The IA is convincing on the need to expand sustainable carbon removals and encourage innovative solutions to capture, recycle and store CO2. It points to the transboundary nature of climate change as justifying EU action, but the proportionality of the initiative is not discussed and there is no subsidiarity grid to further clarify the proposal’s subsidiarity and proportionality aspects. The IA identifies three problems hindering effective and sustainable carbon removal activities; it describes them sufficiently well, but could have given more detail as to their scale in more detail. The IA suggests two sets of policy options (POs) (quality options and governance options) with two alternatives to the baseline per set of options; this raises the question whether the four possible combinations of POs provide a sufficient range of options. The IA assesses the initiative’s environmental, economic and social impacts and links them to seven SDGs. It compares the four POs packages for their effectiveness and efficiency. It describes their coherence with other policy initiatives and instruments, and concludes that the preferred option is where the Commission develops certification methodologies and ensures the correct implementation of the framework. An SME test was done and concluded that SMEs were expected to provide a ‘very significant contribution to the implementation of the initiative’, which ‘potentially offers significant financial opportunities for economic operators in these sectors’. The IA discusses the discarded options, such as a mandatory requirement for all EU operators to certify carbon removals in line with the EU framework. The voluntary nature of the initiative could have been explained more clearly. Although the initiative is apparently supported by the majority of stakeholders and the IA consistently refers to stakeholders’ opinions and is well founded on available evidence, stakeholders’ views on the preferred option could have been presented more transparently. The IA refers to an extensive literature and relevant recent studies; links are provided to most of footnotes and reference documents are mentioned, increasing the transparency and accessibility of the information used.