Removals in EU ETS: resource contraints and governance gaps

Integrating removals into the EU ETS requires consideration beyond price signals and market design, as large-scale deployment is ultimately constrained by biophysical resources. Applying resource intensity assumptions to the maximum projected 2040 deployment levels shows that while energy demand from DACCS remains relatively modest, BioCCS and biochar place significant pressure on biomass and land systems. Combined biomass demand could reach up to 15% of the estimated EU supply, creating direct competition with other sectors such as bioenergy, industry, and agriculture. Land-use requirements are particularly sensitive to feedstock assumptions and could approach available limits under high deployment scenarios.