The engineered carbon dioxide removal (CDR) segment of the VCM has increasingly focused on solutions with provable permanence, rewarding technologies that lock away CO₂ for long durations.

But the recently passed OBBB shifts the landscape. The update equalizes credit amounts across use cases: both CCS and DAC are now eligible for their respective maximums—$85 and $180 per ton—regardless of whether the captured CO₂ is permanently stored or used in products.

In short, the act of capture in the US is equally rewarded, even if the carbon ultimately returns to the atmosphere.

According to the nonpartisan Congressional Research Service, 45Q could provide up to $3 billion per year in federal support through 2032. That figure is roughly double the size of the entire global voluntary carbon credit market in 2024.

With such a large subsidy in play, developers may increasingly prioritize non-storage capture pathways that qualify for 45Q but are ineligible for VCM crediting. Durable, high-integrity CDR supply may be left underfunded as a result.

This issue is less relevant for nature-based solutions, which deliver broader co-benefits like biodiversity, ecosystem health, and community resilience. But for engineered CDR, the concern is real: if 45Q incentives crowd out durable removals, what should corporate buyers do?

One option is to double down on permanence, accepting higher costs and thinner supply to preserve climate integrity. This path may help companies maintain alignment with net zero commitments and strengthen trust with stakeholders seeking high-quality climate action.

Another option (albeit more radical) is to support the creation of a new, adjacent market for circular CO₂ use—separate from the permanence-driven CDR space but still rooted in transparency and measurable impact. This may be especially important as some of the captured CO₂ will be used for Enhanced Oil Recovery, a pathway most climate-conscious companies will want to avoid, and therefore needs to be countered.