Carbon removal has entered its performance era
Welcome back to Critically Speaking, the Supercritical newsletter for carbon removal buyers.
This month’s edition is adapted from a letter by Michelle You, our co-founder and CEO, originally shared with a small group of carbon removal buyers focused on 2026 procurement strategy.
Two years ago, carbon removal was full of promises. Most of my conversations with companies centered on pledges: ambitions for 2030, moonshots for 2050, and exploratory purchases meant to “learn about the space.”
2025 made clear how quickly that world is disappearing. As 2030 net-zero targets approach, not all tonnes are arriving on schedule. AI-driven emissions growth, rising scrutiny of quality, and early regulatory signals illuminate why the next phase of carbon removal will be judged not on ambition, but on tonnes removed.
Carbon removal is entering its performance era.
Over the past year, working with some of the most advanced buyers in the world across dozens of procurement processes, I’ve seen how quickly expectations are changing.
I wanted to share three observations I’ve noticed as the market transitions from promises and hope to performance and delivery.
1. Delivery risk is when, not if
As projects move from pilot to first-of-a-kind to commercial operations, the market is learning what delivery looks like in practice.
Many of the early offtakes signed in 2021–2022 are now reaching real delivery milestones. Some are arriving on time. Others are delayed or underdelivering, requiring changes to expected volumes and timelines.
Sophisticated buyers are responding by redesigning how portfolios are built. Rather than assuming linear delivery from individual projects, they treat carbon removal like a supply chain designed to absorb disruption.
This means diversifying across suppliers and pathways, incorporating buffers, and working with partners who can replace credits when projects fall short. As our understanding of quality evolves, the strongest portfolios leave flexibility to adapt.
Portfolios built around a single developer or pathway can fall out of alignment quickly. Reliability comes from building in flexibility from the start. It’s the difference between meeting a net-zero commitment and missing it.
2. The shift from project-first to criteria-first procurement
Many companies still approach carbon removal the old-fashioned way.
We see this in RFPs built around shortlists of named projects, often selected for how neatly they align with a company’s narrative. That approach made sense when experimentation was the goal and purchases were largely symbolic.
As the market matures, advanced buyers are moving away from project-first procurement toward a criteria-first approach.
Instead of picking individual projects, they define what a tonne must deliver, including permanence, additionality, delivery confidence, and compliance eligibility, and procure against those outcomes. This is already how buyers approach other forms of net-zero infrastructure, from green steel to clean power.
No one checks which wind farm produced the electrons powering their office. They care that the power is reliable, affordable, and traceable to a clean source.
The same shift is now underway in carbon removal. Buyers are becoming more explicit about performance requirements, for example, a tonne of biochar with permanence of 200+ years, delivered by a proven supplier, verified under rigorous MRV, and structured to align with emerging compliance frameworks, such as the EU ETS.
3. Compliance is driving quality
Compliance is coming fast. Japan has already integrated carbon removal into its national emissions trading system, and the EU and UK are expected to follow by 2029. Regulators are converging on a clear principle: carbon must be stored for centuries, not decades, to count as compliance-grade.
Forward-looking buyers are procuring as if these rules already apply. They are planning for the standards their tonnes will need to meet in the future, not the minimum required today.
Under frameworks such as the EU’s Carbon Removals and Carbon Farming (CRCF) regulation, “permanent” removal is defined as storage lasting 200 years or more. Under SBTi’s proposed guidance, it’s 1,000 years or more.
These thresholds matter. A tonne stored for a decade is not the same climate outcome as a tonne secured for centuries, and regulators are codifying that difference. Buyers preparing for compliance are responding accordingly, prioritizing long-lived removal pathways and suppliers with robust monitoring, reporting, and replacement mechanisms that can withstand audit over time.
As demand concentrates around permanent, verifiable removal, competition for high-quality supply is intensifying. Buyers who move early secure access and build audit-ready portfolios. Those relying heavily on short-lived storage are finding fewer viable options as standards tighten.
What a mature carbon removal market looks like
A mature carbon removal market doesn’t look like a collection of interesting projects. It looks like an asset class.
In a mature market, tonnes are procured years in advance against clear specifications. Permanence thresholds are explicit. Delivery risk is planned for. Buyers know which tonnes qualify under what regulations. Corporate claims are built to survive an audit.
This is already how the most advanced buyers operate.
The market is still early, but the divide is becoming clear. Portfolios built for exploration will age quickly. Portfolios built for performance will set the bar.
Those who make that shift now will not only meet their climate commitments. They will help shape the market that the rest of the world depends on.
What’s new at Supercritical?
💡Policy clarity isn’t coming before you need to buy carbon removal. So how do you build a defensible CDR strategy when the rules are still being written? Join us for a live briefing on January 21st at 11 am GMT, led by Dr. Mai Bui, Supercritical’s Director of Climate Science. Register here.