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The CDR Policy Scoop
SHOWDOWN: Corresponding Adjustments: Necessary or Overkill?
CDR Policy Scoop is back with our next SHOWDOWN, this time on one of the hottest fault lines in carbon markets: should voluntary offsetting require corresponding adjustments?
As Article 6 implementation moves forward, the Voluntary Carbon Market (VCM) faces a pivotal question: are corresponding adjustments NECESSARY for integrity, or OVERKILL, creating a constraint that could choke much‑needed finance for mitigation and removals?
There's a clear rule that corresponding adjustments are required for CORSIA compliance and when credits count toward another country’s NDC, but should that same bar apply when companies use credits for offsetting and net-zero claims?
In the “Necessary” Corner: Olga Gassan‑zade, former chair of the Paris Agreement’s Article 6.4 Supervisory Body and leading expert on carbon markets and international climate policy, arguing that corresponding adjustments are needed to avoid double counting and align the VCM with the Paris Agreement.
In the “Overkill” Corner: Johan Börje from Stockholm Exergi, who very successfully convinced buyers that finance stacking without corresponding adjustments is essential right now. He brings the perspective of a pioneering CDR project developer focused on scaling real‑world removals within evolving policy and market frameworks.
Our co-hosts turned moderators, Eve Tamme and Sebastian Manhart, will keep the conversation sharp, grounded, and accessible: cutting through the jargon and focusing on what this really means for buyers, projects, and host countries.
(Disclaimer: Both guests and moderators are speaking in a personal capacity and their views do not represent those of their respective organisations.)
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91. The EU ETS Proposal: the Scoop’s Debrief
26:26||Season 1, Ep. 91In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart follow up on their interview with Mette Quinn to hash out their own read of Brussels' proposal to fold carbon removals into the EU ETS, and they don't agree on much. Is this really a "compliance market," or a purchasing programme that happens to sit on the ETS cap? Eve and Sebastian take opposing sides, and the answer matters more than semantics: it shapes how the whole mechanism should be judged.The cost assumptions get the roughest treatment. Sebastian has spent the past week stress-testing the BioCCS and DAC numbers behind the impact assessment, and he's not convinced. The transport and storage figures look wildly optimistic against what he's hearing from Europe's biggest BioCCS developers off the record. Biochar comes off worse still: favourably discussed in the impact assessment, then dropped entirely from the actual proposal, with nature-based solutions getting an explicit review clause that biochar never received.Timing is the other flashpoint. A 250 million ton removals commitment sounds decisive, until you line it up against a 48 million ton auctioning target for 2039 and realise the years don't match. Add in unresolved questions about who eats the risk on non-delivered offtakes or a shifting carbon price, and the "who pays" question stops being hypothetical.They close on supply: will a demand signal alone be enough to pull removals out of the Global South, or will an undersupplied market let developers simply triage toward whoever pays most? Robert Höglund's observation that this may be the first major EU proposal to treat permanent removals as functionally equivalent to reductions gets a nod too, a precedent Eve and Sebastian both think could ripple well beyond the ETS.Show notes:Eve Tamme: LinkedIn and WebsiteSebastian Manhart: LinkedIn and WebsiteRemovals Enters the EU ETS — with Mette QuinnEU ETS revision proposal
90. Removals Enter the EU ETS: What Brussels Actually Proposes - with Mette Quinn
26:44||Season 1, Ep. 90In this episode of The CDR Policy Scoop, Eve Tamme and Sebastian Manhart sit down with Mette Quinn, Deputy Director for Carbon Markets and Clean Mobility at the European Commission, days after Brussels published its proposal to fold carbon removals into the EU Emissions Trading System. Quinn confirms the number the sector has been debating since Friday: a commitment to buy 250 million tons of permanent, domestically produced removals through BioCCS and direct air capture, funded by auctioning matching allowances plus a top up reserve, with a review clause for 2034 if the volumes do not materialize.Eve and Sebastian press Quinn on the mechanics behind that figure, from the price gap between today's BioCCS costs and the EU allowance price, to whether national subsidies were built into the Commission's cost modeling, which Quinn confirms they were not. They also test the supply pipeline: Quinn's own estimate of close to 48 million tons by 2040 sits close to Eve's independent projection, though still short of the full 250 million target.The conversation covers how the scheme will work for project developers, including the paid on delivery model Quinn says the Commission is exploring softening through prepayment and Innovation and Modernization Fund financing, and the proposal's heavy reliance on BioCCS while direct air capture remains less cost competitive. Quinn is candid that no other technology pathway is currently envisaged, though the Carbon Removal Certification Framework leaves room for that to change.Quinn closes by drawing a sharp line between domestic removals, where funding is committed now with a 2034 review, and international credits, where a 2033 assessment will decide whether purchases continue at all, a distinction she ties to environmental integrity and the Commission's confidence in each pathway.LinksEve Tamme: LinkedIn and WebsiteSebastian Manhart: LinkedIn and WebsiteMette Quinn: LinkedInEU ETS revision proposal
89. Inside the Fight to Save $600 Million for DAC - with Vikrum Aiyer
31:36||Season 1, Ep. 89In this episode of The CDR Policy Scoop, Sebastian Manhart sits down solo with Vikrum Aiyer, Head of Global Energy and Policy and Climate Policy and External Affairs at Heirloom, to trace the last eighteen months of US carbon removal policy. It starts with a survival story: Heirloom and partner Climeworks were awarded roughly 600 million dollars for a Louisiana direct air capture hub under the bipartisan infrastructure law, funding that looked shaky the moment the Trump administration began reviewing Biden era spending. Vikrum explains how a coalition of economic development groups, workforce organizations, and elected officials kept the project alive by leading with jobs, exports, and energy security rather than climate targets.The conversation turns to 45Q, the tax credit that pays up to 180 dollars per ton for durable removal. Vikrum details how a shift in EPA greenhouse gas reporting policy left the credit's verification framework in a temporary gap, with a Treasury safe harbor expiring and a new reporting structure still being negotiated alongside the Carbon Capture Coalition and industry peers. He credits the One Big Beautiful Bill Act with not just protecting 45Q but expanding its reach across more carbon management pathways.Sebastian and Vikrum close on California, where the state's cap and trade extension folded in an 85 million dollar annual pot for decarbonization technologies, including CDR, and wrote CDR integration into statute for the first time. Vikrum lays out the live debate over whether emitters should invest directly in removal project capex or whether those dollars should flow to communities instead, and argues the market needs both credit purchases and direct investment to hit the scale carbon removal requires.LinksSebastian Manhart: LinkedIn and WebsiteVikrum Aiyer: LinkedInHeirloom: Website
88. Buffer Pools Aren't Enough: The Case for Contracted Durability - with Luke Pritchard
28:48||Season 1, Ep. 88In this episode, Eve Tamme digs into contracted durability with Luke Pritchard, Director at Beyond Alliance, a coalition of major carbon dioxide removal buyers.Last month, Beyond Alliance published a white paper with RMI and the American Forest Foundation, developed with input from both engineered and nature based CDR developers, setting out what contracted durability could look like and how it fits into the wider policy landscape.The conversation opens on why durability has stayed unresolved for so long. Luke explains that setting the threshold too low leaves open questions about who holds liability after the monitoring period ends, while setting it too high, without a mechanism like a permanence trust or horizontal stacking, locks nature based solutions out of the market entirely. Buffer pools and insurance, he argues, were never built to guarantee the long duration outcomes that durability requires on their own.Eve and Luke get into what a permanence trust would actually cost, with Luke citing anecdotal buyer estimates of around 15 percent on top of the credit price, and the tension this creates: cheaper nature based credits paired with contracted durability could pull demand away from engineered removals unless separate price support policy exists. They also map contracted durability against the live policy moments where it could land next, from the Paris Agreement Crediting Mechanism and California's SB 905 process to the EU, SBTi's Net Zero Standard, and ICVCM's continuous improvement work.The episode closes with a premortem: Luke's biggest worry is undercapitalization, a permanence trust that takes in too little up front, misjudges reversal risk, and runs out of money when it is needed most.LinksEve Tamme: LinkedIn and WebsiteLuke Pritchard: LinkedIn Contracted Durability: A Framework for Performance Based Carbon Removal by Beyond Alliance, RMI, and American Forest Foundation.
87. Getting CDR Right in the EU ETS: What's at Stake - with Francesca Battersby and Louis Uzor
29:28||Season 1, Ep. 87In this episode, Eve Tamme sits down with Carbon Gap’s ETS experts, Francesca Battesby and Louis Uzor ahead of the European Commission’s ETS proposal, expected on 17 July. CDR is about to gain access to the world’s biggest compliance market for carbon, and this conversation lays out what is actually at stake.The discussion opens on the integration model: a public authority managing CDR procurement, or covered entities acting on their own. Francesca and Louis explain why a public authority could bring mandate and long term credibility, and they unpack the open question of credit vintage, including whether pre-2031 activity could be grandfathered in.From there the conversation turns to where CDR sits relative to the ETS cap, and why Carbon Gap favours staying below the cap for now. They also tackle the price gap between DAC and BioCCS and EU allowances, pointing to the UK’s combined CfD and ETS model as a possible blueprint.The episode closes on the numbers that will decide whether integration is meaningful: the Commission’s 75 megaton estimate for 2040, Isometric’s higher 100 megaton suggestion, and Carbon Gap’s own analysis of CDR’s share of ETS emissions. Francesca and Louis flag what to watch for on 17 July, from biochar and enhanced weathering to the EU’s 90 percent domestic reduction ambition.Links:Eve Tamme: LinkedIn and WebsiteFrancesca Battersby: LinkedIn Louis Uzor: LinkedIn Carbon Gap, “Integrating CDR into the EU ETS” (June 2025) Carbon Gap, “Divide to Deliver” The State of Carbon Dioxide Removal, 3rd Edition (2026) UK Government consultation, “Extending the UK ETS cap beyond 2030”
86. Quarterly Catch Up: National CDR Targets, ETS Integration, and Who Pays for Removals
28:06||Season 1, Ep. 86In this episode of The CDR Policy Scoop, Sebastian Manhart and Eve Tamme sit down for their second quarterly, unscripted catch-up of the year, working through what is actually moving in CDR policy right now with no guest in the mix, just two co-hosts comparing notes.The conversation opens on the member state CDR targets expected by the end of the year and why a patchwork of twenty seven national targets could be a net positive for the sector, forcing a wider range of technologies and approaches into play rather than funneling everyone toward the EU ETS. From there they turn to the ETS integration itself, unpacking a Potsdam Institute modeling exercise on how CDR volumes between forty and eighty megatons a year by twenty forty could stabilize carbon prices, and Sebastian previews a new peer reviewed paper on using ETS revenue to front load investment into removals through European Investment Bank bonds.They then dig into aviation, a sector Sebastian and Eve agree the CDR community has been too quiet on. The ReFuelEU Aviation review looks unlikely to open the door to removals, and the two make the case for a coordinated push before the window closes. That leads into CORSIA, where enforcement turns out to be far weaker and far more geographically uneven than either expected, and where Sebastian argues the real opportunity may lie with nature based removals rather than durable ones.The episode closes on Article 6.4 as the presumed foundation for future international credit quality criteria despite still-undefined removal methodologies, and on Norway's new NOACCS auction scheme, a sizable but narrowly targeted funding mechanism that raises questions about how well governments are learning from each other's programs.LinksEve Tamme: LinkedIn and WebsiteSebastian Manhart: LinkedIn and WebsiteAriadne dossier (Potsdam Institute) on CDR integration into the EU ETSHow Frontloaded ETS Revenues Can Close Europe’s Durable CDR GapNOACCS, a competitive auction scheme consultation on the scheme is now open until August 6th
85. ISO, SBTi, and the LCAW Verdict on Corporate Net Zero - with Kaya Axelsson
27:37||Season 1, Ep. 85In this episode of The CDR Policy Scoop, Sebastian Manhart and Eve Tamme are joined by Kaya Axelsson, Research and Policy Fellow at Oxford Net Zero, just days after what she describes as the most anticipated Monday of her year: June 22, when both the ISO Net Zero Standard and the SBTi Corporate Net Zero Standard launched at London Climate Action Week. Kaya spent three years inside both standard-setting processes, and the conversation captures what this convergence moment actually means for companies, for carbon markets, and for carbon removal.The episode opens on what Kaya calls the single global playbook. Her case: the two standards don't fundamentally contradict each other. ISO is wider in scope, internationally governed via WTO-compatible processes, and a natural tool for trade policy, green public procurement, and claims legislation, particularly in markets across Africa and Asia that SBTi has yet to reach. SBTi brings detailed near-term implementation guidance and the momentum of eleven thousand companies already signed up. Kaya explains how she sees companies using them together and what each does better than the other.But she is not without concerns. The episode surfaces a significant one: a potential communication error in the SBTi standard that risks allowing companies to claim net zero alignment without ever setting a long-term net zero target. For CDR, the implications are direct. SBTi's decision not to require removals purchases before 2035 is, in Kaya's view, a cost-based rather than science-based call, and a missed opportunity to start scaling the supply of what companies will eventually need. ISO, by contrast, requires five-year removal milestones from the outset.The conversation closes on what comes next: the governance of commodity certificates such as green steel, SAF, cement, which both standards now actively encourage companies to purchase. Kaya predicts this will be the defining debate at the next London Climate Action Week, and explains why getting the governance architecture right matters as much as the demand signal itself.LinksEve Tamme: LinkedIn and WebsiteSebastian Manhart: LinkedIn and WebsiteKaya Axelsson: LinkedIn and WebsiteISO Net Zero Standard SBTi Corporate Net Zero Standard Robert Höglund & Claire Wigg’s: Exponential Roadmap InitiativeBuild the world your net zero target assumes
84. Inside the ISO Net Zero Standard - with Delia Meth-Cohn
30:26||Season 1, Ep. 84In this episode of The CDR Policy Scoop, Sebastian Manhart sits down with Delia Meth-Cohn, Co-founder of Rethinking Removals, who has been part of the ISO Net Zero Aligned Organization Standard working group from its very first meeting, two years ago.The conversation opens on why Delia got involved, recruited by the British Standards Institute to make sure removals expertise was in the room from the start. She explains what makes ISO structurally different from SBTi: where SBTi is a voluntary framework for leading, self-selecting companies, ISO is built to be globally applicable, rooted in national standards bodies and the WTO framework, and designed to accommodate countries with different net zero end dates, from Europe’s 2050 to China’s 2060 and Saudi Arabia’s 2070.The discussion gets to the heart of what the standard actually does on removals: it makes the implicit removals target in net zero frameworks explicit. Companies setting a long-term reduction target must treat whatever remains as their “anticipated residual emissions”, and that figure becomes a removal target they are required to plan toward, with a validated first milestone within five years. Delia is clear that flexibility is intentional: the strategy can involve a portfolio of credits, removals within operations, or value chain approaches, so long as the trajectory is defensible and verified.Sebastian pushes on the question of ambition and comparability: can two companies with very different removal strategies both receive the same ISO certification? Delia acknowledges the tension and closes on a call to action: the standard is currently in public consultation, comments feed through national standards bodies into the final draft, and this is the CDR community’s real window to push back on anything that falls short. The final standard is expected by mid-2027.LinksSebastian Manhart: LinkedIn and WebsiteDelia Meth-Cohn: LinkedIn and Rethinking RemovalsISO Net Zero Aligned Organization Standard (public consultation)
83. Green-Hushing, Safe Harbors, and Who Actually Owns a Carbon Credit - with Dr Ruth Dagan
29:30||Season 1, Ep. 83In this episode of The CDR Policy Scoop, Sebastian Manhart sits down with Dr. Ruth Dagan, Senior Partner and Head of Environment & Climate Change at Herzog Law, and Co-Chair of the IETA Legal Working Group, to cover two legal challenges that are quietly suppressing corporate demand for carbon credits.The first is litigation risk. Since 2022, climate washing claims have increased by seventy percent globally, with around 160 cases on the books and fifty-four relating specifically to carbon credit offsets. Apple's carbon neutral Watch campaign was lost in Germany and only tentatively won in the US. The upshot is that many companies are choosing to say nothing about their climate action at all. Ruth calls this green-hushing, and argues it is actively draining demand from the voluntary carbon market.The conversation covers the two regulatory responses now taking shape: the EU Empowering Consumers Directive, coming into force in September, which blacklists product-level carbon neutrality claims outright, and California's AB 1911, which proposes the opposite, a safe harbor that would actively protect companies using high-integrity credits. Ruth outlines the work being led by IETA and the Coalition to Grow Carbon Markets, now backed by eleven governments.The second challenge is more fundamental: most carbon credit registries, including PACM, include explicit disclaimers that they make no legal statement about who actually owns the credits in an account. Ruth explains how this came to be, what it means for institutional investment, and how the Unidroit project, due to conclude in early 2027, offers a route to resolution.LinksSebastian Manhart: LinkedIn and WebsiteDr. Ruth Dagan: LinkedIn and ProfileEmpowering Consumers DirectiveCalifornia AB 1911Coalition to Grow Carbon Markets / IETA safe harbor reportGrantham Institute Global Trends in Climate Change Litigation