Policy layering in EU carbon farming governance: insights from eight EU Member States[La superposition des politiques dans la gouvernance de l'agriculture carbone au sein de l'UE : enseignements tirés de huit États membres de l'UE]

Carbon farming has become an increasingly prominent concept in European climate and agricultural policy, particularly in the context of efforts to strengthen carbon removals from the land sector. In parallel, the European Union adopted the Carbon Removals and Carbon Farming Regulation (CRCF) in 2024, adding a new certification-based governance layer to an already dense landscape of public agricultural support instruments and diverse private initiatives. This article examines how this evolving policy field is perceived by national experts across eight EU Member States. Drawing on expert survey data collected in 2023, we analyse expert perceptions of carbon farming relevance, the potential and barriers of different practices, the status of monitoring, reporting and verification, and expectations regarding private initiatives. The results indicate that carbon-farming-related practices are currently supported mainly through existing CAP instruments rather than through coherent stand-alone carbon-farming strategies, and that inventory visibility of these measures remains limited and highly heterogeneous across countries. We interpret these patterns as indications of policy layering, in which new governance instruments are being added to established agricultural and climate policy architectures, without changing the existing policy structure. The type of layering varies by dimension: while some complementarities between CAP and CRCF incentives for farmers exist, the absence of reliable demand structures for CRCF credits and structural incompatibilities between CRCF certification and national climate accounting systems point towards an inefficient outcome and counter-productive layering, respectively. Unless these challenges are addressed, the CRCF risks remaining a layered instrument without real integration into national policy frameworks and with low climate impact.