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Permanent storage of EU ETS emissions through carbon capture and utilisation

Climate action

The EU ETS Directive has been revised with the EU target set out in the European Climate Law to reduce net greenhouse gas (GHG) emissions by 55% by 2030, compared to 1990 levels. This Delegated Act, adopted pursuant to Article 12(3b) of the EU ETS Directive, will establish the conditions under which ETS emissions can be considered necessary to consider that these greenhouse gases have become permanently chemically bound in a product so that they do not enter the atmosphere under normal use and under any normal end-of-life activity.

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Public consultation

ID: 14135

Lobbying Activity

54 responses

Environmental Groups Demand Stricter CO2 Storage Permanence Rules

European Environmental Bureau, 16 Jul 2024

The organization supports the permanence requirement but demands stricter enforcement to prevent delayed emissions. They call for excluding products where CO2 could be released through deterioration processes and for publishing a list of non-compliant products.
This would prevent industries from claiming climate benefits for products that release CO2 later.
Synthetic fuel producers and industries using incineration lose eligibility for EU ETS credits.

WWF warns against industry pressure on EU carbon storage rules

WWF European Policy Programme, 16 Jul 2024

WWF insists on a strict definition of permanence lasting several centuries and excluding natural carbonation processes. They urge the Commission to resist industry pressure and maintain a transparent whitelist for approved products.
Strict standards ensure that the EU ETS remains focused on direct emission reductions.
Industrial operators using unproven technologies or natural carbonation would be barred from ETS benefits.

Soda Ash Industry Seeks Recognition for Carbon Capture

European Chemical Industry Council, 16 Jul 2024

ESAPA requests that sodium carbonate be added to the list of products where CO2 is considered permanently chemically bound. They argue that soda ash production captures CO2 from limestone into a stable chemical compound. The industry emphasizes that sodium carbonate remains stable for centuries under normal conditions.
This would exempt their production emissions from EU carbon trading costs.
Glass manufacturers lose as they must still pay for emissions when heating degrades sodium carbonate.

Finnish Forest Industry urges uniform treatment of carbon-binding products

Finnish Forest Industries Federation (Metsäteollisuus ry), 15 Jul 2024

The industry requests that all applications of precipitated calcium carbonate remain eligible for emission subtractions. They argue carbon is chemically bound in these stable products regardless of end use.
This prevents increased emission costs for paper producers and protects existing technology investments.

BASF urges EU to recognize carbon capture utilization in emissions trading

BASF SE, 15 Jul 2024

BASF requests that the EU recognize the climate benefits of carbon capture and utilization for both short- and long-lived products. They argue the current system creates regulatory barriers and risks double counting when waste incineration enters the emissions trading system.
This would allow them to count captured carbon as emissions reductions across their product portfolio.
Climate integrity suffers if short-lived products claim permanent carbon removal despite releasing CO2 at end-of-life.

EDF backs carbon storage rules while prioritizing direct electrification

ELECTRICITE DE FRANCE, 16 Jul 2024

EDF requests prioritizing direct electrification and energy efficiency over carbon capture technologies. Carbon capture should target unavoidable emissions in specific hard-to-abate industrial sectors. They call for clear EU management and prioritization of carbon dioxide resources.
This approach protects EDF's core electricity business while clarifying new regulatory requirements.
Carbon capture developers might face slower adoption due to the proposed prioritization hierarchy.

Wirtschaftskammer Österreich urges broader carbon storage definitions

Wirtschaftskammer Österreich, 16 Jul 2024

The organization argues that the definition of permanent carbon storage is too restrictive. They request that thirty-year storage and technologies like methane splitting be officially recognized.
Broadening definitions would lower compliance costs and provide investment security for industrial members.

European Aluminium urges inclusion of industrial by-products in CCU rules

European Aluminium AISBL, 16 Jul 2024

The organization proposes adding "carbonated industrial by-products" like processed bauxite to the list of permanent carbon storage solutions. They want alumina refineries to receive credit for chemically binding gases into materials used for cement and construction.
Refineries would benefit from new revenue streams and lower carbon costs by repurposing waste into valuable resources.
Traditional cement material suppliers may lose market share to these subsidised, carbon-neutral industrial alternatives.

Paper Industry Warns Against Penalising Carbon Capture in Production

Confederation of European Paper Industries, 15 Jul 2024

Cepi requests that the delegated act should not differentiate between end applications of precipitated calcium carbonate. The current Monitoring and Reporting Regulation treats all PCC applications equally, and this approach should be maintained. Companies have invested in CO2 capture infrastructure that chemically binds carbon in PCC, preventing atmospheric release.
This would preserve their ability to deduct captured CO2 from emissions accounting and avoid being penalised for carbon capture investments.

Eurogas urges inclusion of solid carbon in storage rules

EUROGAS, 15 Jul 2024

Eurogas requests that solid carbon from chemical processes be recognized as permanent sequestration. They also call for clear rules on long-term liability and carbon tracking throughout the product lifecycle.
This would exempt their processes from the costly obligation to surrender carbon allowances.
Climate objectives may be compromised if monitoring fails to ensure carbon remains stored for centuries.

CEMBUREAU Urges Broader Recognition of Permanent CO2 Storage in Products

CEMBUREAU - The European Cement Association, 15 Jul 2024

The cement industry requests recognition that CO2 storage in recycled chemical products like plastics should count as permanent if properly recycled. They also want CO2 allowances surrendered by emitters rather than capturing installations for non-permanent uses.
This would enable carbon capture investments at landlocked cement kilns without geological storage access.
Environmental groups lose stricter controls ensuring CO2 remains permanently removed from atmosphere.

Ceramic Industry Urges Broader CCU Recognition in EU ETS

European Ceramic Industry Association, 16 Jul 2024

The industry requests adding 'clay' to specify 'carbonated clay bricks and tiles' for precision. They also want inclusion of carbonated recycled steelslag aggregates as eligible products. They argue remineralization processes should be recognized more broadly in the EU ETS.
This would enable more ceramic manufacturing processes to achieve climate neutrality through CCU.

Biogas group seeks special recognition for biogenic carbon storage

European Biogas Association, 16 Jul 2024

The group requests a clear distinction between biogenic and fossil carbon sources. They also want biochar included as a form of permanent storage.
The sector would profit from their low-cost carbon being prioritized in regulations.
Fossil fuel processors would face a competitive disadvantage under these proposed rules.

Consultation response

Verband der Chemischen Industrie e.V., 12 Jul 2024

Rechtsakt löst bestehende Probleme bei Anerkennung von CCU nicht Der vorgelegte delegierte Rechtsakt löst die bestehenden Hemmnisse bei der Förderung und Incentivierung von CCU nicht. CO2 wird ein zukünftiger Rohstoff sein und damit dazu beitragen, fossile Rohstoffe ersetzen. Eine pragmatischere…

Spanish business group urges wider recognition of carbon capture

CEOE - Confederación Española de Organizaciones Empresariales, 16 Jul 2024

The organization wants the Commission to recognize all carbon capture technologies providing long-term storage. They advocate for a fast, simple process to approve new carbon-based products.
Efficient approval processes would prevent regulatory delays from blocking innovation and private investment.

Snam urges more flexible EU carbon capture storage rules

Snam S.p.A., 16 Jul 2024

Snam argues the approach is too restrictive and should include recyclable products like plastics. They also suggest adding specific chemical products to the list of permanent storage solutions.
Broader rules would allow Snam to provide carbon services to more industrial sectors.
Climate groups may fear that including recyclable products increases the risk of carbon re-emission.

Wiener Stadtwerke urges support for non-permanent carbon capture

WIENER STADTWERKE GmbH, 16 Jul 2024

The group requests new rules to support non-permanent carbon capture for chemicals and plastics. They argue the current system unfairly penalizes recycled carbon while favoring fossil fuels. They also propose better recognition of waste-to-energy plants.
This would prevent their waste-to-energy plants from being unfairly charged for carbon that is reused.
Fossil fuel producers lose the regulatory advantage they currently hold over recycled carbon alternatives.

Plastics Recyclers Europe backs carbon capture rules and ETS expansion

Plastics Recyclers Europe, 15 Jul 2024

PRE supports rules ensuring captured emissions stay bound in products during use and disposal. They call for prioritizing recycling over carbon-intensive waste management to reduce emissions. Finally, they advocate for expanding the EU ETS to include under-contributing sectors.
Prioritizing recycling over disposal helps the industry maintain the value of plastic materials.
Carbon-intensive waste management operations may lose business to recyclers or face new regulations.

Consultation response

Bellona Europa, 16 Jul 2024

Bellona Europa welcomes the Commissions initiative in the upcoming Delegated Act to identify the products which can be considered to permanently chemically bind greenhouse gases, specifically captured CO2. Ultimately, installations generating CO2 will not need to surrender allowances only if they…

Waste Industry Calls for Producer Responsibility in Carbon Capture Rules

FEAD, 16 Jul 2024

FEAD requests that producers, not waste operators, be held responsible for ensuring captured CO2 doesn't re-enter the atmosphere. They want upstream accounting of emissions when products are placed on market, and broader recognition of carbon offsetting beyond ETS sectors including avoided emissions from recycling.
This would shift climate compliance costs away from waste operators who cannot control incoming waste streams.
Product manufacturers face increased responsibility and costs for managing end-of-life carbon emissions.

European sugar industry demands exemption from carbon accounting rules

COMITE EUROPEEN des FABRICANTS de SUCRE, 16 Jul 2024

CEFS requests that carbonated lime from sugar production be treated the same as natural limestone and exempt from emissions accounting. They want a negative list approach that excludes certain products from carbon accounting, arguing their carbonated lime is chemically identical to the original limestone.
This would eliminate their liability for emissions when carbonated lime is applied to soil.
Climate accountability suffers as CO2 emissions from agricultural lime application go unaccounted.

CCSA Backs Carbon Credits for Permanent Building Materials

Carbon Capture & Storage Association, 15 Jul 2024

The group supports removing the requirement to pay for carbon allowances for stored emissions. They agree that storage should last for at least several centuries.
This creates financial incentives for companies to develop carbon-storing building materials.

Negative Emissions Platform seeks harmonised carbon removal rules

Negative Emissions Platform, 15 Jul 2024

NEP supports aligning carbon storage definitions with the Carbon Removal Certification Framework. They request classifying carbon from biological sources and the air as removals for better incentives. They also advocate for including carbon removals in the European carbon market.
Classification as carbon removals would provide new financing and a stronger market demand signal.

Solvay urges inclusion of sodium carbonate in permanent carbon storage list

Solvay SA, 16 Jul 2024

Solvay requests adding sodium carbonate to the list of permanent carbon binding products. They argue the compound is chemically stable and stores carbon for centuries.
This would lower compliance costs by allowing CO2 to be considered sequestered rather than emitted.
Environmental groups lose if substances that release CO2 under heat are labeled as permanent.

Zero Emissions Platform Backs EU Permanent Carbon Storage Standards

Zero Emissions Platform, 15 Jul 2024

ZEP supports requirements for permanent capture where CO2 is permanently chemically bound. They advocate for mineralization and products lasting over 100 years.
Clear standards provide the right conditions for deploying industrial carbon management technologies.

Consultation response

Japan Business Council in Europe, 15 Jul 2024

The Japan Business Council in Europe (JBCE) appreciates the opportunity to provide comments on the European Commissions proposal for a Delegated Regulation for the EU-ETS. JBCE believes that the proposed regulation is an important step towards stimulating carbon removal markets and achieving the…

Vantaan Energia urges expanding list of permanent carbon storage products

Vantaan Energia, 9 Jul 2024

The company seeks to include concrete elements and facades in the storage list. They also want to prevent double counting of emissions for non-permanent carbon capture.
Local storage solutions would allow the company to avoid expensive carbon logistics chains.
Waste incinerators might pay multiple carbon fees for the same captured emissions loop.

France Chimie urges broader recognition of carbon capture products

France Chimie, 16 Jul 2024

France Chimie recommends a simple and rapid review process for new products to accelerate innovation. They advocate for recognizing all carbon utilization forms to prevent hindering industry development.
Member companies would reduce compliance costs and avoid legal uncertainty regarding carbon quota surrenders.

German waste industry urges EU to include short-lived carbon capture

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 16 Jul 2024

BDE requests including short-term carbon cycles like synthetic fuels rather than just permanent mineralization. They also want waste incineration CCU recognized under the EU Taxonomy to secure investment.
This allows waste plant operators to secure vital funding for expensive carbon capture infrastructure.
Fossil fuel suppliers face reduced demand as recycled carbon replaces virgin sources in production.

Consultation response

voestalpine AG, 16 Jul 2024

Thank you for the opportunity to comment. Please find our statement in the uploaded document.

CO2 Value Europe urges broader scope for permanent carbon storage

CO2 Value Europe AISBL, 16 Jul 2024

They call for including applications beyond construction where carbon is permanently stored in mineral carbonates. The association suggests adding innovative materials like carbon nanofibers to the eligible product list. They also seek to rectify rules that currently disincentivise non-permanent carbon utilisation.
This provides financial exemptions from carbon costs, strengthening the business case for CCU technologies.
Innovative manufacturers lose financial incentives if the storage definitions remain overly restrictive.

Industrial gas group EIGA seeks storage credits for water neutralization

European Industrial Gases Association AISBL, 16 Jul 2024

The association proposes including the use of captured carbon for water neutralization as a form of permanent storage. They argue dissolved carbonates in water streams retain carbon for centuries and should be recognized in the regulation.
Classifying water neutralization as storage would exempt member companies from paying for carbon allowances.

Sandbag urges stricter transparency for permanent carbon capture products

Sandbag Climate Campaign, 16 Jul 2024

Sandbag calls for a review process that allows for the removal of products from the approved list. They also recommend making all update requests and unsuccessful product evaluations publicly available to ensure accountability.
Stronger rules help ensure that the carbon capture market supports genuine, long-term climate mitigation.
Organizations with conflicts of interest lose the ability to lobby the Commission privately.

Consultation response

LanzaTech EU B.V, 12 Jul 2024

LanzaTech is disappointed by the approach proposed by the Commission that, if implemented, will slow the development of carbon capture and utilization (CCU), a strategic technology in the delivery of the EUs ambitious net-zero climate goals. Specifically, LanzaTech objects to the imposition of EU…

Ragn-Sells urges EU to recognize carbon stored in products

Ragn-Sellsföretagen, 16 Jul 2024

The organization requests that storage of fossil and biogenic carbon in products be considered permanent under a circular certification framework. They also urge the Commission to clarify which product categories fall under the regulation and their annual production volumes.
This would resolve business uncertainty and support the commercial viability of their patented carbon-negative technology.

Syctom urges CO2 storage status for municipal incinerator ash

Syctom Agence métropolitaine des déchets ménagers, 10 Jul 2024

Syctom requests including municipal waste management in the list of compliant carbon storage sectors. They want incinerator bottom ash recognized for its ability to permanently bind greenhouse gases.
This recognition would reduce the future carbon tax burden for waste incinerators.

Belgian chemical industry seeks flexible carbon capture storage rules

Fédération belge des industries chimiques et des sciences de la vie, 16 Jul 2024

Essenscia wants carbon storage rules to reflect product function rather than strict century-long timelines. They also demand that carbon-captured materials be treated the same as fossil alternatives during disposal.
This would lower compliance costs and prevent discrimination against their recycled carbon products.

Finnish Bioenergy Association urges biochar recognition in storage rules

Bioenergia ry - Bioenergy Association of Finland, 16 Jul 2024

The group calls for including biochar in storage rules to ensure regulatory coherence. They argue biogenic carbon storage should be incentivized as removal instead of an exemption.
This would create new revenue streams and ensure long-term certainty for bioenergy investors.

Hazardous Waste Europe urges wider scope for carbon capture rules

Hazardous Waste Europe, 16 Jul 2024

HWE calls for the framework to include non-ETS sectors and alternative technologies like solid carbon production. They also demand strict toxicity assessments to prevent hazardous waste dilution during carbonation.
Including non-ETS sectors allows hazardous waste firms to monetize their carbon reduction efforts.
Public safety could suffer if firms use carbonation to avoid strict hazardous waste controls.

Spanish chemical industry urges expansion of carbon storage list

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 16 Jul 2024

The federation calls for sodium carbonate and precipitated calcium carbonate to be added to the permanent storage list. They advocate for a faster review process and broader recognition of all carbon capture technologies. They also suggest simplifying how products with multiple end-of-life pathways are evaluated.
Broadening the list allows firms to avoid paying for greenhouse gas emissions.
Future generations may inherit unstable storage if permanence standards are significantly lowered.

Calcium carbonate industry urges changes to permanent carbon storage rules

Industrial Minerals Association - Europe, 15 Jul 2024

CCA-Europe requests three changes: eliminate double counting by placing emission obligations on industries releasing CO2, not those capturing it; focus end-of-life criteria on recyclability rather than incineration; and expand the Annex to include precipitated calcium carbonate applications in paper and construction products.
This would prevent double counting of emissions and allow PCC producers to deduct captured CO2.

Consultation response

Puro.earth, 16 Jul 2024

Hello, please find attached the feedback from Puro.earth, a global carbon-crediting platform for durable carbon removals. Kind regards, Marianne & Helen

Waste-to-energy firms urge broader carbon capture product recognition

European Suppliers of Waste-to-Energy Technology, 16 Jul 2024

ESWET calls for including incineration bottom ash in the regulation and broadening product definitions. They also advocate for upstream accounting to attribute emissions responsibility to producers at market entry.
This would strengthen the business case and financial incentives for carbon capture projects.
Product manufacturers would face higher costs and responsibility for emissions at market entry.

Consultation response

Bundesverband der Deutschen Kalkindustrie e.V., 16 Jul 2024

Der Bundesverband der Deutschen Kalkindustrie e. V. (BVK) begrüßt den Prozess der Festlegung der Bedingungen, unter denen abgeschiedenes CO als dauerhaft in einem Produkt gebunden angesehen werden kann, insbesondere die Anerkennung der Mineralisierung als robusten Prozess, der CO in einem stabilen…

Consultation response

Hycamite TCD Technologies Ltd, 16 Jul 2024

We at Hycamite welcome the opportunity to contribute our insights on the Emissions Trading System (ETS) Draft Delegated Act on Permanent CCU. We appreciate the efforts being made to combat climate change and reduce emissions. We would like to propose the inclusion of solid carbon, such as from…

Consultation response

France Ciment, 16 Jul 2024

France Ciment welcomes the Commission's first draft delegated act establishing criteria for CO2 pemanently chemically bound in a product. CCU constitutes a solution to reduce unavoidable emissions inherent to the cement production process. France Ciment calls for establishing a framework conducive…

Consultation response

NRW.Energy4Climate GmbH, 15 Jul 2024

NRW.Energy4Climate welcomes the Commissions legal clarification for the definition of carbon which is permanently chemically bound in products. However, as reflected in the products listed in the Annex meeting the necessary requirements, the assumed period for bound CO2 ("several centuries or…

Consultation response

European Calcium Silicate Producers Association, 16 Jul 2024

ECSPA appreciates the opportunity to provide feedback on the draft Delegated Regulation supplementing Directive 2003/87/EC as regards the requirements for considering that greenhouse gases have become permanently chemically bound in a product. ECSPA particularly welcomes that the draft Delegated…

Consultation response

RAG Companies, 16 Jul 2024

1) The Delegated Act on permanent CCU should encompass any source of carbon, once it can be managed in a sustainable way. Hence, an important innovation in the CCUS sector is methane electrolysis/plasmalysis/pyrolysis, which uses natural gas to produce climate-neutral hydrogen and solid carbon…

Consultation response

Fachverband der Stein- und keramischen Industrie, 16 Jul 2024

Wir setzen uns für den Grundsatz ein, dass Emissionen an dem Punkt erhoben und bepreist werden sollten, an dem die Emissionen in die Atmosphäre gelangen. Betreiber müssen bereits jetzt (und nicht erst ab der Revision des ETS in 2026) in der Lage sein, nachzuweisen, dass das abgeschiedene CO2…

FEDENE calls for incineration ash inclusion in carbon storage rules

Fédération des services énergie environnement, 16 Jul 2024

FEDENE calls for including incineration bottom ash carbonation technology in the current Delegated Act. They request a rigorous methodology for monitoring and reporting CO2 absorption.
This would reduce reported emissions and allow the reuse of ash in construction.

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE MAGNESIA, 16 Jul 2024

MAGES, la Asociación española de fabricantes de magnesia, acoge con satisfacción el proceso para establecer las condiciones en las que el CO2 capturado puede considerarse unido químicamente de forma permanente en un producto, en particular el reconocimiento de la mineralización como un proceso…

Consultation response

Spanish CO2 Technology Platform (Plataforma Tecnológica Española del CO2), 16 Jul 2024

La PTECO2 acoge con satisfacción el proceso para establecer las condiciones en las que el CO2 capturado puede considerarse unido químicamente de forma permanente en un producto y apoya firmemente la necesidad de establecer unas condiciones coherentes con el marco de certificación de la Unión para…

Consultation response

ASOCIACION NACIONAL DE FABRICANTES DE CALES Y DERIVADOS DE ESPAÑA, 15 Jul 2024

1) ANCADE advocates for the principle that emissions pricing should be applied at the point where emissions are released into the atmosphere. 2) ANCADE emphasizes the necessity for operators to have the ability to demonstrate that captured CO2 will remain permanently sequestered in products…