As the European Union considers to reform its Emissions Trading System (EU ETS) by integrating permanent carbon dioxide removals (CDR), this report examines safeguards to support the gradual scale-up of permanent removals whilst keeping their quantity under control to manage risks and ensure incentives for reducing emissions remain

This report by Ecologic Institute researchers Hugh McDonald and Jonathan Gardiner, commissioned by the German Environment Agency, examines how market-based policy instruments – such as an emissions trading scheme for agriculture – could help close this gap.

This project supports the German Environment Agency (UBA) in developing strategic options for the structural evolution of the EU ETS post-2030. Its results will feed into the European Commission's 2026 review of the ETS and inform Germany's position in upcoming negotiations on ETS reform.