Key Takeaways & Executive Findings
- •• • The EU GCD addresses that 53.3% of environmental claims are potentially misleading and 40% lack evidence, establishing verification standards that directly influence CDR certification and third-party validation, setting a precedent for regulatory rigor. • • China's carbon market currently covers only CO2 from specific sectors, with limited greenhouse gas coverage and an incomplete MRV system, whereas the EU ETS includes broader scope and more mature monitoring, reporting, and verification, highlighting a gap that requires phased expansion and international alignment. • • CCUS in China is predominantly applied to enhanced oil recovery due to economic incentives, while BECCS and DACCS remain underdeveloped; prioritizing saline aquifer storage in North and Northwest China with 'source-sink matching' could enable commercial-scale projects. • • The EU policy cluster integrates GCD with ECGT, CRCF, and ESRS to create a coherent regulatory environment, whereas China's '1+N' policy system lacks specific CDR legislation and dynamic adjustment mechanisms, necessitating legal frameworks and standardized MRV methods for saline aquifer storage.
Abstract
Amid intensifying global warming, carbon emission reduction and carbon dioxide removal (CDR) have become central to climate governance. In March 2023, the European Commission proposed the Green Claims Directive (GCD) to combat greenwashing and enhance the reliability, comparability, and verifiability of environmental claims. The GCD, together with the Empowering Consumers for the Green Transition Directive, the Carbon Removal Certification Framework, and the European Sustainability Reporting Standards, forms a policy cluster supporting the EU's green transition and CDR deployment. China, as a major greenhouse gas emitter, has made progress in renewable energy and national carbon market construction, yet its total emissions remain high, CDR technologies are nascent, and CCUS deployment is economically oriented, mainly in enhanced oil recovery. This study systematically reviews the legislative background, core objectives, and synergistic logic of the GCD and related policies, focusing on requirements for CDR certification, third-party verification, and carbon credit regulation. It compares Chinese and EU carbon markets in coverage, allowance allocation, and MRV systems. The analysis indicates that EU experience in policy integration, technical standardization, and market maturity can inform China's policy framework, technology pathways, and market efficiency, supporting large-scale CDR and the 'dual carbon' goals.
1. Introduction
The escalating frequency of extreme weather events linked to CO2-induced warming has forced a global reckoning with both emission reduction and carbon dioxide removal (CDR). While China has aggressively expanded renewable energy and established a national emissions trading system, its total carbon emissions remain at historically high levels, and CDR technologies—particularly bioenergy with carbon capture and storage (BECCS) and direct air capture with carbon storage (DACCS)—are still in nascent stages. The existing CCUS deployments are skewed by economic incentives toward enhanced oil recovery, leaving a critical gap in permanent geological storage. This bottleneck stems from a fragmented policy landscape: no unified certification standard for carbon removal claims, weak third-party verification mechanisms, and a carbon market that covers only a narrow set of gases and sectors, failing to incentivize high-integrity removal.
The European Union's Green Claims Directive (GCD), introduced in March 2023, directly confronts these challenges by establishing minimum requirements for verifying environmental claims, including those related to CDR. Its synergistic policy cluster—comprising the Empowering Consumers for the Green Transition Directive, the Carbon Removal Certification Framework, and the European Sustainability Reporting Standards—creates a coherent regulatory architecture that enforces claim reliability, comparability, and verifiability. This study systematically dissects the GCD's legislative logic and its implications for China, drawing on empirical data from EU environmental claim audits (53.3% misleading, 40% unsubstantiated) and a comparative analysis of carbon market mechanisms. By translating these insights into actionable policy, technology, and market recommendations, we aim to accelerate China's transition from pilot-scale CCUS to commercially viable, large-scale CDR, ultimately supporting its 2030 carbon peak and 2060 carbon neutrality commitments.
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HOU Yunlu, CAI Bofeng, LI Qi, PANG Lingyun, LIU Guizhen, GUO Jing, ZHONG Yiyan (2026). Insights from the EU Green Claims Directive and Related Policies for Carbon Dioxide Removal in China. Chinese Journal of Environmental Engineering. https://doi.org/10.12030/j.cjee.202509093
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Frequently Asked Questions
What specific verification requirements does the EU Green Claims Directive impose on carbon removal claims, and how do they differ from existing Chinese MRV protocols?
The GCD mandates that environmental claims must be clear, unambiguous, accurate, and verifiable, with third-party verification before publication. For CDR, this aligns with the Carbon Removal Certification Framework, which requires quantification of net removal benefits, additionality, long-term storage, and sustainability. In contrast, China's MRV system for carbon markets currently focuses on emission reductions, not removals, and lacks standardized methods for verifying geological storage permanence. The EU's approach, backed by data showing 53.3% of claims misleading, sets a higher bar for scientific evidence and independent auditing, which China could adapt to build trust in CDR credits.
How does the economic viability of CCUS in China compare with EU-supported CDR pathways, and what policy mechanisms could bridge the cost gap?
In China, CCUS is predominantly applied to enhanced oil recovery (EOR) because it generates revenue, whereas dedicated geological storage in saline aquifers is not yet economically attractive. The EU's policy cluster, including the Carbon Removal Certification Framework, creates a market value for verified removals, potentially via carbon contracts for difference or inclusion in the EU ETS. China could adopt similar mechanisms, such as a carbon price floor for removals or subsidies for saline aquifer storage, to incentivize projects in regions with high storage potential, like the North China Plain, where source-sink matching can reduce transport costs.
What are the scalability bottlenecks for BECCS and DACCS in China, and what empirical parameters are needed to assess their feasibility?
BECCS scalability is limited by biomass feedstock availability and competition with food security, while DACCS faces high energy penalties and costs. For China, a phased approach is suggested: first, prioritize saline aquifer storage with existing CO2 capture from industrial sources; second, develop BECCS in regions with abundant agricultural residues; third, pilot DACCS at small scale. Key parameters include storage capacity (e.g., >100 Mt CO2 in the Bohai Bay Basin), capture cost (currently $50-100/t CO2 for coal-fired plants), and energy consumption (e.g., 5-8 GJ/t CO2 for amine-based capture). These metrics must be validated against China's geological and industrial context.
How does the EU's carbon market coverage and MRV rigor compare with China's national ETS, and what implications does this have for CDR integration?
The EU ETS covers ~40% of EU emissions, including CO2, N2O, and PFCs, with a cap-and-trade system and robust MRV requirements, including third-party verification and annual reporting. China's national ETS initially covers only the power sector (about 40% of national emissions) and only CO2, with less stringent MRV and no third-party verification. This disparity means that CDR credits cannot be easily integrated into China's market without expanding coverage and strengthening MRV. The EU's experience suggests that phased expansion to include more sectors and gases, coupled with market stability reserves, could enhance liquidity and incentivize CDR.
What are the key technical and policy challenges in establishing a certification framework for carbon removal in China, and how can the EU's approach inform this?
Challenges include defining additionality, ensuring permanence (e.g., >1000 years for geological storage), avoiding double counting, and establishing liability for leakage. The EU's CRCF provides a methodology that quantifies net removal benefits, requires monitoring and reporting, and includes a registry to prevent double counting. China could adapt this by developing its own MRV standards for saline aquifer storage, incorporating site-specific geological data, and creating a legal framework for long-term stewardship. The EU's experience with the GCD also highlights the need for third-party verification to build trust, which is essential for market acceptance.
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