Bundesverband Carbon Management Solutons
BVCMS
Der BVCMS verbindet Klimaschutz und wirtschaftliche Wertschöpfung.
ID: 468890198897-83
Lobbying Activity
Response to Legislative initiative on CO2 transportation infrastructure and markets
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 States. Germany is just starting with its CCX regulation comprising CCU, CCS and pipeline infrastructure. It is, for instance, currently unclear how emissions legalisation is going to take into the sequestration of CO2. CCX technologies are offering an additional option to achieve the reduce emissions. To deploy the technology which will be strengthen the competitiveness will be to have access to infrastructure.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
8 Jul 2025
1. Introduction The Bundesverband Carbon Management Solutions / Carbon Management Association (BVCMS) welcomes the presentation of the Industrial Carbon Management Strategy (IDAA) as a significant step toward aligning the EUs transition to climate neutrality with the reinforcement of European economic competitiveness. Carbon Management comprise technology open approaches for CCU, CCS, CO2-transport and trade. Given the critical role of carbon management in achieving climate targets, attracting private sector investment is essential. A clear framework for state aid will be necessary. The stated aid should have the function to ramp up the CO2 market but should not replace private investment. The European Commission outlines three strategic pillars: 1. Accelerating permitting procedures for industrial access to clean energy and decarbonisation technologies, while maintaining high environmental standards; 2. Identifying and advancing priority projects and industrial clusters; 3. Establishing and safeguarding European lead markets for low-carbon products. Carbon management, particularly through Carbon Capture and Utilisation (CCU) and Carbon Capture and Storage (CCS), is set to play a pivotal role in EU climate policy. However, the current regulatory landscape remains fragmented both at the EU and Member State levels. This lack of coherence is impeding large-scale private investment from both the financial sector and industry. To unlock the full potential of industrial carbon management, it is essential to accelerate permitting procedures and implement qualitative public procurement criteria that prioritize low-carbon outcomes. These steps are crucial to enhance investment certainty and stimulate private sector engagement. At the same time, businesses require greater regulatory clarity to confidently develop and invest in emerging CO markets. In particular, Carbon Capture and Utilisation (CCU) would benefit from more precise guidance regarding its treatment under the EU Emissions Trading System (EU ETS), beyond the scope of Delegated Act C(2024) 5294. Future demand for CO - particularly from industrial users and hard-to-abate sectors such as aviation and maritime transport - will be significant. It must be recognized that the transformation of these sectors involves a substantial degree of complexity and effort. This should be reflected in policy frameworks and support mechanisms. Moreover, it is imperative that both CCU and Carbon Capture and Storage (CCS) contribute effectively to reducing the cost of compliance with the ETS.
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