Newsletter

Although the expert report has a clear focus on farmers and agricultural activities, PEFC, the Programme for the Endorsement of Forest Certification, would like to highlight certain aspects as this report mentions it covers “carbon farming activities on mineral soils”, which – using the CRCF jargon – could be understood as covering more activities including planting of trees and other forest-related activities. Our feedback can be summarized as follows: - We suggest to clarify the scope of the expert report, - We believe it would be helpful to describe the relation of the recommendations with the latest CRCF draft methodologies, - We support the inclusion for “approved sustainability standards” and argue that credible, existing certification schemes could also be considered for reaching the minimum sustainability requirements (including mandatory co-benefits for biodiversity). We thank the authors for this possibility to provide feedback on the expert report and would be happy to discuss these points further.

Dear Credible team, Thank you for the opportunity to contribute to the Credible 2025 consultation. From Fundación Global Nature (FGN), we welcome the integration of biodiversity co-benefits into carbon farming and would like to share our recently developed methodology for quantifying biodiversity gains in agrarian ecosystems. The executive summary is available here:

https://fundacionglobalnature.org/wp-content/uploads/2025/06/BiodiversityUnits_ExecutiveSummaryMethodology_FGN.pdf

Our methodology, relevant to “Incentivising co-benefits beyond minimum requirements 2: Voluntary quantification”, is based on over 5 years of biodiversity monitoring in Spain, France, and Portugal, across 15+ projects involving regenerative agriculture, Natura2000, grazing, and wetland restoration. Key features of our approach include: Use of both experimental and non-experimental variables, acknowledging the dynamic and human-influenced nature of agrarian ecosystems. Simultaneous assessment at plot and landscape scales to reflect local impacts more accurately. A pre-defined basket of biodiversity metrics to ensure objectivity and avoid biased interpretations. Integration of intra-annual and short-term comparisons to enable early impact assessments. A relative measurement approach rather than relying on absolute thresholds. Inclusion of “Interest” as a variable, recognizing ecological relevance over simple abundance/richness data. Our system distinguishes between technical verification by farmers and ecological verification by experts, allowing regional estimations of biodiversity gain to be extrapolated and used by individual farms. We believe this approach complements existing EU programs (e.g., EMBAL, Natura2000 monitoring), and offers a scalable, robust method to quantify biodiversity benefits in the short term. We would be happy to share project data and insights from 10,000+ biodiversity indicators collected across diverse agroecosystems.

Excellent report .. sorry that the links below won’t work. I would have happily contributed to this report and was glad to be able to share (after the event) details of EURAF Policy Briefing #66.

I was also surprised that there was not more discussion of the Sustainable Finance Initiative (aka the Sustainability Taxonomy). See EURAF Policy Briefing #28. The Climate and Environment Delegated Acts of this are important, and it is a pity that (because of NGO criticism?) the initial drafts of guidance on sustainable agricultural practices were abandoned. This would have been a good start for the CRCF.

Note that there is also a lot of detail in them on sustainable forestry and paludiculture.

Other than that, I agree with the recommendations on the "farm environment plan" – indeed a structure for this in the context of an agroforestry management plan was suggested to DGFISMA in Policy Briefing #28 (with no reply from them).

The six principles you identify are sound (especially pragmatism and incentives). I would have liked to see more discussion on the need for an "on-farm Sustainability Compass" and good DATA.

Many of the indicators needed for sustainability assessment can be modelled or observed using remotely sensed information, but this has to be integrated with Farm Scale IACS/LPIS/GSAA information – and more than half of Member States are not compliant with the requirements of the High Value Datasets Implementing Regulation.

Use of Ecoscheme funding for initial monitoring and planning could be mentioned.

Dear Credible team, thank you for the opportunity to contribute to the Credible 2025 consultation. Our feedback reflects hands-on implementation across markets and aims to inform how digital infrastructure can accelerate traceable, cost-effective carbon farming aligned with the CRCF. The following feedback is based on our work designing digital infrastructure for credit-level traceability, automated sustainability reporting, and integration with emerging standards. In the attached letter, we provide reflections and recommendations in response to the following five expert reports:

1. Barriers and incentives for sharing input data needed in carbon farming and MRV systems in Europe; 2.Earth Observation (EO) for MRV of Carbon Farming; 3. Unlocking data for MRV: Data sharing for effective carbon farming; Ensuring carbon farming delivers sustainability benefits and 5. An effective policy mix for scaling up carbon farming We share our input based on practical implementation experience and with the aim of supporting the development of effective, transparent, and farmer-accessible carbon farming and MRV systems across Europe. Our experience building MRV infrastructure aligns closely with the data architecture envisioned under the EU Carbon Removal Certification Framework (CRCF). In this submission, we provide actionable suggestions to support CRCF-compatible implementation, especially as it relates to credit traceability, automated disclosures, and co-benefit accounting.

Carbon farming’ is very much in vogue right now in agricultural policy and practice. The aim is to bind CO2 from the atmosphere in the soil over the long term through agricultural measures and thus slow down the climate crisis. Whether and to what extent this is possible is the subject of controversial scientific debate. At the same time, the question arises as to whether it makes political sense to rely on carbon farming.

I recognize the importance of “farm environment plans”, market price premiums, accessibility and pragmatism. This said, I see Figure 1 as not very … pragmatic and/or accessible by the farmer. More so, the said FEP will probably spook many farmers already required to submits nutrient management plans in leu of cross-compliance. I also question the “negative listing” (sic) of cropping practices. Is there really a consensus as to what is and isn’t a sustainable cropping practice. ? This could rapidly devolve into never ending byzantine disputes. Polyor SAS (www.polyor.fr) has proposed a more impartial, ergonomic and cost-effective approach to sustainable agriculture and SOC/M conservation.

Aligning CRCF Sustainability Goals with Circular Bio-Based Soil Innovations We encourage the CRCF certification framework to explicitly recognize and support the use of biodegradable, circular, and microplastic-free soil amendments that actively contribute to sustainability objectives beyond carbon removal. In particular, soil inputs derived from bio-based waste materials, structured using fungal or microbial matrices, and enriched with carbon-sequestering agents such as biochar, can provide multiple co-benefits aligned with Article 7(f) of the CRCF Regulation:

Enhancement of soil organic matter and microbial activity Support for biodiversity and ecosystem functions at the soil and landscape level Prevention of pollution, including avoidance of synthetic binders and microplastic residues Circularity in material use, particularly in nutrient delivery and restoration strategies These solutions can play a vital role in advancing CRCF's ambition to deliver sustainability co-benefits beyond minimum requirements, and should be eligible for recognition under the Sustainability+ label.

We recommend including: Positive examples of nature-based, fully degradable soil inputs Integration with low-cost, farm-level indicators for biodiversity and soil health Alignment with digital farm environment plans and MRV approaches that are farmer-friendly and scalable Such inputs can serve both regenerative agriculture and broader land restoration objectives, especially on mineral soils where synthetic or plastic-bound materials risk undermining long-term sustainability outcomes.