Governance questions surrounding marine carbon dioxide removal (mCDR) are becoming increasingly urgent—and they will not wait for the science to settle.
Projects are already being proposed, pilot schemes are being planned, and regulatory frameworks are taking shape in real time, often before the evidence needed to guide them is fully developed.
This post takes stock of the mCDR governance landscape as it currently stands.
What is already in place?
Several international and EU frameworks are relevant to mCDR, although none was designed specifically for marine carbon removal:
The London Protocol: This is the main international reference point for regulating the placement of materials in the ocean, including certain marine geoengineering activities. It provides a route for legitimate scientific research under specific conditions, but important governance and enforcement questions remain.
The United Nations Convention on the Law of the Sea (UNCLOS): UNCLOS establishes the rights and responsibilities of states across different maritime zones. However, it does not address carbon dioxide removal specifically.
The Convention on Biological Diversity (CBD): The CBD has adopted decisions relevant to ocean geoengineering, including a precautionary position on climate-related geoengineering activities that could affect biodiversity or have transboundary impacts.
The EU Carbon Removal and Carbon Farming Certification Framework (CRCF): This is one of the most significant recent developments at the EU level. It establishes a framework for certifying carbon removals, although its initial focus is largely terrestrial. How it develops will help determine whether mCDR approaches can eventually access EU markets and policy instruments.
Despite this patchwork of existing rules, major gaps remain:
- There is no clear permitting pathway for most mCDR activities beyond small-scale research.
- There are no internationally agreed standards defining what counts as verified marine carbon removal.
- There is no established framework for distributing benefits, risks, and liabilities across jurisdictions in transboundary deployments.
- Countries and communities in the Global South remain underrepresented in governance discussions that may directly affect their oceans and livelihoods.
Our project is engaging directly with these questions. We aim to help ensure that future governance frameworks are grounded in strong evidence, shaped by diverse perspectives, and workable in practice.
We will share more as the project develops. If you have expertise in international maritime law, EU policy, or governance design, we would be glad to hear from you.