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Regulation 2024/3012: what is certified in soil carbon?

The EU’s CRCF framework, the development of methodologies in 2026, and the groundwork for an informed discussion about small olive groves.

Certifying outcomes within a defined scope

Regulation (EU) 2024/3012 establishes a voluntary Union certification framework for permanent carbon removals, carbon farming and carbon storage in products. It was published on 6 December 2024 and entered into force on 26 December 2024. Publication and entry into force are distinct dates. [1]

The regulation addresses measurable and verifiable climate outcomes under specific methodologies. It does not certify every aspect of a farm’s regenerative management or guarantee a payment to every grower using cover crops. Carbon stored in soil can be released again, so it cannot be treated unconditionally as permanent carbon removal.

The four main requirements

The framework requires quantification, additionality, storage with monitoring and liability for reversals, and environmental sustainability. The net result is calculated against a baseline, taking account of emissions associated with the activity. Additionality considers whether the activity goes beyond legal requirements and its relationship to the certification incentive. Carbon farming must provide at least one additional benefit for biodiversity or ecosystems. [1] [2]

In practice, an increase in organic matter prompts further questions: across which area, at what depth, measured by which method, compared with which expected development, and for how long? Carbon concentration in a sample is insufficient, by itself, to establish the total stock in a plot. Calculating a stock also requires appropriate information about soil mass, depth and the coarse-fragment fraction, among other factors. [7]

Developments in 2026

On 9 July 2026, the Commission adopted delegated act C(2026)4666 covering three categories: agriculture and agroforestry on mineral soils; rewetting and restoration of peatlands and other organic soils; and afforestation. The announcement of 10 July describes this step; it does not, on its own, establish that scrutiny of the act has been completed. [3] [4]

Status recorded on 19 October 2026: the European Parliament’s Legislative Observatory records an extension of the scrutiny period, a motion for objection dated 14 October and a plenary vote scheduled for 20 October. This section describes the procedure as it stood on the original review date, without anticipating its outcome. It requires a further check after the vote. [5]

The possibility of group audits

Implementing Regulation 2025/2358 sets out rules for certification schemes, bodies and audits. Article 12 provides for group audits of carbon farming under conditions including geographical proximity, similar soil and climatic conditions and procedures, a common methodology, and an internal control system with a responsible manager. A shared declaration of participation is insufficient. [6]

For Paxos, this is an option worth investigating. It does not establish that all traditional olive groves can be included in one group. Slope, access, soil and management history vary. Grouping must be supported by data and an accepted methodology.

What to establish before entering an agreement

We recommend obtaining clear answers about sampling and audit costs, ownership of data and units, the duration of commitments, and liability if carbon is lost. Who pays when another audit is required? What happens if the land manager changes? What proportion of any payment remains with the grower?

The assessment should also include benefits beyond those priced as carbon: protection against erosion, better soil functioning and preservation of the productive resource. Our priority is a reliable monitoring protocol. Possible future certification income can be considered on that basis, without presenting it as a guaranteed return to justify costs or commitments today.

Primary sources and references

  1. Regulation (EU) 2024/3012, particularly Articles 4–8 and 19
  2. EUR-Lex: official summary of the CRCF framework
  3. European Commission: announcement of 10 July 2026
  4. EUR-Lex: C(2026)4666, adopted on 9 July 2026
  5. European Parliament: procedure 2026/2819(DEA)
  6. Implementing Regulation (EU) 2025/2358, Article 12
  7. FAO: protocol for measuring soil organic carbon stocks

Sources reviewed: 19 October 2026. Legal and administrative developments are described as recorded on that date.

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