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Oil and gas producers' contributions to the 2030 Union CO2 storage objective

Climate action

The Net-Zero Industry Act introduced the obligation for certain EU-based oil and gas producers to contribute to the Union objective of reaching 50 million tonnes of CO2 injection capacity in the EU by 2030. This Delegated Regulation will specify how contributing entities will be identified, how their contributions will be calculated, and how they will report on their progress towards meeting their contributions.

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Public consultation

ID: 14408

Lobbying Activity

19 responses

TotalEnergies Seeks Extended Timeline and Transparency on EU Carbon Storage Obligations

TotalEnergies SE, 16 Apr 2025

TotalEnergies requests a six-month extension to submit compliance plans (from June to December 2025), transparency on production data used to calculate obligations, and mandatory consultation with obligated entities before finalizing contributions. They also seek to exclude commercially sensitive information from public reporting and allow corporate groups to consolidate contributions across EU storage sites.
This would give them more time to prepare compliance plans and protect commercially sensitive customer information from disclosure.
The public loses transparency about which CO2 sources companies plan to store and their commercial agreements.

Shell urges delay in EU carbon storage targets, citing compliance challenges

Shell Companies, 16 Apr 2025

Shell requests that compliance be measured by Final Investment Decision rather than operational capacity, arguing the 2030 timeline is too short. They want the 2020-2023 production reference period averaged with current production to reduce obligations. Shell also seeks to allow Norwegian storage sites as compliance options and lower the exemption threshold for smaller producers to 1%.
This would reduce Shell's compliance obligations and give more time to meet targets.
Climate goals suffer as delays reduce pressure on major polluters to decarbonize quickly.

DIHK calls for faster CO2 storage permitting processes

Deutsche Industrie- und Handelskammer, 26 Mar 2025

The organization urges the acceleration of carbon capture infrastructure development. They recommend clear maximum time limits and binding deadlines for permitting authorities. They also support fair exemptions for small businesses to avoid unfair burdens.
Fixed timelines would give German industries better planning reliability and investment certainty.
Competent authorities would face increased administrative strain to meet new mandatory response deadlines.

IOGP Europe Urges Delay and Flexibility for CO2 Storage Goals

International Association of Oil Gas Producers Europe, 16 Apr 2025

IOGP Europe seeks the postponement of the June 2025 deadline and a one percent threshold. They propose a structured dialogue to verify production data and the calculation factor used.
This would provide legal certainty and ensure companies are not penalized for infrastructure delays.
Environmental advocates lose certainty because the proposal prioritizes investment decisions over actual operational capacity.

Eurogas urges delay and confidentiality in CO2 storage rules

EUROGAS, 16 Apr 2025

Eurogas requests postponing the plan submission deadline to December 2025 and calibrating exemption thresholds to protect smaller entities. They also call for protecting commercially sensitive data, such as potential storage customers, from public disclosure.
Producers would avoid disclosing sensitive business secrets while gaining extra time to prepare complex compliance strategies.
Reduced public transparency regarding carbon capture projects could limit local community engagement and oversight.

Clean Air Task Force calls for stronger CO2 storage reporting requirements

Clean Air Task Force, Inc., 16 Apr 2025

The organization supports the methodology for calculating producer contributions but requests stricter reporting requirements. They want obligated entities to provide detailed capacity estimates with uncertainty ranges, outline project risks and contingency plans, and clarify infrastructure responsibilities between storage sites and emitters.
This would reduce risk of under-delivery on CO2 storage targets they advocate for.

Bellona Europa urges strict CO2 storage accountability for producers

Bellona Europa, 16 Apr 2025

The organization demands a finalized list of obligated entities to ensure detailed planning by 2025. They advocate for robust reporting standards and mandatory penalties for non-compliance.
This ensures the deployment of infrastructure critical to Bellona's climate and industrial decarbonization goals.
Large oil and gas companies lose the ability to focus solely on high-profit extraction activities.

MOL Group urges delay and 1% threshold for CO2 storage

MOL Hungarian Oil and Gas Company, 16 Apr 2025

MOL requests postponing the 2025 planning deadline and setting a 1% production threshold for exemptions. They also demand the removal of requirements to disclose sensitive commercial project data.
This would reduce immediate compliance pressure and protect trade secrets from competitors.
Smaller oil and gas producers would be forced to contribute to storage targets.

Orlen calls for delay in carbon storage compliance deadlines

Orlen S.A., 16 Apr 2025

Orlen recommends postponing the June 2025 deadline due to insufficient preparation time. They request exemptions for small producers and the removal of detailed site coordinates. The company argues investment decisions should count as meeting the 2030 storage targets.
This would protect trade secrets and lower the risk of missing strict deadlines.
The European Union faces a higher risk of missing its 2030 climate goals.

OMV urges EU to include Norway in carbon storage targets

OMV Aktiengesellschaft, 16 Apr 2025

OMV stresses the urgency of expanding the geographical scope to Norway to allow for outside-EU contributions. They demand a fair distribution of obligations by strictly opposing exemptions for any non-SME producers. Additionally, they request that annual reports remain non-binding and protect sensitive trade secrets.
Using Norwegian sites would significantly reduce OMV's burden in meeting individual storage targets.
Smaller oil and gas producers would face new compliance costs if the exemption threshold is lowered.

Norwegian Industry Urges Inclusion of its Continental Shelf Storage

Confederation of Norwegian Enterprise, 15 Apr 2025

The organization insists that storage on the Norwegian Continental Shelf must count towards capacity obligations. They also recommend providing incentives for CO2 emitters to create market demand.
This would secure the business case for Norwegian projects and ensure their commercial viability.
Storage providers lose if they are obligated to build capacity without guaranteed emitters.

Zero Emissions Platform urges fair distribution of CO2 storage duties

Zero Emissions Platform, 16 Apr 2025

The platform calls for a fair distribution of storage obligations and exemptions for smaller companies. They seek clearer definitions regarding corporate changes and more precise reporting for actual injection capacity.
Clearer reporting rules and small company exemptions would reduce administrative costs and legal uncertainty.
Larger producers face higher costs if exempted capacity is reallocated to them unfairly.

Consultation response

Carbon Capture Storage Europe, 16 Apr 2025

CCS Europe welcomes the opportunity to comment on the European Commissions approach to the CO2 storage target under the Net-Zero Industry Act (NZIA), and to help guide its work on implementing the CO2 injection capacity obligation for the oil and gas sector. This draft Delegated Act goes in the…

Consultation response

Element NL, 16 Apr 2025

The attached file captures the position of Element NL the association of oil- and gas producers in the Netherlands on the draft Delegated Act regarding the contributions of E&P companies to the goal for CO2-storage in 2030. In this file you'll find our positions, questions for clarifications and…

Consultation response

Energie Beheer Nederland, 16 Apr 2025

The attached file captures the viewpoints of Energie Beheer Nederland (EBN, State Energy Company of the Netherlands) on the draft Delegated Act regarding producers contributions to the EUs 2030 storage objective as defined in the Net Zero Industry Act (NZIA) and additional comments regarding the…

Consultation response

SNGN ROMGAZ SA, 15 Apr 2025

ROMGAZ is the largest Romanian gas producer with a significant role in the countries energy supply security, and is one of the entities significantly impacted by the CO2 storage obligation provided by the Net Zero Industry Act. As much as we welcome all legal initiatives at EU level encouraging CO2…

Consultation response

Federation of Norwegian Industries (Norsk Industri), 8 Apr 2025

The Federation of Norwegian Industries, representing more than 3 200 industrial companies and more than 145 000 employees in Norway, welcome this opportunity to provide feedback on the delegated regulation on carbon storage under the Net Zero Industry Act (NZIA). Carbon capture and storage (CCS) as…

Consultation response

Bundesverband Erdgas, Erdöl und Geoenergie e.V., 15 Apr 2025

CO2 injection capacity objective - NZIA BVEG recommendations to the Draft Delegated Regulation specifying the rules on the identification of authorized oil and gas producers required to contribute to the objective of reaching the Union-target for available CO2 injection capacity by 2030, on the…

Consultation response

ORGANIZACIÓN LATINOAMERICANA DE ALCALDES, 24 Mar 2025

Hoy en día nos encontramos en una situación límite en la que se están investigando, intensamente, métodos de captura y almacenamiento de carbono. Lamentablemente, todas las actividades que realiza el ser humano han generado una acumulación de gases de efecto invernadero en la atmósfera,…