The targets are set. The supply is not.
486 companies have a 2040 net zero target and 1,807 have 2050, all of them needing removals in the same years. Committed European capacity is about 1.4 Mt a year, a new facility takes four to seven years to build, and from 2031 the EU buys centrally at the scale of the whole market. Whether and when that binds you depends on what you report under, which is what this works out.
The question is not whether removals get cheaper. It is whether the tonnes exist when your target year arrives, and whether you are in the queue by then. From 2031 the EU enters as a central buyer at a scale comparable to the entire European market.
Target-year counts from the SBTi target dashboard, 486 at 2040 plus 1,807 at 2050. That is the validated minority; roughly 8,000 EU companies stay in CSRD scope and most hold targets outside SBTi, so the real figure is higher and nobody measures it. Capacity from company disclosures at final investment decision; the EU purchase programme from COM(2026) 616 Art. 9c. Sources and the arithmetic in the detailed analysis below.
- Towards an SBTi target
- Yes, and only removals. They neutralise residual emissions at net zero under C46, and from 2035 cover a rising share of ongoing emissions under C45. Long-lived gases need long-lived removals, so afforestation and soil carbon do not substitute there. CRCF units stay eligible.
- In your CSRD report
- Separately, under ESRS E1-7. Gross Scope 1 to 3 stays unadjusted, so buying does not lower your reported emissions. It is disclosure, not netting.
- Under the EU ETS
- It does not oblige you to buy. The ETS covers installations, not companies in general, and under Art. 14(1a) even a covered operator can only count removals it captures and stores itself, not credits it buys. What the ETS proposal does create is one very large buyer: from 2031 the Commission auctions 250 million allowances and spends the revenue on CRCF-certified BioCCS and DACCS. You compete with it for the same European tonnes.
- In a public claim
- Unsettled. The Commission is drafting guidance on what buyers may say with CRCF units, expected around the end of 2026. Until it exists, claims are a judgement call for your own counsel.