Grain Ecosystem

Additionality is a crucial concept in various fields, including environmental economics, finance, and development of carbon removal projects. At its core, additionality evaluates whether an action results in additional benefits compared to a baseline scenario where the action did not occur. In the context of carbon removal projects, additionality ensures that the reductions or removals in greenhouse gas (GHG) emissions would not have happened without the implementation of the project. All projects must be additional to be eligible for the voluntary carbon market standard requirements. 

Thus, the core question is: "Would the carbon removal have happened without the project?": If the answer is 

, the project is not additional and is ineligible. If the answer is 

, the project is considered additional to the baseline. 

For carbon removal technologies like biochar production, additionality criteria are critical for validating their impact. They prevent overestimation of climate benefits and ensure carbon credits represent real, measurable, and additional contributions to climate goals. Without additionality, projects risk inflating their contributions, potentially undermining the credibility of carbon markets. 

This article explores the types of additionality typically applied in carbon removal projects, how they are measured, and the specific requirements for different biochar methodologies.  

Financial additionality evaluates whether a project would have been financially feasible without revenue from carbon credits or other external financial support. The key question is: Would the project be financially viable without carbon revenues? The answer must be 

for the project to qualify as additional. 

Carbon removal projects, such as biochar production, often require substantial upfront investments in equipment, technology, or infrastructure. Financial additionality ensures that non-traditional funding sources –carbon markets and carbon financing– play a critical role in making these projects possible.  

For example, a biochar project converting agricultural waste, such as rice husks, into biochar would not demonstrate financial additionality if it were already financially viable without carbon revenues. If the project’s costs were fully covered by existing revenues from biochar sales, government subsidies, or other non-carbon finance sources, and it could operate profitably in the current market, the project would proceed regardless of carbon credits. In this case, the carbon removals achieved would not be considered additional, as they would occur even in the absence of carbon finance. 

Environmental additionality ensures that the project results in carbon removal or environmental benefits that would not have occurred naturally. This type of additionality is crucial in avoiding "baseline overlap", where projects claim benefits for actions that would have happened regardless. 

Biochar made from bagasse waste is an excellent example of a project having environmental additionality. For instance, a biochar project utilizing bagasse that would otherwise decompose and release CO₂ demonstrates environmental additionality by actively preventing those emissions. 

Environmental additionality considers the total emissions generated by the project to ensure it sequesters more carbon than it emits. For example, a forestry clearing project would not qualify as additional if its implementation results in more carbon emissions than before the project, as it would fail to deliver a net environmental benefit. 

Our GHG calculation tool can help you estimate the emissions your project removes or emits, allowing you to verify whether the climate impact of your project is net negative (meaning less GHGs in the atmosphere by the end of the project). 

Regulatory or policy additionality assesses whether a project generates benefits that go beyond what is legally or policy-mandated. Projects cannot claim additionality if their actions are already required by existing laws or regulations. 

For example, a solar energy project wouldn’t meet regulatory additionality if local laws already mandate the use of renewable energy. 

The standards we follow exclude projects mandated by any law, statute, or other regulatory framework to reduce/remove emissions, making regulatory additionality a crucial requirement for initiating work with Grain. 

Common practice additionality assesses whether a particular practice or technology is already widely implemented within a specific sector or region. If the activity is commonly used among similar businesses or industries, it is assumed to be commercially viable on its own and does not qualify as additional. 

For example, if most agricultural operations in a region already use reduced tillage as part of their standard practices, a new low or no-tillage project in the same area would not meet common practice additionality criteria.  

Good news for biochar projects: since they’re not common practice anywhere, they consistently meet this type of additionality. 

Measuring additionality can be complex because it is based on a theoretical scenario: what would have occurred in the absence of the project. To address this, carbon removal methodologies use two main approaches: project-specific and standardized. 

Project-specific approaches assess a project’s unique characteristics and circumstances to determine its additionality. These often follow a step-wise procedure, which varies by standard and methodology, requiring each project to provide evidence at every step to meet the necessary criteria. 

In contrast, standardized approaches were developed to overcome some of the limitations of project-specific methods, such as subjectivity, inconsistency, and the significant administrative burden they impose. These approaches use pre-defined eligibility criteria, like performance benchmarks or technology thresholds, to evaluate projects. 

While both approaches aim to ensure that additionality claims reflect genuine benefits, the choice between them depends on the context of the project and the requirements of the certifying Standard. 

Additionality across biochar methodologies 

As mentioned, the four Standards with biochar methodologies mandate that projects must not be required by any regulatory, policy, or other legal obligations. However, each Standard includes specific requirements and conditions for further determining additionality. 

Additionality-Standards

The Verra VCS Biochar methodology uses a standardized approach to demonstrate additionality, known as an “activity method.” This approach simplifies the process by relying on a "positive list" of approved activities. Projects engaging in activities on this list are automatically deemed additional and do not require further evidence. Under this methodology, converting waste biomass into biochar is included on the positive list, meaning all biochar projects using waste as feedstock are pre-approved as additional. 

To qualify, project developers must first demonstrate regulatory surplus, ensuring that the project’s activities are not legally required, and comply with the feedstock specifications outlined in the methodology. For more details on feedstock requirements, check out 

Verra also considers biochar production to be at such a low penetration rate globally that no country exceeds the five percent threshold specified in the VCS Methodology Requirements. As a result, all biochar projects are considered automatically additional under this methodology. 

Puro.Earth uses a project-specific approach to evaluate additionality. This methodology requires a Production Facility Audit, which includes, among other elements, a demonstration of additionality to ensure that carbon removals result from carbon finance. Even if a project receives significant non-carbon financial support, it can still be considered additional if it requires further investment, faces certain risks, or involves the development of human capital. The project developer must provide complete project financials and a counterfactual analysis based on a project-specific baseline. All projects must follow the 

CAR uses a standardized approach to calculate additionality. To be consider additional, projects must complete two tests: the performance standard test and the legal requirement test:  

Isometric calculates additionality using a project-specific baseline scenario and incorporates a counterfactual analysis. The baseline scenario assumes that no project activities take place and no infrastructure is built, establishing a reference point for evaluating the project’s impact. The counterfactual represents the amount of CO₂ that would have remained durably stored in the biomass feedstock in the absence of the project. 

This Standard emphasizes three pillars of additionality: Financial, Environmental, and Regulatory. A project must demonstrate that its claimed environmental impact would not have occurred under the baseline scenario. 

Additionality in carbon removal projects addresses the core question: Would the carbon removal have happened without the project? 

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<p></p><h2>What is additionality? </h2><p>Additionality is a crucial concept in various fields, including environmental economics, finance, and development of carbon removal projects. At its core, additionality evaluates whether an action results in additional benefits compared to a baseline scenario where the action did not occur. In the context of carbon removal projects, additionality ensures that the reductions or removals in greenhouse gas (GHG) emissions would not have happened without the implementation of the project. All projects must be additional to be eligible for the voluntary carbon market standard requirements. </p><p>Thus, the core question is: "Would the carbon removal have happened without the project?": If the answer is <strong>yes</strong>, the project is not additional and is ineligible. If the answer is <strong>no</strong>, the project is considered additional to the baseline. </p><p>For carbon removal technologies like biochar production, additionality criteria are critical for validating their impact. They prevent overestimation of climate benefits and ensure carbon credits represent real, measurable, and additional contributions to climate goals. Without additionality, projects risk inflating their contributions, potentially undermining the credibility of carbon markets. </p><p>This article explores the types of additionality typically applied in carbon removal projects, how they are measured, and the specific requirements for different biochar methodologies.  </p><h2>Types of additionalities </h2><h3>1. Financial additionality </h3><p>Financial additionality evaluates whether a project would have been financially feasible without revenue from carbon credits or other external financial support. The key question is: Would the project be financially viable without carbon revenues? The answer must be <strong>no </strong>for the project to qualify as additional. </p><p>Carbon removal projects, such as biochar production, often require substantial upfront investments in equipment, technology, or infrastructure. Financial additionality ensures that non-traditional funding sources –carbon markets and carbon financing– play a critical role in making these projects possible.  </p><p>For example, a biochar project converting agricultural waste, such as rice husks, into biochar would not demonstrate financial additionality if it were already financially viable without carbon revenues. If the project’s costs were fully covered by existing revenues from biochar sales, government subsidies, or other non-carbon finance sources, and it could operate profitably in the current market, the project would proceed regardless of carbon credits. In this case, the carbon removals achieved would not be considered additional, as they would occur even in the absence of carbon finance. </p><h3>2. Environmental additionality </h3><p>Environmental additionality ensures that the project results in carbon removal or environmental benefits that would not have occurred naturally. This type of additionality is crucial in avoiding "baseline overlap", where projects claim benefits for actions that would have happened regardless. </p><p>Biochar made from bagasse waste is an excellent example of a project having environmental additionality. For instance, a biochar project utilizing bagasse that would otherwise decompose and release CO₂ demonstrates environmental additionality by actively preventing those emissions. </p><p>Environmental additionality considers the total emissions generated by the project to ensure it sequesters more carbon than it emits. For example, a forestry clearing project would not qualify as additional if its implementation results in more carbon emissions than before the project, as it would fail to deliver a net environmental benefit. </p><p>Our GHG calculation tool can help you estimate the emissions your project removes or emits, allowing you to verify whether the climate impact of your project is net negative (meaning less GHGs in the atmosphere by the end of the project). </p><h3>3. Regulatory or policy additionality </h3><p>Regulatory or policy additionality assesses whether a project generates benefits that go beyond what is legally or policy-mandated. Projects cannot claim additionality if their actions are already required by existing laws or regulations. </p><p>For example, a solar energy project wouldn’t meet regulatory additionality if local laws already mandate the use of renewable energy. </p><p>The standards we follow exclude projects mandated by any law, statute, or other regulatory framework to reduce/remove emissions, making regulatory additionality a crucial requirement for initiating work with Grain. </p><h3>4. Common practice additionality </h3><p>Common practice additionality assesses whether a particular practice or technology is already widely implemented within a specific sector or region. If the activity is commonly used among similar businesses or industries, it is assumed to be commercially viable on its own and does not qualify as additional. </p><p>For example, if most agricultural operations in a region already use reduced tillage as part of their standard practices, a new low or no-tillage project in the same area would not meet common practice additionality criteria.  </p><p>Good news for biochar projects: since they’re not common practice anywhere, they consistently meet this type of additionality. </p><h2>How can additionality be measured? </h2><p>Measuring additionality can be complex because it is based on a theoretical scenario: what would have occurred in the absence of the project. To address this, carbon removal methodologies use two main approaches: project-specific and standardized. </p><p>Project-specific approaches assess a project’s unique characteristics and circumstances to determine its additionality. These often follow a step-wise procedure, which varies by standard and methodology, requiring each project to provide evidence at every step to meet the necessary criteria. </p><p>In contrast, standardized approaches were developed to overcome some of the limitations of project-specific methods, such as subjectivity, inconsistency, and the significant administrative burden they impose. These approaches use pre-defined eligibility criteria, like performance benchmarks or technology thresholds, to evaluate projects. </p><p>While both approaches aim to ensure that additionality claims reflect genuine benefits, the choice between them depends on the context of the project and the requirements of the certifying Standard. </p><h2>Additionality across biochar methodologies </h2><p>As mentioned, the four Standards with biochar methodologies mandate that projects must not be required by any regulatory, policy, or other legal obligations. However, each Standard includes specific requirements and conditions for further determining additionality. </p><img src="/media/AdditionalityStandards.jpg" alt="AdditionalityStandards.jpg" width="900"  height="1176"/><h3>Verra Verified Carbon Standard (VCS) </h3><p>The Verra VCS Biochar methodology uses a standardized approach to demonstrate additionality, known as an “activity method.” This approach simplifies the process by relying on a "positive list" of approved activities. Projects engaging in activities on this list are automatically deemed additional and do not require further evidence. Under this methodology, converting waste biomass into biochar is included on the positive list, meaning all biochar projects using waste as feedstock are pre-approved as additional. </p><p>To qualify, project developers must first demonstrate regulatory surplus, ensuring that the project’s activities are not legally required, and comply with the feedstock specifications outlined in the methodology. For more details on feedstock requirements, check out <a href="67362abaea63cff8e65976e2" target="_blank" rel="noopener noreferrer">our article on Feedstock and Eligibility Across Standards</a>. </p><p>Verra also considers biochar production to be at such a low penetration rate globally that no country exceeds the five percent threshold specified in the VCS Methodology Requirements. As a result, all biochar projects are considered automatically additional under this methodology. </p><h3>Puro.Earth </h3><p>Puro.Earth uses a project-specific approach to evaluate additionality. This methodology requires a Production Facility Audit, which includes, among other elements, a demonstration of additionality to ensure that carbon removals result from carbon finance. Even if a project receives significant non-carbon financial support, it can still be considered additional if it requires further investment, faces certain risks, or involves the development of human capital. The project developer must provide complete project financials and a counterfactual analysis based on a project-specific baseline. All projects must follow the <a href="https://7518557.fs1.hubspotusercontent-na1.net/hubfs/7518557/Supplier%20Documents/Puro%20Additionality%20Assessment%20Requirements.pdf" target="_blank" rel="noopener noreferrer">Additionality Assessment Requirements</a>. </p><h3>Climate Action Reserve (CAR) </h3><p>CAR uses a standardized approach to calculate additionality. To be consider additional, projects must complete two tests: the performance standard test and the legal requirement test:  </p><ul class="bullet"><li value=1>The performance standard test assesses whether biochar projects meet defined eligibility criteria across three key phases: biomass acquisition, biochar production, and biochar application. For biomass acquisition, the protocol differentiates between waste/by-product biomass and purpose-grown biomass; however, Grain exclusively works with waste/by-product biomass. The biochar production phase requires evidence that production levels surpass historical "business as usual" benchmarks and that carbon credit revenues play a crucial role in making the operation viable. Lastly, the biochar application phase emphasizes ensuring the durability of carbon sequestration by requiring biochar of high quality to be applied in ways that guarantee the long-term storage of its carbon content. </li><li value=2>The legal requirement test ensures that the GHG reductions and removals achieved by a project are not the result of federal, state, or local regulations or other legally binding mandates. To comply, project developers must verify that neither the production of biochar nor its application in eligible end uses is legally required. This involves submitting a signed Attestation of Voluntary Implementation form before verification and including procedures in the project’s Monitoring Plan to ensure ongoing compliance. </li></ul><h3>Isometric  </h3><p>Isometric calculates additionality using a project-specific baseline scenario and incorporates a counterfactual analysis. The baseline scenario assumes that no project activities take place and no infrastructure is built, establishing a reference point for evaluating the project’s impact. The counterfactual represents the amount of CO₂ that would have remained durably stored in the biomass feedstock in the absence of the project. </p><p>This Standard emphasizes three pillars of additionality: Financial, Environmental, and Regulatory. A project must demonstrate that its claimed environmental impact would not have occurred under the baseline scenario. </p><ul class="bullet"><li value=1>Financial. The project must show that removals are its primary objective and sole source of revenue. If there are other sources of income, the project must demonstrate that economic barriers would have prevented its implementation without carbon financing. Evidence of financial additionality requires a return-on-investment analysis. This includes calculating the Internal Rate of Return (IRR) over a 10-year period and proving one of the following: a zero or negative IRR, an IRR of less than the cost of capital (required rate of return) or return on equity for the project. </li></ul><ul class="bullet"><li value=1>Environmental. The project must ensure that its climate impact is net negative. This means that after subtracting the counterfactual CO₂ removal and accounting for all project-related greenhouse gas emissions, the overall outcome must result in a net reduction of atmospheric CO₂. </li></ul><ul class="bullet"><li value=1>Regulatory. The project demonstrates regulatory additionality if it is not required by any regulatory, policy, or legal obligation; otherwise, it must show that it exceeds the minimum regulatory requirements. </li></ul><h2>Sources </h2><ul class="bullet"><li value=1><a href="https://www.climateactionreserve.org/wp-content/uploads/2024/04/CAR-US-and-Canada-Biochar-Protocol-V1.0.pdf" target="_blank" rel="noopener noreferrer">Climate Action Reserve U.S. and Canada Biochar protocol. Version 1.0. Section 3.4. (March 19, 2024). </a></li></ul><ul class="bullet"><li value=1><a href="https://registry.isometric.com/standard#additionality" target="_blank" rel="noopener noreferrer">Isometric Standard. Section 2.5.3. </a></li></ul><ul class="bullet"><li value=1><a href="https://registry.isometric.com/protocol/biochar/1.0#additionality" target="_blank" rel="noopener noreferrer">Isometric Biochar Production and Storage Protocol. Section 6.4.</a>   </li></ul><ul class="bullet"><li value=1><a href="https://7518557.fs1.hubspotusercontent-na1.net/hubfs/7518557/Supplier%20Documents/Puro.earth%20Biochar%20Methodology.pdf" target="_blank" rel="noopener noreferrer">Puro.Earth Biochar Methodology. Edition 2022 V3. Section 1.2. (February 1, 2024).</a>   </li></ul><ul class="bullet"><li value=1><a href="https://verra.org/wp-content/uploads/2023/07/VM0044-Methodology-for-Biochar-Utilization-in-Soil-and-Non-Soil-Applications-v1.1.pdf" target="_blank" rel="noopener noreferrer">Verra Verified Carbon Standard. VM0044. Methodology for biochar utilization in soil and non-soil applications. Section 7 and Appendix 1. (July 5, 2023). </a></li></ul><h2>Related content</h2><ul class="bullet"><li value=1><a href="https://www.grainecosystem.com/knowledge-hub/articles/6728f17b8fb102739587a394" target="_blank" rel="noopener noreferrer">A Practical Guide to Carbon Benchmark Setting for Sustainability Goals</a> </li><li value=2><a href="https://grainecosystem.com/knowledge-hub/articles/67acecbd23e6759660f10f42" target="_blank" rel="noopener noreferrer">A Guide for Projects Already Producing Biochar: Navigating Eligibility and Additionality</a> <em>(Members only)</em></li><li value=3><a href="67362abaea63cff8e65976e2" target="_blank" rel="noopener noreferrer">Biochar: Feedstock Sourcing & Eligibility for every Standard</a></li><li value=4><a href="https://grainecosystem.com/knowledge-hub/articles/67dad8ac219f610385130456" target="_blank" rel="noopener noreferrer">What Are Carbon Credits?</a></li></ul>

Additionality: Definition, Types, and Applications