In November 2022, the European Commission put forward a proposal for a regulation for a Carbon Removal Certification Framework (CRCF). The principles laid out in the CRCF proposal of the European Commission and the proposed amendments by Council and European Parliament set minimum sustainability criteria. They are vague and require specification into executable criteria for certification. This report examines the robustness of the sustainability criteria included in the CRCF proposal and discuss different concepts for sustainability criteria.