Carbon Management Europe and Carbon Gap have published a discussion paper examining how a structured mechanism for aggregating demand could help unlock private investment capital for carbon dioxide removal (CDR) in Europe. The paper is released on the eve of the European Commission's first CRCF Days, where the concept will be discussed in a dedicated session on 20 May.
Achieving EU climate neutrality by 2050 will require large-scale carbon removals alongside deep emissions reductions across sectors. A growing pipeline of European CDR projects exists, but most cannot yet attract the private financing needed to move from development to construction. The core constraint is not a shortage of capital, but rather the absence of credible purchasing commitments from buyers: without these, project developers cannot demonstrate the revenue certainty that investors and lenders require before committing funds.
The paper draws from a closed multi-stakeholder workshop in February 2026 with corporate buyers, financial institutions, and European Commission observers, and examines how an EU CDR Carbon Removal Buyers' Club - a coordinated group of companies committing to purchase verified carbon removals - could address this gap. By aggregating demand and providing shared governance standards, such a mechanism could reduce perceived investment risk and support multiple projects in reaching commercial scale simultaneously.
The analysis maps design options for a CDR Buyer’s Club across four dimensions: the regulatory framework it should apply, the technologies and geographies it should cover, how procurement should be structured, and how ambition levels and buyer commitments should be defined.
The value of this paper is that it starts from real market conversations, not assumptions about what buyers should want. Through our February workshop and wider engagement, we heard where buyers and investors see opportunity, where they still face constraints, and what a credible first version of the Buyers Club could look like by the end of this year. This is a practical design challenge of turning buyer interest into credible demand in a way that works with the CRCF and which can be strengthened over time.
– Alexander Mäkelä, Chief Policy Officer, Carbon Gap
The core challenge facing European carbon removals is not technical; it is financial. Capital exists, but projects cannot access low-cost capital without credible buyers in place. A well-designed buyers' club, anchored in the CRCF, could provide exactly the demand signal the market needs to move forward.
– Zişan Özdemir, Technology and Policy Analyst, Carbon Management Europe
The Carbon Removals and Carbon Farming Regulation (CRCF), whose first methodologies entered into force this month, emerges as the most credible regulatory foundation. A CRCF-aligned approach with flexibility to incorporate future methodologies in the pipeline, a focus on near-commercial projects within EU and EEA jurisdictions, and a corporate-led structure operating at market formation scale represent the most workable directions from stakeholder deliberations.
The paper is clear that a CDR Buyers' Club would not replace existing market actors. Its role would be to function as a coordination platform - providing common standards, institutional credibility, and aggregated demand signals while working alongside the intermediaries, project developers, and financial institutions already active in the European CDR ecosystem.
Both Carbon Gap and Carbon Management Europe will be present at CRCF Days to discuss these findings and contribute to the wider debate on scaling high-integrity carbon removals in Europe.