 2026: EU ETS Phase 5 review
We will keep tracking each of these as they move, and sharing what they mean for developers, registries, and buyers in this space.
