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Legislative initiative on CO2 transportation infrastructure and markets

Energy

The Communication on a 2040 climate target and its impact assessment underscores the need for carbon capture utilisation and storage (‘CCUS’) to meet the EU 2050 climate objectives. The Industrial Carbon Management strategy, published at the same time in February 2024, recognises the need for a legislative initiative with a view to ensuring the development of competitive markets and transportation infrastructure for CO2. The political guidelines for the 2024-2029 Commission reiterate this need. This initiative will implement this ambition.

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Public consultation

ID: 14804

Lobbying Activity

89 responses

Transport and Environment Urges CO2 Infrastructure for E-Fuels

Transport and Environment (European Federation for Transport and Environment), 11 Sept 2025

T&E calls for CO2 infrastructure planning to prioritize sustainable e-fuel production. They request third-party access for biogenic carbon suppliers to prevent sourcing bottlenecks. They also recommend including rail as a cost-effective transport method.
This secures the supply of sustainable carbon needed to decarbonize shipping and aviation.
Fossil power plants lose when infrastructure planning avoids locking in their emissions.

Chemical industry urges flexible CO2 transport rules and market development

European Chemical Industry Council, 11 Sept 2025

The industry requests a phased approach to CO2 transport regulation with initial flexibility before introducing prescriptive market rules. They want coordination of cross-border infrastructure, recognition of carbon capture utilization benefits, and multiple transport modes including pipelines, barges, vehicles and rail.
This would allow them to recover infrastructure investment costs during market development.
Environmental groups lose stronger immediate carbon transport standards and market oversight rules.

EDF recommends regulated CO2 infrastructure and clear liability rules

ELECTRICITE DE FRANCE, 11 Sept 2025

EDF requests regulated third-party access to networks and accounting separation to prevent cross-subsidization. They also call for European rules assigning responsibility for leaks to infrastructure operators.
Regulated, cost-reflective tariffs would provide financial predictability for EDF's industrial decarbonization projects.
Energy consumers may face higher costs if existing networks cross-subsidize CCS development.

Shell urges EU to prioritize funding over regulation for CO2 transport

Shell Companies, 11 Sept 2025

Shell requests EU focus on funding, de-risking, and coordinated infrastructure development rather than premature regulation. They advocate for public-private partnerships, an EU regulatory body for cross-border transport, and integration of non-pipeline transport modes. They warn that early focus on third-party access, tariffs, and unbundling risks misaligning policy with market maturity.
This would reduce investment risk and enable Shell to scale its CCS operations commercially.
Smaller emitters lose fair access to infrastructure without third-party access rules.

Consultation response

Friends of the Earth Europe, 11 Sept 2025

Friends of the Earth Europe is deeply concerned that the European Commissions plans for CO2 transport and dumping and risk a further lock-in of fossil fuels in Europe, further support for the fossil fuel industry who are at the heart of the climate crisis, another distraction from the clean…

Fern warns against taxpayer-funded CO2 transport infrastructure

Fern, 5 Sept 2025

Fern opposes building large-scale CO2 infrastructure at taxpayer expense. They argue current carbon removal technologies are unproven and threaten biodiversity.
This approach prevents the depletion of land carbon sinks.
The fossil fuel industry loses its primary justification for continued operation.

German Industry Urges State-Backed EU CO2 Transport Infrastructure

Deutsche Industrie- und Handelskammer, 10 Sept 2025

DIHK calls for a state-backed refinancing model for CO2 pipelines. They advocate for including negative emissions in the emissions trading system. The group also requests caps on network fees.
These measures would reduce transformation costs and protect industrial sites from relocation.
Environmental groups and local residents may face risks from expanded onshore storage.

Eni urges flexible CO2 rules and increased funding support

Eni S.p.A., 11 Sept 2025

Eni requests flexible regulations that protect existing projects and account for national differences. They also advocate for using carbon market revenues to fund new infrastructure.
The company would lower investment risks and profit from repurposing old infrastructure.
Smaller industrial emitters could lose fair access if transport tariffs are not transparently regulated.

Austrian Industry Urges Rapid EU CO2 Pipeline Network Expansion

Wirtschaftskammer Österreich, 8 Sept 2025

The chamber demands a pipeline-based core network by 2030 to link landlocked industry to storage. They request distance-independent transport tariffs to ensure fair costs regardless of geographic location.
Flat pricing prevents Austrian firms from suffering cost disadvantages due to their distance from storage.
Coastal regions and storage providers may lose the pricing advantage of their geographic proximity.

ENGIE urges EU to formalize roles for CO2 midstreamers

ENGIE, 11 Sept 2025

ENGIE requests formal recognition for CO2 midstreamers to manage cross-border emissions transport. They support standardizing CO2 quality and removing regulatory barriers to international storage. Additionally, they propose including permanent carbon removals within the EU ETS.
Formal midstreamer status allows ENGIE to maintain ownership of molecules and secure financing.
Infrastructure operators lose direct ownership of the CO2 molecules moving through their networks.

Iberdrola urges carbon infrastructure funding by technology operators

IBERDROLA, 11 Sept 2025

Focus carbon capture only on hard-to-abate sectors after exhausting other mitigation. Operators using carbon capture must fund the necessary infrastructure themselves. Replace EU-wide planning with bilateral cooperation facilitated by the Commission.
This protects renewable energy investments by ensuring electrification remains the primary solution.
Industrial carbon emitters lose access to potentially socialized or taxpayer-funded infrastructure.

Oceana warns carbon capture risks destroying marine ecosystems

FUNDACION OCEANA, 11 Sept 2025

Oceana opposes the EU's carbon capture push due to high costs. They favor renewable energy over risky offshore storage infrastructure.
Stopping offshore carbon storage protects marine life from acidification and construction.
Fossil fuel companies lose their justification for continued offshore oil exploration.

BDEW Urges EU to De-risk CO2 Infrastructure Investments

BDEW Bundesverband der Energie- und Wasserwirtschaft e. V., 11 Sept 2025

The association requests state-backed funding accounts and subsidies to cover high initial construction costs. They also call for simplified permitting and clustering to improve economic efficiency for early users.
Private operators reduce their investment risks while securing guaranteed returns for their new infrastructure projects.
Public finances bear the risk of covering gaps if carbon capture volumes fail to meet expectations.

Oil and gas producers urge flexible CO2 market regulation

International Association of Oil Gas Producers Europe, 11 Sept 2025

The organization requests a phased, flexible approach to CO2 infrastructure regulation that avoids premature rigid rules. They want light-touch early regulation allowing negotiated tariffs and exemptions, coordinated cluster-based public funding, and de-risking instruments like carbon contracts and loan guarantees.
This would reduce regulatory constraints on early infrastructure projects and increase investment returns.
Countries without storage sites face uneven access to decarbonization infrastructure and higher costs.

RWE urges streamlined EU CO2 network development

RWE AG, 11 Sept 2025

RWE recommends streamlining planning processes for carbon pipelines. They suggest prioritizing industrial clusters for a faster rollout. They also advocate for flexible rules that avoid strict profit controls.
RWE would benefit from faster project connections and reduced regulatory oversight during the early rollout.
Smaller companies outside major industrial clusters could face restricted access to new CO2 transport networks.

Equinor urges EU to prioritize cross-border CO2 transport rules

Equinor ASA, 11 Sept 2025

The company requests priority for removing cross-border CO2 transport barriers and opposes regulating offshore transport and storage as natural monopolies. They argue onshore pipelines need regulated access, but offshore infrastructure faces competition from multiple providers and shipping options.
This would preserve commercial flexibility for their offshore CO2 infrastructure investments and storage projects.
Smaller emitters lose stronger regulatory protections ensuring equal access to offshore CO2 infrastructure.

Cement industry demands fair access to EU CO2 infrastructure

CEMBUREAU - The European Cement Association, 11 Sept 2025

CEMBUREAU calls for an EU-wide CO2 transport network that ensures all cement plants have non-discriminatory access at fair prices. They request faster permitting by designating carbon capture projects as being of overriding public interest while seeking more government funding to support high operational costs.
These measures would lower financial barriers and provide regulatory certainty for expensive industrial decarbonization projects.
Local communities and environmental groups may have less influence over projects fast-tracked under overriding public interest rules.

European shipowners urge EU to create single CO2 transport market

European Community Shipowners' Associations, 19 Aug 2025

Shipowners want a single European market for CO2 transport to replace bilateral deals. They request that onboard carbon capture be integrated into EU strategies and funding.
This would open new revenue streams and lower costs for older vessels.
National authorities lose the ability to manage CO2 transport through specific bilateral deals.

European Biogas Association demands support for biogenic carbon capture

European Biogas Association, 11 Sept 2025

The EBA requests a regulatory framework that prioritizes biogenic CO2 and establishes a traceability system. They advocate for infrastructure planning that includes small-scale producers using liquid transport.
This helps small producers overcome high transport costs and access markets more competitively.
Fossil CO2 suppliers lose market share as biogenic alternatives receive policy priority and financial support.

German chemical industry demands equal treatment for carbon capture

Verband der Chemischen Industrie e.V., 11 Sept 2025

The industry seeks to include waste incineration in carbon pricing. They want products using captured carbon exempted from emission costs.
This would exempt companies from emission costs and create a new market for trading carbon.
Waste incineration operators would face higher costs from mandatory inclusion in carbon trading.

Air Liquide urges open access to EU carbon storage infrastructure

AIR LIQUIDE, 11 Sept 2025

The company demands open, non-discriminatory access to storage and the development of onshore capacity. They also call for regulatory exemptions for local private pipelines while requiring mutual recognition for storage in the United Kingdom.
These changes would lower costs and facilitate the decarbonization of the company’s hydrogen production assets.
Current storage operators lose market dominance through mandatory unbundling and increased transparency requirements.

Seas At Risk urges EU to halt CCS infrastructure plans

Seas At Risk, 10 Sept 2025

The organization calls for an immediate halt to infrastructure development and a ban on carbon storage in marine environments. They demand that the EU prioritize deep emission cuts and ecosystem restoration over high-risk technological solutions.
The organization would secure better protection for marine ecosystems and ensure funding goes to nature-based solutions.
Energy companies lose the infrastructure support needed to maintain fossil fuel-based business models.

Zero Waste Europe warns CO2 infrastructure risks locking in incineration

Zero Waste Europe, 25 Aug 2025

ZWE demands a holistic impact assessment prioritizing the circular economy and resource efficiency. They insist CO2 infrastructure should only support incineration if waste prevention and recycling are fully maximized. CCS must not justify expanding capacity or prolonging old plant lifetimes.
This approach ensures that investments support zero-emission pathways rather than outdated waste treatment.
Operators of polluting waste-to-energy plants lose the opportunity to extend their facilities' operational life.

German local utilities urge CO2 infrastructure while prioritizing water safety

Verband Kommunaler Unternehmen e.V., 11 Sept 2025

VKU supports CCU/S to decarbonize waste management and generate negative emissions. They demand a ban on CO2 storage in water protection areas to safeguard drinking water. They also call for uniform EU-wide standards and cross-border infrastructure planning.
This ensures a viable decarbonization path for waste facilities while protecting water assets.
CCS storage developers lose access to potential sites situated in water protection areas.

European Sea Ports Organisation demands CO2 infrastructure recognition

European Sea Ports Organisation, 11 Sept 2025

ESPO calls for a supply chain approach that fully recognises the role of ports in carbon capture. They request fast-tracked permitting and dedicated funding for specialized infrastructure like pipelines and terminals. The group also advocates for classifying CO2 as a commodity instead of waste to ease transport.
These changes would reduce investment risks and accelerate port-based decarbonisation projects.
Local communities may face faster industrial expansion with reduced power to block projects.

Repsol calls for market-based CO2 transport network development

Repsol, S.A., 11 Sept 2025

Repsol requests that CO2 network development focus on industrial clusters with comprehensive cost-benefit analysis of transport alternatives. They advocate for market-based regimes, tax incentives, and Carbon Contracts for Difference to stimulate investment while avoiding underutilized assets.
This would reduce infrastructure costs borne by industry and protect competitiveness.

Snam urges regulated business models for CO2 transport infrastructure

Snam S.p.A., 11 Sept 2025

Snam proposes a regulated framework using the Regulatory Asset Base model for infrastructure access. They request full cost coverage and protection from risks like underutilized pipelines.
This framework guarantees stable capital returns and protects Snam from infrastructure underutilization.
Member States or taxpayers bear financial risks if industrial demand for transportation fails.

Clean Air Task Force urges fair access rules for EU CO2 networks

Clean Air Task Force, Inc., 11 Sept 2025

The organization requests regulations ensuring equal third-party access to CO2 infrastructure, preventing excessive tariffs that deter investment, and mitigating coordination risks. They call for appropriately sized networks with cross-border provisions and standardized CO2 specifications.
This would enable climate NGO advocacy goals by ensuring infrastructure supports rapid decarbonization.
Infrastructure developers face stricter regulation limiting monopoly pricing power and operational flexibility.

Wiener Stadtwerke urges EU to share CO2 pipeline investment risks

WIENER STADTWERKE GmbH, 2 Sept 2025

They want member states to share investment risks and provide financial security for emitters. They suggest a flat tariff system based on volume rather than distance for landlocked regions. They also call for faster permitting and standardized CO2 purity requirements across networks.
Shifting financial risk to the state would reduce the company's significant investment burden.
Coastal regions and emitters near storage sites would lose the advantage of proximity.

FEPORT urges investment in port CO2 transhipment infrastructure

FEPORT, 11 Sept 2025

The organization calls for recognizing ports as essential nodes and investing in CO2 transhipment infrastructure. They request financial incentives through the EU ETS to ensure returns on carbon capture projects.
This would resolve current infrastructure bottlenecks and secure returns on high-cost terminal investments.

Bellona Europa Urges New EU Authority for CO2 Infrastructure

Bellona Europa, 11 Sept 2025

The organization requests an independent EU authority for CO2 network planning and coordination. They call for non-discriminatory infrastructure access and a cross-border CCUS Network Code.
A unified regulatory framework would reduce carbon abatement costs and prevent national fragmentation.
Infrastructure operators would be prevented from charging excessive tariffs or extracting monopoly rents.

Carbon Gap urges inclusive EU rules for carbon removal infrastructure

Carbon Gap ASBL, 11 Sept 2025

The organization requests that new infrastructure rules accommodate carbon removal technologies alongside traditional capture methods. They advocate for an integrated system with non-discriminatory access to pipelines for all CO2 types.
This ensures carbon removal projects can access essential infrastructure without being sidelined by industrial giants.
Legacy industrial emitters might lose exclusive control over carbon management networks and public funding.

Tata Steel Nederland urges EU carbon transport infrastructure rules

Tata Steel Nederland, 11 Sept 2025

The company requests independent regulatory oversight to prevent monopolies and ensure fair access to carbon storage. They advocate for government funding to bridge the price gap between storage costs and carbon taxes. Additionally, they call for a coordinated EU-wide plan for cross-border carbon transport pipelines.
These measures would protect the company from financial losses if technical issues disrupt carbon storage services.
Taxpayers may face higher burdens if public funds are used to absorb the industry's financial risks.

Heidelberg Materials urges integrated EU framework for CO2 transport

Heidelberg Materials AG, 11 Sept 2025

The company requests an integrated EU-wide CO2 network with open access and faster permitting. They want financial tools to lower risks and recognition for carbon utilization efforts.
Financial mechanisms would help the company avoid bearing the full costs of infrastructure.
Environmental advocates could see standard oversight weakened by fast-tracking projects as public interest.

Orlen urges investment-friendly EU framework for CO2 transport markets

Orlen S.A., 11 Sept 2025

Orlen requests increased public funding and tax incentives to lower investment risks for carbon capture facilities. They advocate for simplified cross-border transport rules and a new dedicated category for CO2 infrastructure. The company also suggests allowing early investors to prioritize their own capacity over third-party access.
Orlen would lower its financial exposure while maintaining strategic control over its transport infrastructure.
Smaller competitors lose out if large operators are allowed to restrict third-party pipeline access.

Enagás urges EU to let gas operators lead CO2 networks

Enagás S.A., 11 Sept 2025

The organization argues that natural gas network operators are best positioned to manage CO2 infrastructure due to their existing expertise. They recommend a flexible, hub-based planning approach that avoids imposing uniform regulatory models too early. Additionally, dedicated financing instruments are needed to reduce investment risks for industrial decarbonisation.
Enagás would secure its market position by repurposing gas assets for CO2.
Industrial investors face delays if the EU imposes rigid regulatory frameworks.

European Barge Union Urges CO2 Transport via Inland Waterways

European Barge Union, 13 Aug 2025

The EBU argues that inland waterways are ready for CO2 transport. They request the sector take a leading role in these new markets.
This would allow barge operators to secure new business by absorbing CO2 flows.

Port of Rotterdam urges EU strategy for CO2 infrastructure corridors

Havenbedrijf Rotterdam NV, 11 Sept 2025

The Port of Rotterdam urges an EU-wide CO2 infrastructure strategy focused on strategic corridors. They request that advanced projects be shielded from new regulatory burdens while fast-tracking permitting. They also propose financial tools to bridge the gap between costs and carbon prices.
This would solidify Rotterdam's position as a dominant hub for European carbon management.
Developers of competing parallel pipelines may be sidelined to prioritize specific strategic corridors.

Carbon Capture Association urges flexible rules for CO2 transport

Carbon Capture & Storage Association, 11 Sept 2025

The EU should address structural barriers by unlocking storage access outside the bloc. Regulatory design must remain flexible, avoiding prescriptive rules that could stifle the industry. They also demand significantly increased funding and risk-mitigation tools under the next budget.
This approach provides the regulatory predictability and financial guarantees required to unlock investment.
Dominant market players lose the ability to restrict access through anti-competitive practices.

Negative Emissions Platform wants removals in CO2 infrastructure laws

Negative Emissions Platform, 11 Sept 2025

NEP urges the inclusion of permanent carbon removal in upcoming infrastructure legislation. They call for two European-level investment projects and a strategy to scale up removal technologies.
Integrating removals early would reduce long-term costs and provide the certainty investors need.
Smaller removal projects risk being crowded out of infrastructure by larger, established industrial emitters.

Business & Science Poland Urges Funding for CO2 Infrastructure

Związek Pracodawców Business & Science Poland, 11 Sept 2025

BSP requests a framework providing clear regulations and suitable funding support for investors. They recommend separating the value chain to allocate specific funds for capture installations. The group suggests removing barriers to storage in marine basins like the Baltic.
Subsidies and tax incentives would help Polish metal producers maintain their global competitiveness.
Carbon market participants could face lower liquidity if removals are integrated into trading.

Westenergy Urges EU to Include Carbon Utilization in Infrastructure Plans

Westenergy Oy, 11 Sept 2025

Westenergy calls for open two-way access to pipelines and intermediate storages to support carbon utilization. They advocate for EU-wide CO2 quality standards and infrastructure designed for smaller emitters like waste-to-energy plants.
This allows inland waste-to-energy plants to overcome geographical barriers and transport carbon for reuse.

Waste-to-energy sector urges inclusion in EU CO2 infrastructure planning

Confederation of European Waste-to-Energy Plants, 11 Sept 2025

The sector seeks guaranteed access to CO2 transport networks and inclusion in European infrastructure planning. They argue for exclusion from the carbon trading system in favor of specific decarbonization incentives.
This allows plants to bypass expensive carbon taxes while securing technical support for decarbonization.
Local economies would bear higher costs if these facilities face carbon taxes without infrastructure.

Vantaan Energia Demands Robust EU Carbon Transport Infrastructure

Vantaan Energia, 9 Sept 2025

VE calls for a complete value chain and coordination for cross-border operability. They request tailored support mechanisms and carbon removal integration into the ETS.
This would reduce financial risks for their planned one-billion-euro carbon capture project.
Competitors in waste incineration lacking carbon capture would face significantly higher compliance costs.

Port of Antwerp-Bruges urges unbundled EU CO2 transport network

Havenbedrijf Antwerpen - Brugge NV van publiek recht, 11 Sept 2025

Appoint independent carbon network operators to ensure cost-efficient investment planning. Apply light regulated third-party access to pipelines to balance open access with investment. Designate CO2 infrastructure as having overriding public interest to expedite permitting.
Regulated cost recovery and mutualization would lower financial risks for infrastructure developers.
Private developers lose the ability to build exclusive, fragmented transport infrastructure.

Energinet urges flexible and future-proof EU CO2 infrastructure rules

Energinet, 4 Sept 2025

Energinet requests a flexible regulatory approach prioritizing long-term planning over immediate savings. They advocate for shared pipeline access and common standards to support cross-border flows.
Energinet would secure its position as a regulated natural monopoly for pipeline transport.
Proponents of short-term cost-cutting lose if support schemes prioritize expensive, future-proof capacity.

Consultation response

PowerShift - Verein fuer eine oekologisch-solidarische Energie- Weltwirtschaft e.V., 8 Sept 2025

We must express our deepest concerns about this consultation. There is no evidence that establishing a CO2 infrastructure in the EU would help to combat climate change. On the contrary, it would undoubtedly cause additional CO2 emissions, thereby undermining climate protection efforts. Despite…

Fluxys urges independent operators for EU carbon transport network

Fluxys SA, 11 Sept 2025

The organization proposes neutral carbon network operators legally unbundled from emitters. They suggest a light form of regulated access to balance infrastructure with investment. They call for a guarantee mechanism to address liabilities that are hard to insure.
Fluxys would leverage its gas expertise to dominate the market through pipeline repurposing.
Private firms are restricted from building dedicated infrastructure for their own industrial needs.

Consultation response

Open Grid Europe GmbH, 11 Sept 2025

CO-Abscheidung, -Transport, -Speicherung und -Nutzung (CCUS) sind unverzichtbare Bestandteile der EU-Klimastrategie. Die Zeit drängt: Der Aufbau einer funktionsfähigen CO-Transportinfrastruktur und -Wertschöpfungskette muss schnell erfolgen. Die Investitionsbereitschaft und konkrete Projektplanung…

NaTran Advocates for Regulated CO2 Networks and Multi-Gas Synergies

NaTran, 9 Sept 2025

NaTran proposes dual planning and mandatory third-party access to ensure fair competition. They suggest financing models combining anchor user commitments, private investment, and government guarantees.
Leveraging existing gas infrastructure and operational synergies would significantly reduce deployment costs.
Smaller industrial players might be excluded if infrastructure requires long-term commitments they cannot provide.

Consultation response

Ragn Sells AS, 8 Sept 2025

Legislative initiative on CO2 transportation infrastructure and markets Estonia has accumulated over 1 billion tons of industrial waste, including 500 million tons of oil shale ash, which burdens the environment. These ash deposits now present an opportunity to reclaim critical raw materials like…

Czech Chamber urges gas-style model for CO2 transport networks

Hospodářská komora České republiky, 3 Sept 2025

The Chamber recommends that CO2 transportation could be organized similarly to the natural gas market model. They argue gas operators are well-positioned to manage networks and require public funds for high costs.
Infrastructure firms can leverage their existing corridors and expertise to dominate the new carbon transport market.
Taxpayers face potential financial liabilities if state guarantees are invoked to cover insufficient user commitments.

CCU industry urges inclusion in EU CO2 transport infrastructure plans

CO2 Value Europe AISBL, 11 Sept 2025

The organization requests that carbon capture and utilization (CCU) be included alongside carbon capture and storage (CCS) in CO2 transport infrastructure planning. They argue that CCU projects can work in synergies with CCS and contribute revenues for infrastructure-building. They call for comprehensive market-pull mechanisms to drive companies away from fossil resources.
This would enable their members to access CO2 transport infrastructure and create revenue streams from CCU products.

Stadtwerke München urges EU to secure CO2 transport investments

Stadtwerke München GmbH, 10 Sept 2025

SWM calls for a cross-border CO2 pipeline network with uniform quality standards and state financial guarantees to reduce investment risks. They recommend integrating negative emissions into the EU Emissions Trading System to incentivize carbon removal technologies. They also advocate for enabling CO2 trade and storage with non-EU countries like the UK and Norway.
State guarantees and standardized infrastructure would lower investment risks and costs for their decarbonization projects.
Taxpayers may face financial risks if the state provides subsidies and guarantees for underused infrastructure.

Consultation response

Verein Deutscher Zementwerke e.V., 22 Aug 2025

VDZ thanks for the opportunity to provide additional input on the development of a robust European CO infrastructure and welcomes the EU Commissions intention to establish, if necessary, a new legislative initiative with rules for an EU CO2 market and a CO2 infrastructure. This shall also consider,…

Industrial gas group seeks unbundled transport and storage

European Industrial Gases Association AISBL, 11 Sept 2025

EIGA requests non-discriminatory storage access and unbundling transport from storage operations. They also suggest avoiding over-regulation of private industrial hubs to maintain flexibility.
Cheaper onshore storage closer to emission sources would significantly lower their operational costs.
Existing storage operators lose their competitive advantage through mandatory data sharing and unbundling.

Consultation response

Equilibre des Energies, 11 Sept 2025

EdEn believes CO2 capture and storage will be needed to offset residual emissions from hard-to-abate industrial sectors. Industrial carbon removals from biogenic and possibly from atmospheric sources will also be an essential component in the manufacture of chemicals, plastic products and synthetic…

Teréga Urges Harmonized Rules and Subsidies for CO2 Networks

Teréga, 10 Sept 2025

Teréga requests a harmonized regulatory framework and robust financial support mechanisms. They prioritize onshore storage and state guarantees to mitigate investment risks.
Public guarantees and subsidies would reduce Teréga's financial risks and costs.
BECCS and BECCU developers might lose out if other incentives are prioritized.

Consultation response

Grand Port Fluvio-maritime de l'Axe Seine, 10 Sept 2025

The Major River-Sea Port of the Seine Axis HAROPA PORT has united the ports of Le Havre, Rouen, and Paris under one public authority since 2021. As Frances largest port, it handles 102 million tonnes of annual maritime and inland traffic, generating 7.3 billion in economic value and supporting…

Consultation response

Center for International Environmental Law, 11 Sept 2025

Investments in CO2 transport infrastructure risk diverting critical time and resources away from more effective climate action, while simultaneously prolonging reliance on fossil fuels. Building large-scale CO2 transport infrastructure to support Carbon Capture & Storage (CCS), Carbon Capture &…

Consultation response

GAZ-SYSTEM S.A., 11 Sept 2025

CCUS technology can play a pivotal role in the energy transition and the decarbonisation of European industry, while making a significant contribution to the overarching objectives of EU climate policy. The establishment of coherent, transparent and EU-wide regulatory frameworks should enable the…

European Lime Association urges fair access to CO2 transport networks

European Lime Association, 11 Sept 2025

EuLA calls for regulated third-party access and fair tariffs for small emitters. They propose EU-wide infrastructure planning and financial de-risking tools like CCfDs. The group seeks fast-track permitting and limited liability after CO2 custody transfer.
Regulated access prevents high costs and ensures smaller lime plants can decarbonize.
Infrastructure operators lose the power to charge discriminatory prices to smaller emitters.

Consultation response

Global CCS Institute Ltd, 11 Sept 2025

The Global CCS Institute (Institute) welcomes the opportunity to offer its perspective in response to the call for evidence launched by the European Commission on the future legislative initiative on CO2 transportation infrastructure and markets. The Institute is an international think tank whose…

Finnish Bioenergy Association Urges Priority for Biogenic CO2 Infrastructure

Bioenergia ry - Bioenergy Association of Finland, 11 Sept 2025

The association requests explicit regulatory recognition of biogenic CO2, targeted transport infrastructure development, and funding models that prioritise early connection of biogenic sources. They emphasise that coordinated infrastructure development and market design valuing permanent removals are essential.
This would unlock their biogenic CO2 streams for the emerging market and reduce infrastructure costs.

German fuel industry urges CO2 infrastructure access and regulatory support

Wirtschaftsverband Fuels und Energie e. V., 11 Sept 2025

The association requests guaranteed access to CO2 pipeline infrastructure for refineries, allowance of CO2 exports outside the EU for storage, and integration of negative emissions technologies into the EU emissions trading system by 2030. They seek to avoid double pricing of CO2 in the EU-ETS and want support for early adopters of CO2 infrastructure through suitable relief mechanisms.
This would enable them to decarbonize unavoidable refinery emissions while maintaining hydrocarbon production for chemical feedstocks.
Climate advocates lose stronger carbon pricing if double-charging is removed and negative emissions create offset loopholes.

Spanish cement industry urges EU-wide CO2 transport network

Agrupación de fabricantes de cemento de España, 10 Sept 2025

The group requests regulated third-party access to CO2 networks and streamlined permitting processes. They also advocate for EU-wide standards and financial tools like Carbon Contracts for Difference.
This would lower decarbonization costs and ensure the sector's long-term economic viability.
Owners of private CO2 infrastructure might lose exclusive control due to mandatory access requirements.

ECGA urges public funding for carbon capture infrastructure

European Advanced Carbon and Graphite Materials Association, 4 Sept 2025

The association demands that transport infrastructure costs are not the responsibility of private emitters. They call for targeted financing and revenue stabilisation to manage high capture costs.
Shifting these massive costs to the public sector prevents industrial relocation abroad.
Renewable energy sectors lose if public funds are diverted to carbon infrastructure.

Consultation response

Koninklijke Vopak N.V., 11 Sept 2025

Royal Vopak welcomes the opportunity to provide input on the European Commission's Call for Evidence concerning the development of a CO market and infrastructure in the EU. We are committed to the energy transition, underscored by our pledge to invest EUR 1 billion in infrastructure for the energy…

Consultation response

MVV Energie AG, 10 Sept 2025

Wir reichen die ausführliche Stellungnahme der MVV Energie AG zur Initiative CO2-Markt und CO2-Infrastruktur in der EU als angehängtes PDF-Dokument ein.

Waste-to-Energy suppliers urge voluntary EU carbon capture framework

European Suppliers of Waste-to-Energy Technology, 11 Sept 2025

The organization calls for a comprehensive CO2 market that enables voluntary carbon capture deployment. They demand transparent third-party access and multiple transport modes, including rail and truck, for diverse plants.
Voluntary implementation prevents burdensome costs for facilities while allowing them to sell carbon credits.
Monopolistic infrastructure providers lose market dominance through mandatory third-party access and diverse transport requirements.

Consultation response

Celanese Performance Solutions Switzerland Sàrl, 11 Sept 2025

Celanese highly welcomes the European Commissions legislative initiative on CO2 transportation infrastructure and markets as a necessary first step of a fully-fledged EU CCUS policy framework. However, it is of critical importance for the upscale of CCUS technologies in Europe that this framework…

Consultation response

Carbon Capture Storage Europe, 11 Sept 2025

CCS Europe welcomes the opportunity to contribute to the European Commissions call for evidence on the forthcoming legislation for CO transportation infrastructure and markets. The capture of CO2 for permanent storage or use with a climate benefit is recognised by the European Commission as…

Consultation response

NRW.Energy4Climate GmbH, 10 Sept 2025

Wir unterstützen eine europäisch koordinierte Initiative für den Hochlauf von CO2-Infrastrukturen. Als Input zum Call for Evidence kann einerseits unsere Karte dienen, die einen Überblick über die Standorte aktuell diskutierter CCU/CCS-Vorhaben gibt (mit einem Fokus auf NRW):…

Polish chemical industry urges separate funding for carbon capture

Polska Izba Przemysłu Chemicznego, 11 Sept 2025

The organization recommends a "separate the CCS value chain" to allow emitters to focus solely on capture technology. They request "dedicated funds" for capture installations and a "reduction (by 50-70%) in ETS fees" to ensure global competitiveness.
This approach would protect firms from being burdened with additional costs of hundreds of millions.
Climate advocacy groups may object to extending the period of fossil-based fuel production.

Consultation response

bayernets GmbH, 11 Sept 2025

Dear Sir and Madam, please find our feedback attached. Best Regards Simona Rens

Consultation response

Polski Klub Ekologiczny Okręg Mazowiecki, 11 Sept 2025

Polski Klub Ekologiczny Okręg Mazowiecki ma głębokie wątpliwości i obawy związane z proponowanymi zmianami. W naszej ocenie rozwiązania z zakresu wychwytywania i przechowywania CO2, a szczególnie przesyłania go na większe odległości i zatłaczania do struktur geologicznych są przykładem życzeniowego…

Consultation response

Chemelot, 3 Sept 2025

Chemelot welcomes the European Commissions initiative to create a strong framework for CO transport infrastructure and market design. Without large-scale Carbon Capture, Utilisation and Storage (CCUS), the EU will not meet its 2050 climate neutrality target. CCUS is particularly essential for…

Consultation response

Bundesverband Carbon Management Solutons, 11 Sept 2025

The role of the state is to set up the regulatory framework to achieve economic growth and the climate objectives. Companies should decide in which technology they would like to invest. One key challenge is that regulatory certainty is currently in the process of being developed in the Member…

Consultation response

Związek Pracodawców Polska Miedź (The Polish Copper Employers' Association), 11 Sept 2025

Legnica, 10th September 2025 ZPPM / 18S / IX / 2025 European Commission Directorate-General for Energy (DG ENER) Decarbonisation and Sustainability of Energy Sources (ENER.C.2) Rue Demot 24 / Demotstraat 24 1040 B - 1049 Brussels Belgium Position of the Polish Copper Employers Association on…

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Spanish CO2 Technology Platform (Plataforma Tecnológica Española del CO2), 11 Sept 2025

PTECO2 welcomes the opportunity to provide feedback through this call for evidence to the upcoming legislative initiative on CO transport infrastructure and markets. PTECO2 an initiative promoted by the private sector, research centers, and Spanish universities aimed at fostering the development…

Consultation response

CONFEDERACIÓN ESPAÑOLA DE LAS INDUSTRIAS DE LAS MATERIAS PRIMAS MINERALES, 11 Sept 2025

PRIMIGEA welcomes the opportunity to provide its input on the European Commissions legislative initiative regarding CO transport and storage infrastructure. We positively receive this consultation as a means to defend the legitimate interests of our members in the extractive industries of mineral…

Consultation response

NET4GAS, s.r.o., 10 Sept 2025

NET4GAS is in full support of Commission's intention to establish a framework enabling the emergence of CO2 infrastructure and a well-functioning market for CO2. Please find below the list of principles and mechanisms the proposal shall include. Regulatory Framework and Governance The regulation of…

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Oil Change International, 10 Sept 2025

Carbon capture and storage (CCS) is extremely expensive, cannot actually capture sufficient emissions or store them safely, and will expose local communities and nature to risk across Europe if a CO2 transport network is built. The EU must not allow the fossil fuel lobby to continue to direct EU…

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE MAGNESIA, 10 Sept 2025

MAGES appreciates the opportunity to contribute to the European Commissions public consultation on the Legislative initiative on CO transportation infrastructure and markets. Our position paper outlines actionable steps for a coherent, cross-border CO transport and storage framework, and we look…

Consultation response

DigitalTrade4.EU, 10 Sept 2025

Our feedback to the European Commission links the development of a CO Market and Infrastructure with the EU Trade Framework 2025 (EUTIR), advocating for a unified digital trust backbone. We demonstrate how EUTIRs secure, interoperable registry can provide legal certainty, reduce risks, and enable…

Consultation response

Dansk Offshore, 10 Sept 2025

Please find in the attached, Dansk Offshore - The Danish Industry association for upstream oil and gas production and CO2 storage, answer to the call for evidence all best Gorm Boe Petersen Head of Secretariat Dansk Offshore

Consultation response

Český plynárenský svaz, 9 Sept 2025

The Czech Gas Association fully supports the Commissions intention to establish a framework enabling the emergence of CO infrastructure and a well-functioning market for CO. Please find below the list of principles and mechanisms that the proposal should include. The full version of the feedback…

Consultation response

MGH Energy, 5 Sept 2025

As an e-fuel (RFNBOs) project developer, MGH Energy welcomes this call for evidence which implements commitments made in the EU Carbon Management Strategy (ICM) of 6 February 2024: - Propose a future CO2 transport regulatory package; - Propose an EU-wide CO2 transport infrastructure planning…

Consultation response

The International Association of Independent Tanker Owners, 3 Sept 2025

INTERTANKO welcomes the renewed momentum for CCS/CCU in current EU policy discussions. This technology is critical to decarbonise hard-to-abate heavy industries, and it will be absolutely instrumental for the EU to successfully reach net-zero emissions by mid-century. This renewed momentum calls…