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CO2 Value Europe AISBL

CVE

CO2 Value Europe is a trade association promoting carbon capture and utilisation technologies.

Lobbying Activity

CO2 Value Europe urges inclusion of CCU in EU Taxonomy

4 Dec 2025
Topic — The consultation reviews the EU taxonomy environmental delegated act to update technical screening criteria.
Message — The association requests that the Taxonomy includes Carbon Capture and Utilisation in its entirety. They reiterate the need to be consistent with what other policy frameworks acknowledge as essential. This prevents mixed signals to public and private investors regarding necessary climate solutions.123
Why — Inclusion would ensure CCU projects secure vital funding and streamlined administrative support.45
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CO2 Value Europe urges including CCU in Circular Economy Act

5 Nov 2025
Topic — The consultation explores new legislative measures to promote a sustainable EU circular economy.
Message — They urge the inclusion of carbon capture and utilization as a circularity tool. The group proposes a binding definition for circular carbon feedstocks and mandatory production mandates.123
Why — Incentives would help carbon capture projects scale up and reach market competitiveness.45
Impact — Fossil fuel producers face displacement as captured carbon substitutes traditional virgin feedstocks.6
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CCU Industry Urges Swift Recognition of Mineralisation Carbon Removals

22 Sept 2025
Topic — EU regulation establishing certification methodologies for permanent carbon removal activities including DACCS and BioCCS.
Message — The organization requests swift adoption of rules recognizing mineralisation technologies using biogenic or DAC CO2 as carbon removals. They want harmonised definitions for DAC CO2 and biogenic CO2 across EU legislations, enabling CCU and CCS technologies to be deployed together. They urge avoiding replication of unworkable legal precedents from RFNBO rules.1234
Why — This would enable their members to access carbon removal certification for mineralisation projects storing atmospheric CO2.56
Impact — Joint CCU/CCS projects face additional hurdles from rules treating storage and utilisation separately.78
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CO2 Value Europe urges ambitious incentives for carbon capture utilisation

16 Sept 2025
Topic — EU regulation establishing a binding 90% net greenhouse gas reduction target by 2040.
Message — The organisation requests that EU authorities adopt legislation advantaging CCU over fossil feedstocks, including through ETS revision and market-pull mechanisms for CO2-based products. They emphasise that ambitious targets must come with ambitious incentives to enable CCU deployment at scale.12
Why — This would enable faster investments and deployment of CCU technologies, reducing regulatory barriers.34
Impact — Fossil feedstock producers lose their regulatory advantage over captured carbon alternatives.5
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Meeting with Sophie Wilmès (Member of the European Parliament)

16 Sept 2025 · CO2 capture

CCU industry urges inclusion in EU CO2 transport infrastructure plans

11 Sept 2025
Topic — EU legislation to develop competitive CO2 markets and transportation infrastructure for carbon capture.
Message — 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.123
Why — This would enable their members to access CO2 transport infrastructure and create revenue streams from CCU products.45
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CO2 Value Europe urges more funding for synthetic transport fuels

4 Sept 2025
Topic — EU initiative to create a strategic roadmap for investing in sustainable transport.
Message — The group seeks more funding and expanded emissions trading support for maritime fuels. They also request double-sided auctions and a review of restrictive regulatory rules.12
Why — This would lower investment risks and help European industry compete with Chinese producers.34
Impact — Fuel providers who fail to meet decarbonization targets will face significant financial penalties.5
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CCU industry urges CBAM extension to hydrogen-derived hydrocarbons

26 Aug 2025
Topic — The Commission is consulting on extending carbon border taxes to downstream industrial products.
Message — The group requests extending CBAM to hydrogen derivatives like methanol and e-fuels to prevent carbon leakage. They also demand a clear distinction between embedded carbon and process emissions for chemicals. Finally, imported fuels should be zero-rated to match domestic carbon accounting rules.12
Why — These measures would increase the competitiveness of sustainable CCU products against cheaper fossil-based imports.3
Impact — Importers of fossil-based downstream products would lose their price advantage over domestic green producers.4
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CO2 Value Europe urges 'circular content' quotas for plastic bottles

13 Aug 2025
Topic — Common rules for calculating and reporting recycled content in single-use plastic bottles.
Message — The association proposes broadening the mandate through a 'circular content' quota. This category should cover both recycled waste and carbon capture and utilisation.12
Why — Including carbon capture technologies allows their members to supply feedstock for plastic production.3
Impact — Waste recyclers would lose their exclusive position as the sole recognized carbon source.4
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Meeting with Radan Kanev (Member of the European Parliament)

14 Jul 2025 · Support for amendment on CCUS

CO2 Value Europe seeks fairer Innovation Fund access for CCU

8 Jul 2025
Topic — This consultation evaluates the effectiveness and operations of the EU Innovation Fund.
Message — They suggest considerably increasing the budget for medium-scale projects and earmarking specific budgets. They also request more flexibility for innovative value chains facing policy uncertainty.123
Why — This would help innovative carbon capture projects secure the funding they currently lack.45
Impact — Large projects with high emission savings would lose their current competitive advantage.6
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CO2 Value Europe urges clear alternative carbon feedstock definition and market support

8 Jul 2025
Topic — Regulation supporting decarbonisation of energy-intensive industries through accelerated investment and market creation.
Message — The organization requests clarification of permit processes for CCU projects under the Net Zero Industry Act, inclusion of CCU in CO2 transport infrastructure, and a clear definition of alternative carbon feedstock. They propose progressive mandatory targets for alternative carbon in products like chemicals and building materials, public procurement quotas, and an EU low-emission intensity label.1234
Why — This would enable CCU technologies to scale up and create viable business pathways for their 115 member companies.56
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CO2 Value Europe demands carbon capture inclusion in bioeconomy strategy

23 Jun 2025
Topic — The European Commission is consulting on a circular, regenerative, and competitive bioeconomy strategy.
Message — The group urges the Commission to include Carbon Capture and Utilisation (CCU) in the strategy. They argue that using captured biogenic carbon is necessary because the biomass supply will fall short of demand.12
Why — This would establish a policy framework helping the industry compete with cheaper fossil products.34
Impact — Fossil fuel suppliers lose market dominance as captured carbon replaces oil and natural gas.5
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe. It represents over 115 members throughout the whole CCU value chain from carbon capture to value-added products such as synthetic fuels, chemicals and building materials. CO2 Value Europe welcomed the adoption of the NZIA on 13 June 2024 and the inclusion of the CCU value chains within the list of net-zero technologies under Article 4. However, the multiplicity of categories CCU products are covered by complexifies CCU stakeholders application for permit when a project covers an entire value chain (from CO2 capture to a final good) or is aimed at more than one final use (ie. RFNBOs and chemicals). Therefore, CO2 Value Europe calls on the European Commission to ease the administrative burden by (i) adopting the name Carbon utilisation technologies for the sub-category currently named CO2 utilisation technologies, (ii) including the final products and primarily used components listed below, (iii) amending names of other elements proposed in the draft Annex for precision purposes where relevant to CCU products. The attached document makes specific propositions relevant to this Implementing Act on main specific components for both 'carbon capture technologies' and 'carbon utilisation technologies', and proposes necessary changes and additions to 5 net zero technology categories relevant for the consultation on the Delegated Act on the identification of sub-categories & primarily used components.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe. It represents over 115 members throughout the whole CCU value chain from carbon capture to value-added products such as synthetic fuels, chemicals and building materials. CO2 Value Europe welcomed the adoption of the NZIA on 13 June 2024 and the inclusion of the CCU value chains within the list of net-zero technologies under Article 4. However, the multiplicity of categories CCU products are covered by complexifies CCU stakeholders application for permit when a project covers an entire value chain (from CO2 capture to a final good) or is aimed at more than one final use (ie. RFNBOs and chemicals). Therefore, CO2 Value Europe calls on the European Commission to ease the administrative burden by (i) adopting the name Carbon utilisation technologies for the sub-category currently named CO2 utilisation technologies, (ii) including the final products and primarily used components listed below, (iii) amending names of other elements proposed in the draft Annex for precision purposes where relevant to CCU products. The attached document proposes necessary changes and additions to 5 net zero technology categories relevant for the consultation on this Delegated Act, and makes specific propositions for the associated Implementing Act on main specific components for both 'carbon capture technologies' and 'carbon utilisation technologies'.
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Meeting with Aura Salla (Member of the European Parliament)

17 Feb 2025 · The role of CCUS in clean energy transition

Meeting with Bart Groothuis (Member of the European Parliament)

22 Jan 2025 · CCU

Meeting with Aurel Ciobanu-Dordea (Director Environment)

17 Jan 2025 · Stimulating the use of captured CO2 in Europe

Meeting with Alexandre Paquot (Director Climate Action)

15 Jan 2025 · EU policies for Carbon Capture and Utilisation (CCU)

CO2 Value Europe urges faster support for synthetic aviation fuels

6 Jan 2025
Topic — The Commission is setting rules for subsidizing sustainable aviation fuels through the ETS.
Message — The association requests swift implementation of the support system to boost e-kerosene investments. They demand that recycled carbon fuels be included to align with existing aviation mandates.12
Why — This support would help developers secure long-term contracts and scale up e-kerosene production.3
Impact — Producers of recycled carbon fuels face exclusion from financial support compared to competitors.4
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CO2 Value Europe urges consistent rules for carbon capture fuels

25 Oct 2024
Topic — This consultation defines the methodology for calculating greenhouse gas savings for low-carbon fuels.
Message — The association requests clear rules to provide investment certainty for carbon capture and utilization technologies. They call for consistent language across EU regulations and oppose time limits on industrial emissions.123
Why — Removing these investment barriers would help the industry scale up carbon capture and utilization projects.45
Impact — Environmental groups lose if industrial carbon sources are used beyond the originally planned transition.6
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CO2 Value Europe demands legal certainty for carbon capture

29 Jul 2024
Topic — This initiative updates technical rules for monitoring and reporting greenhouse emissions.
Message — The group calls for clearer definitions to avoid conflicting interpretations of EU laws. They also seek long-term stability to protect industrial investments from future changes.12
Why — Consistent regulations would allow businesses to finalize plans and secure investments.3
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CO2 Value Europe urges broader scope for permanent carbon storage

16 Jul 2024
Topic — Establishing criteria for exempting permanently stored carbon emissions from EU ETS obligations.
Message — 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.123
Why — This provides financial exemptions from carbon costs, strengthening the business case for CCU technologies.4
Impact — Innovative manufacturers lose financial incentives if the storage definitions remain overly restrictive.5
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Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050. Many of the existing indicators in the programme are very pertinent to measure in actual terms the efforts made at EU level to build a climate-neutral, resource-efficient, non-toxic, resilient, fair, and competitive circular economy. In our perspective, additional indicators would be welcome, in particular to measure the replacement of fossil fuels and fossil resources by fossil-free alternatives. This is why we invite the European Commission to include indicators that would measure the degree of defossilisation of the EU economy, for example by measuring the substitutions of fossil products by fossil-free fuels in hard-to-abate sectors like aviation, shipping or energy-intensive industries such as cement and steel, by monitoring the uptake of alternative carbon feedstock in the production of chemicals, or by calculating the amount of CO2 that is being permanently stored via mineralised products. The EU has been making progress in the right direction with the latest adopted EU legislations from the Fit-for-55 package. But it needs to go further to incentivise for CCU technologies to be deployed at scale. Tools like the monitoring framework for the 8th Environment Action Programme should measure and monitor the impact the new legislations and EU initiatives have on climate indicators.
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Meeting with Hildegard Bentele (Member of the European Parliament) and DHL Group and

15 Nov 2023 · “Ramp-Up of Green Fuels for Aviation and Shipping - An Opportunity for Climate Protection, Industrial Policy and International Cooperation” - Panelist

CO2 Value Europe Demands Binding Targets for Carbon Capture Utilization

31 Aug 2023
Topic — Evaluating how carbon capture technologies can help decarbonize the European Union economy.
Message — The group calls for binding incorporation targets for captured carbon in chemicals. They demand that CCU pathways be explicitly included in all EU climate laws. They also advocate for rapid deployment of CO2 transport infrastructure.12
Why — Mandatory targets would create a guaranteed market and boost investment for CCU technologies.34
Impact — Traditional fossil fuel suppliers lose market share as captured CO2 replaces conventional feedstocks.56
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CO2 Value Europe Demands Strategic Status for Carbon Capture

23 Jun 2023
Topic — The Net Zero Industry Act aims to boost European manufacturing of clean technologies.
Message — CO2 Value Europe urges including Carbon Capture and Utilisation in the strategic technology category. They seek priority status for permitting and financing to accelerate industrial decarbonisation efforts.12
Why — Companies would benefit from faster regulatory approvals and better access to investment capital.3
Impact — Fossil fuel suppliers lose demand as CCU provides alternative feedstocks for chemicals and materials.4
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CO2 Value Europe urges 80% climate target using carbon capture

23 Jun 2023
Topic — A consultation on setting the EU's greenhouse gas reduction target for 2040.
Message — The group proposes an 80% reduction target by 2040 and requests mandatory quotas for non-fossil carbon. They also call for zero taxation rates on carbon capture fuels for shipping and aviation.1234
Why — These measures would create a guaranteed market and financial incentives for carbon capture technologies.56
Impact — Fossil fuel producers would lose market share as regulations mandate a switch to renewable carbon.78
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Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

19 May 2023 · Meeting with CO2 Value Europe on NZIA

Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 85 members along the CCU value chain, from CO2 producers, converters and users of CCU products to researchers and project developers. CCU refers to established and innovative industrial processes that aim at capturing carbon either from industrial point sources, including from biogenic sources, or directly from the air and transforming it into value-added products such as synthetic fuels, chemicals and building materials. As CO2 Value Europe, we see the development of new requirements for sustainability of a wide range of products as a crucial signal given to a variety of sectors to intensify their efforts to decrease the carbon footprint of daily products. CCU can play a key providing alternative carbon feedstock for the production of daily products through carbon circularity: rather than extracting additional fossil resources from the ground to use carbon in everyday products, Europe should support circular carbon solutions by reusing unavoidable emissions on one end to deliver essential products to another. We call for including as a horizontal measure in the ESPR a minimum percentage of non-fossil carbon to be included in EU products to be more circular and sustainable, including through recycled content, bio-based materials and renewable carbon through CCU. Our detailed position can be found attached.
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CO2 Value Europe Urges Inclusion of Carbon Capture in Taxonomy

3 May 2023
Topic — This consultation establishes a classification system for environmentally sustainable economic activities within the EU.
Message — The association requests explicit references to Carbon Capture and Utilisation within circular economy rules. They propose recognizing captured CO2 as a valid feedstock for manufacturing plastic packaging.12
Why — This change would facilitate investment in CCU technologies and help defossilise the chemical industry.3
Impact — Traditional fossil carbon suppliers lose market share as chemical production shifts to captured CO2.4
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CO2 Value Europe urges EU to defossilise packaging production

29 Mar 2023
Topic — This consultation reviews EU requirements for packaging design, reuse, and recycling.
Message — CO2 Value Europe requests new quotas for packaging to include alternative carbon feedstocks. They want legislation to include defossilisation targets and recognize carbon capture and utilization.12
Why — These changes would create market demand and legal recognition for CCU technologies.34
Impact — Fossil fuel suppliers lose market share as packaging shifts to non-fossil carbon.56
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CCU Industry Urges Recognition of CO2 Mineralisation as Permanent Carbon Removal

22 Mar 2023
Topic — EU proposal to certify carbon removal activities for climate policy integration.
Message — The organization requests clear recognition of CCU technologies that permanently store atmospheric or biogenic carbon, particularly CO2 mineralisation in construction products, as carbon removals in the legislation. They want definitions precise enough to avoid confusion but broad enough not to exclude future innovations.123
Why — This would allow their mineralisation technologies to qualify for carbon removal certificates and ETS exemptions.45
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Response to Sustainable Products Initiative

22 Jun 2022

CO2 Value Europe is the European Association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030 and 2050, and for the development of the CCU industry. We represent more than 70 stakeholders along the entire CCU value chain. We commend the publication of the Sustainable Products Initiative. We believe that it is crucial that EU authorities take ambitious measures to decrease the carbon footprint of everyday products, and enabling a transition towards a more circular economy. CCU products can contribute directly to making sustainable products a reality, as CCU helps decreasing the carbon footprints of products, and also reuses existing waste to valorise them. We consider that the Sustainable Products Initiative, and in particular its future sectoral targets and objectives for steel, cement, textiles and chemicals, should refer directly to products made out of CCU, in order to give a signal to producers that one pathway towards carbon neutrality can be CCU products. By making explicit references to using renewable carbon feedstock for the production of those four categories of products, EU authorities can amplify the dynamics for reducing their carbon footprint upstream and moving away from the use of fossil resources. In line with the Communication on Sustainable Carbon Cycles published in December 2021, where the Commission suggests that 20% of carbon in carbon-containing products should be of non-fossil origin by 2030, similar targets can be formulated for the target products of the Sustainable Products Initiative, for example : - For chemicals: by 2025, at least 10% of the carbon used in chemicals shall be from non-fossil sources (including captured carbon), and at least 20% by 2030. There are already examples of chemicals products from captured carbon in the market (e.g. methanol, polyols &polyurethanes, ethanol & derivatives, etc.) - For textiles: by 2025, at least 5% of the carbon used in the production of textiles shall be from non-fossil sources (included captured carbon), and at least 20% by 2030. There are already examples of commercial textile applications of recycled carbon Similar targets could be set for CO2-based cementitious materials and or CO2-based concrete, complemented by further construction products based on CCU mineralisation. Our detailed comments and recommendations can be found attached.
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Carbon Industry Urges EU to End Industrial Emission Reuse Ban

17 Jun 2022
Topic — Establishing methodology for calculating greenhouse gas savings from renewable and recycled fuels.
Message — The association calls for a grandfathering clause allowing projects started before 2040 to continue using industrial carbon emissions. They argue the proposed 2035 ban on reused emissions is incompatible with industrial investment cycles. Furthermore, they request clearer definitions for sustainable carbon sources to avoid disrupting the emerging sector.12
Why — This protection would secure long-term industrial investments and prevent project cancellations.34
Impact — European climate targets become unattainable if industrial carbon reuse is prematurely restricted.56
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CO2 Value Europe calls for CCU technologies recognition as carbon removals

2 May 2022
Topic — EU framework for certifying carbon removals from ecosystems and industrial solutions.
Message — The association requests recognition of carbon capture and utilisation technologies as carbon removals when CO2 is captured from air or biogenic sources and stored durably in materials. They want clear principles and legal certainty for investing in CCU technologies that lead to negative emissions.123
Why — This would enable their 70+ member organizations to claim carbon removal credits for CCU technologies.456
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Response to EU Solar Energy Communication

11 Apr 2022

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2 into a variety of value-added products such as synthetic fuels, chemicals and building materials. We welcome the development of a specific EU strategy on solar energy, which is bound to become a crucial source of renewable energy for the years ahead and achieve its full potential in helping meet the European Green Deal’s climate & energy targets. For CCU to reach its potential to mitigate climate change, it needs further renewable energy deployment, including via solar energy. Apart from the indirect utilisation of solar energy to produce electricity that can be used for the production of green hydrogen and CO2-based products (the so-called Power-to-X approach), the sunlight can also be directly used in innovative processes (e.g. artificial photosynthesis) for transforming CO2 and H20 into an array of solar fuels and chemicals. We call on the EU institutions to put forward in the solar strategy both indirect and direct utilisation of solar energy for solar fuels and chemicals, in order to continue activating all available levers to deliver on climate change objectives. Our position on the EU solar energy strategy can be found attached.
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

11 Apr 2022

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2 into a variety of value-added products such as synthetic fuels, chemicals and building materials. We welcome the European Commission’s initiative on renewable energy projects and supports strongly the revision of the Renewable Energy Directive, aiming to double the share of renewables in Europe to reach 40% by 2030. In order to reach this target, barriers and unnecessary constraints around renewable energy projects should be removed and minimised as much and as fast as possible, which is why we consider any initiative from the EU aiming to contribute to efficient development and deployment of renewable energy projects as a step in the right direction. We advocate for ambitious and realistic climate policies enabling an energy transition towards renewable and low carbon sources, and towards zero carbon energy systems, in particular by: - Boosting the access to affordable renewable hydrogen in Europe - Supporting hydrogen-based solutions and zero/low carbon technologies - Reinforcing Fit-for-55 proposal with higher and earlier targets for renewable energy and energy efficiency - And accelerating the deployment of renewable energy projects. We support the option for EU authorities to adopt guidance helping implement the Renewable Energy Directive and providing them clear instruction on how to transition to renewables. Our detailed recommendations on how EU authorities can help foster renewable energy projects can be found attached.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2 into a variety of value-added products such as synthetic fuels, chemicals and building materials. We welcome the ReFuelEU Aviation initiative aims to boost the supply and demand for sustainable aviation fuels in the EU, in order to reduce aviation’s environmental footprint and enable it to help achieve the EU’s climate targets. As CO2 Value Europe, we make a number of asks to ensure consistency between the ReFuelEU Aviation and other Fit-for-55 proposals, and we advocate for more ambitious targets for the use of synthetic fuels in aviation in the coming years. Our detailed feedback and suggestions on the proposal can be found attached.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2 into a variety of value-added products such as synthetic fuels, chemicals and building materials. The proposal for revising the Renewable Energy Directive makes a number of modifications to existing rules, targets, including targets for the production of renewable fuels of non-biological origin (RFNBOs), provided that they enable for a 70% reduction of GHG emissions compared to the use of regular fuels. We welcome those proposed changes which can help mainstreaming and systematising the use of RFNBOs in Europe. As CO2 Value Europe, we make a number of recommendations for improvements that can be made to the proposal, in particular on adding interim RFNBOs targets, on the additionality principle, on GHG emissions reductions methodologies, and in general on delegated acts that will follow the adoption of the proposal. Our detailed feedback on the proposal can be found attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2 into a variety of value-added products such as synthetic fuels, chemicals and building materials. We welcome the proposed revision of the Energy Taxation Directive aiming to align taxation of energy products and electricity, for example renewable fuels of non-biological origin with EU energy and climate policies, to contribute to the EU 2030 energy targets and climate neutrality by 2050. We support the exemptions provided for producing renewable fuels of non biological origin, and encourage the Commission to develop guidance for EU countries to detail how they can apply exemptions or reductions in the level of taxation for CCU products. Our detailed feedback on the proposal can be found attached.
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CO2 Value Europe urges recognition of carbon capture in ETS

8 Nov 2021
Topic — The European Commission is revising the carbon market to achieve climate neutrality by 2050.
Message — The group requests clear definitions for product use and rules to prevent double counting emissions. They also recommend frontloading the Innovation Fund to support new technologies throughout the value chain.123
Why — This would create legal certainty and financial incentives for companies to invest in carbon capture.45
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Response to FuelEU Maritime

8 Nov 2021

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. As CO2 Value Europe, we welcome the European Commission’s FuelEU Maritime initiative to boost the uptake of sustainable fuels in shipping and ports in order to reduce emissions from the sector. While its ultimate goal is to bring the sector in line with the EU’s ambition of climate-neutrality by 2050, the proposal as it stands does not provide quotas for uses of renewable fuels, but only sets target for CO2 *reduction from 2025 to 2050. As CO2 Value Europe, we make a number of suggestions to set a direction when it comes to the use in volumes of renewable fuels for the maritime sector, as well as ensuring clarity and consistency in EU legislations on accounting for greenhouse gases emissions reductions. Our detailed feedback on the proposal can be found attached.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Verband Deutscher Maschinen- und Anlagenbau e.V.

22 Oct 2021 · CCUS sector development in Europe

Carbon capture industry urges inclusion in EU carbon cycle plans

6 Oct 2021
Topic — EU proposal to certify carbon removals and promote carbon farming practices.
Message — CO2 Value Europe requests that Carbon Capture and Utilisation be appropriately considered in the Commission's sustainable carbon cycles vision. They argue CCU can reduce emissions, create circular systems, enable industrial symbiosis, lead to carbon removals, and provide alternative feedstock to fossil carbon.12
Why — This would create competitive industrial markets for their carbon capture technologies and products.34
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

CO2 Value Europe (CVE) is the European Association representing the Carbon Capture and Utilisation (CCU) community in Europe. CVE welcomes the efforts to establish voluntary schemes that will verify the sustainability compliance of biofuels, RFNBO and RCF. While the delegated act on the methodology for calculating GHG emission savings for RFNBO and RCF pursuant Article 28 (5) of the REDII is under preparation, it is important that the present implementing act and the rules and definitions on product groups, mixtures, infrastructure, implementation of mass balance, co-processing, C14 use, are not hindering the consideration of RFNBO (e.g. the transport and distribution of green hydrogen in the same pipeline as other hydrogen types; or the co-production of biomethanol and e-methanol in the same facility) and that they are aligned with the work within the Union Database.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 65 members along the CCU value chain, primarily industrial actors from different sectors. CVE welcomes the development of a taxonomy that identifies sustainable economic activities and contributes to the promotion of financing in these sustainable economic activities. However, CVE is strongly concerned with the fact that no technical screening criteria for CCU have been developed in the Delegated Act for Mitigation and Adaptation and that CCU is also neglected in different other parts of the Delegated Act (see below). This is especially worrisome in light of the contribution that CCU can make to the environmental objectives of mitigating climate change and promoting the circular economy, as shown by recent LCA studies, indicatively:  https://doi.org/10.1039/C9SE00479C for CCU fuels  https://doi.org/10.1039/C9EE00914K and https://doi.org/10.1073/pnas.1821029116 for CCU chemicals  https://doi.org/10.1039/D0SE00190B and https://doi.org/10.3390/met10030342 for CCU mineralisation products. Many more LCA studies are becoming increasingly available for CCU technologies, providing the necessary scientific evidence for their recognition as climate mitigation solutions (https://doi.org/10.1016/j.apenergy.2020.114599; https://doi.org/10.1016/j.scitotenv.2019.01.395; https://doi.org/10.1021/acs.chemrev.7b00435; https://doi.org/10.1016/j.ijggc.2019.102882; https://doi.org/10.1016/j.jclepro.2019.118359). CO2 Value Europe believes that CCU technologies with the potential of contributing significantly to the climate goals of the European Union should be already recognised in the Taxonomy as a sustainable activity, even if they are not all yet commercially mature. The commercial character of an activity should not be restrictive as to whether this activity shall be considered as sustainable under the Taxonomy. Investment in such high potential technologies must happen now (see e.g. Innovation Fund, IPCEI) so that their contribution is fully visible in the following 3-4 years; in order for this to happen, legislative packages like the EU Taxonomy should give already now the signal to private and public investors that such technical solutions are considered sustainable, thereby fostering their large scale deployment. Article 10 of Regulation (EU) 2020/852 explicitly cites CCU as a solution that brings a substantial contribution to climate change mitigation. The inclusion of CCU in the taxonomy is needed as the positive impacts of reusing CO2 are too important to be postponed to a later review of the taxonomy. The attached document proposes technical screening criteria for the utilisation of captured CO2 and then addresses the problems in other technical screening criteria proposed in the Delegated Regulation that neglect the potential of CCU technologies. At the same time the attached documents addresses the problem of the absence of carbon capture as a sustainable economic activity. Indeed, although we read in various passages about “carbon capture” (e.g. 4.8 under technical screening criteria point 6 (c); 4.7, 4.19, 4.23 under “technical screening criteria” point 2) or “captured CO2” (e.g. 5.11 in “description of the activity”; 5.12 in “description of the activity”) or “where CO2 emitted ...is captured” (e.g. 3.6, 3.8, 3.9, 4.7, 4.19, 4.23 under “technical screening criteria”), carbon capture is not defined separately as sustainable economic activity. While one can assume that capture of anthropogenic emissions (point sources) could be indirectly incorporated in the respective manufacturing activities (Section 3 - Manufacturing), the Delegated Regulation ignores the huge potential of Direct Air Capture (DAC) that is internationally acknowledged2 as an essential contribution towards climate neutrality. DAC is already commercial in small scale and is expected to reach large scale commercialization in the coming years.
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CO2 Value Europe seeks ETS credits for carbon reuse

26 Nov 2020
Topic — The European Commission is reviewing the Emissions Trading System to reach climate neutrality.
Message — The group requests financial recognition for carbon emissions avoided through capture and reuse. They call for carbon stored in minerals or synthetic fuels to be discounted from obligations.12
Why — Industrial firms would reduce compliance costs by subtracting captured carbon from their allowance obligations.34
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Response to Sustainable Products Initiative

16 Nov 2020

CO2 Value Europe very much supports the EU’s goals to increase the circularity of the EU’s economy, while preserving its natural environment and supporting the contribution of the EU’s industry to achieve a climate-neutral continent. As a consequence, we welcome the Sustainable Products Initiative. Carbon Capture & Utilisation (CCU) covers a large set of innovative processes that can recycle CO2 into a variety of valuable products, such as organic compounds, chemical building blocks, synthetic fuels, and building materials. In essence, CCU is circular economy applied to carbon: CO2 is not be considered as a waste but as a resource. In CCU processes, CO2 is captured from industrial process emissions (or directly from the air) and recycled it into valuable products. A major part of our economy is based on indispensable carbon-containing products. In the future, such products will have to be manufactured using a sustainable source of carbon. There are only 3 sustainable (i.e. non-fossil) sources of carbon: the use of biomass (which contains carbon taken from the air by photosynthesis), the recycling of carbon-containing products (e.g. plastics) at the end of their useful lifetime (wherever this is possible), and the utilisation of CO2 taken from industrial emissions or captured directly from the air. To conclude: indeed, a fully circular carbon economy can emerge where CO2 is no longer considered as a waste emission but as a carbon source in replacement of fossil feedstock. CO2 mineralisation is a family of CCU processes that illustrate a “double” circular economy (circular economy for carbon + circular economy for solid waste materials). In such processes, mineral waste streams are put in contact with captured CO2 (in a reaction called “carbonation”) to create useful construction materials, and the carbon remains permanently sequestered into the product. Such a reaction is spontaneously exothermic, meaning that it does not require external energy input! Besides ensuring circularity for carbon, CO2 mineralisation into products also manages solid waste materials in a circular manner – as illustrated in the diagram on page 2 of the folder on https://www.co2value.eu/wp-content/uploads/2018/10/18-10-09_co2value_flyer_print.pdf. Indeed, mineral waste coming from various industry sectors are transformed into valuable construction materials, so they no longer have to be disposed of in landfills (waste management benefit). Similarly, construction and demolition waste can also be looped back into the production of fresh construction materials and diverted from landfills. When it comes to sustainability of building products, CVE believes that it is important to include an assessment at the level of the whole building or construction works (EN 15804, Level(s) framework, CEN/TC 350) and not only at the level of the product. Moreover, carbon is a key component in most of the chemical products used in daily life, such as transportation and heating fuels, plastics, packaging, furniture, clothing, pharmaceuticals, and many others. Today, most of the carbon demand in the chemical sector is satisfied by fossil resources. For the chemical industry to reduce both its direct and indirect CO2 emissions and to decrease its dependence on fossil resources, it will require a constant supply of renewable carbon sources. By switching from fossil to CO2-based feedstock, the European chemical industry can reinvent itself, exploit new market opportunities and become sustainable while strengthening its leadership position.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

E-fuels generated from CO2 and renewable energy are essential to defossilize transport sector and a wide range of European industries and thereby achieving the climate goals. As liquid and gaseous energy carriers, these CO2 based fuels provide an immediate solution reducing or even reaching net zero CO2 emissions in a variety of fields, incl. road transport/shipping/aviation. Every unit of e-fuels displaces one unit of fossil fuel. In transportation, CCU-derived fuels can immediately contribute to reduce net CO2 emissions because they can be used in existing combustion engines and do not require any change to the existing fuel distribution infrastructure, unlike other solutions. The needed CO2 capture and conversion technologies have predominantly been developed in Europe and have matured over the last years. RED II should offer a comprehensive regulatory framework that could bring these essential technologies to market and unfold their vast CO2 reduction potential. CVE believes following points will be crucial in defining a regulatory framework: - An increase in the goal of 32% share of renewable energies in the EU’s final energy consumption is necessary and aligned with EU goals for 55% emission reductions by 2030 and climate neutrality by 2050 - To accelerate the reduction of CO2 emissions in all forms of transport across Europe, it is crucial to establish a level playing field between all low or zero emissions energy carriers including e-fuels, (advanced) biofuels and electricity - A level playing field in the transport sector can be supported when appropriate sub-targets and multipliers apply consistently also to H2 and subsequent transformations of H2 to CCU fuels across all transport sectors - E-fuels which emit CO2 during use can have the same impact on Well-to-Wheel (WTW) emissions as ‘zero emission vehicles’ (ZEV) powered by electricity or hydrogen. Therefore, the same legislative support should be given to e-fuels which can power hard-to-electrify transport, as is given to direct use of electricity and hydrogen - Current Tank-to-Wheel (TTW) emission standards which apply to automakers, favor ZEV and are biased against vehicles which operate on high blends or pure alternative energy carriers which generate TTW emissions. REDII should support emission standards reflecting CO2 abatement from utilization of alternative energy carriers - Specific targets of renewable energy consumption should be extended to further sectors, apart from transport. Indeed, renewable hydrogen and CCU products like e-methanol or e-methane can be very important for the chemical, process and other industries - Every unit of e-fuels displaces one unit of fossil fuel: REDII allows all industrial emission sources of CO2 which otherwise would be released to ambient air as feedstock for e-fuels. Any confusion about the ‘color of CO2’ should be avoided in the Directive and delegated acts - RED II must define in a clear and robust way how e-fuel plants can take renewable electricity from the grid, while considering industrial realities. Guarantees of Origin are the best instrument to document the renewable origin of electricity and the directive should support the use of such instruments. At the same time, the REDII revision should synchronize with current process of developing Delegated Acts for renewable electricity use under REDII. Until this is done, operators should be granted a flexibility period during which they can develop projects to deploy e-fuels and achieve emission reductions without unrealistic constraints on renewable energy supply - Existing fuel specifications for gasoline limit the use of alternative energy carriers due to limitations on blending % and oxygen content. As tests have shown that new blends can be safely adopted, the Commission should ease the adoption of alternative fuels that are compatible with existing car fleets as well as the introduction of high blends or pure alternative fuels for new generations of vehicles
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

23 Jul 2020

CO2 Value Europe represents the CO2 utilisation community in Europe aiming to develop CO2 re-use as a feedstock for a new industrial sector making a significant contribution to Europe’s low-carbon economy. We call for a financial recognition of CO2 emissions that are avoided through putting CO2 to use in different applications - generally known as CCU (Carbon Capture and Utilisation). In so doing, business incentives will be created to close the CO2 loop by re-using CO2 in applications such as mineralization, e-fuels and chemicals. Mineralization is the reaction of CO2 with Ca(calcium)- and Mg(magnesium)-containing materials to form carbonates, stable products that permanently sequester CO2 and can be applied in different sectors (e.g. building materials, functional minerals, etc.). The recognition of these mineralisation products as stable materials permanently storing CO2 should be extended in the ETS MRR. The CO2 emitted from an ETS installation and stored through mineralisation onsite or offsite should be discounted from allowance obligations of original ETS installation. E-fuels are liquid and gaseous fuels from the reaction of CO2 with renewable hydrogen. E-fuels are drop-in fuels, using existing infrastructure, promoting integration of more renewables into the energy system, and providing immediate solutions for industry, transport and domestic sectors. CCU-based fuels (e-fuels) should not be treated as fossil fuels when used as energy source in ETS installations and should be recognised as neutral in CO2, in the same way as biomass and biogas. CVE would be very happy to closely cooperate with the European Commission in the future to ensure a supportive regulatory framework for CCU products, so that the European Union can fully utilize these technologies to achieve climate neutrality by 2050.
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Response to A EU hydrogen strategy

8 Jun 2020

CO2 Value Europe welcomes the kick-start of a much-needed renewable hydrogen strategy that will effectively manage the central role that hydrogen can play towards a climate-neutral EU economy. This strategy is a major opportunity to address barriers related to markets, infrastructures and technical challenges that prevent significant scaling up of renewable hydrogen production. As the roadmap mentions, it is necessary to look at the whole value chain in order to create a renewable hydrogen ecosystem. Therefore, it is important to include in this strategy solutions that use renewable hydrogen as an intermediate, like CCU fuels using renewable hydrogen and captured CO2. Such technologies should be deployed in parallel to stand-alone renewable hydrogen as they have a large potential to use existing infrastructure and defossilise energy intensive industries, the domestic sector as well as hard to electrify transport sectors (e.g. sustainable aviation fuels) in the short to medium term.
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Response to Strategy for smart sector integration

8 Jun 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 65 members from different sectors along the CCU value chain. CVE welcomes the European Commission’s initiative to promote integrated energy systems with the aim to curb CO2 emissions. CVE believes that a strong contribution to these objectives can be made by: • Incentivising the circularity of CO2 • Promoting the direct as well as indirect electrification of hard to defossillise sectors • Promoting the production and uptake of sustainable alternative fuels and renewable gases
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Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members from different sectors along the CCU value chain. CVE welcomes the elaboration of minimum climate benchmarks referring to Regulation 2019/2089. As far as Article 11 (1) (f) is concerned, we would like to emphasize that renewable electricity-based hydrogen and renewable electricity-based hydrocarbons (e-fuels, e-chemicals) should not be part of this requirement
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Response to FuelEU Maritime

24 Apr 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 65 members from different sectors along the CCU value chain, including the maritime e-fuels sector. CVE welcomes the European Commission’s FuelEU Maritime initiative to curb CO2 emissions in the European maritime sector by promoting the production and use of sustainable alternative fuels. CVE believes that it is of utmost importance that the defossilisation of the maritime sector, especially the uptake of e-fuels from CO2 (i.e. CCU fuels), starts now. E-fuels are needed to help defossilise the maritime sector in the short term and at the lowest cost and to meet the REDII targets. Because CCU fuels are a drop-in fuel, the risk of investing in a new type of drivetrain is avoided. While energy efficiency improvements are essential, e-fuels are a sustainably scalable option for the deep defossilisation of all shipping modes. Similarly, biofuels can deliver a valuable contribution, but will not be able alone to cover the fuel demand due to limitations in feedstock availability; and direct electrification may not be an option for long distance commercial shipping. Therefore, it is important that this initiative ensures the commercial development of e-fuels. In this light, CVE considers that the baseline scenario should not be an option anymore. Shipping is a growing source of emissions and needs to be tackled now in order for the EU to be truly committed to the Green Deal. Delaying action will be detrimental, because the sooner technological development and scale-up takes place, the sooner the production costs of e-fuels can decrease and be competitive to the fossil alternative. This will ensure the most cost-effective transition of the maritime sector and maintain the EU’s leadership in e-fuels. General support measures such as “Goal-based performance requirements on the carbon-intensity of energy used in marine operations and at berth” would facilitate the short-term defossilisation of the maritime sector. However, long-term solutions will require the combination of more fuel-specific measures. Therefore, support measures that aim at boosting the market uptake of e-fuels are crucial. These could take the form of facilitating access to funding or of the differentiation of port fees as suggested. Greater access to R&I funding will help boost the maturity of the technologies involved while greater access to commercial funds will help increase the competitiveness of e-fuels compared to their fossil fuel counterparts. Here, the EU Emission Trading System, the Energy Taxation Directive and the Sustainable Finance Taxonomy play an important role. However, to achieve the optimal outcome for the long-term and sustainable GHG emissions reduction of shipping, prescriptive requirements on blending/definition of the share of sustainable alternative fuels (and specifically for e-fuels) and/or shoreside electricity to be used by ships in operation and at berth are needed. This mechanism will ensure that timely investments in all essential technologies are made. Simultaneously, the prescriptive requirements remove the risk for investors in e-fuel production plants by ensuring a minimum demand. In conclusion, CVE supports the Fuel-EU maritime initiative and strongly supports the adoption of specific support mechanisms for e-fuels and prescriptive requirements that create the initial demand. We are happy to contribute to the efforts of the Commission in elaborating these mechanisms further.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members from different sectors along the CCU value chain. CVE welcomes the European Commission ReFuelEU initiative to curb CO2 emissions in aviation by promoting the production and use of sustainable aviation fuels (SAFs). We appreciate the opportunity to provide feedback on the roadmap. Several CVE members are closely involved in upscaling the e-fuels market for aviation, such as Sunfire, Climeworks, TNO, KIT, Total, Carbon Recycling International and Nordic Blue Crude. A rapid market uptake of e-fuels is necessary to supply SAFs at large scale: SAFs are currently exclusively made from organic or waste feedstock. However, bio- and waste-SAFs will not be able to satisfy the large demand alone, due to feedstock availability. As a consequence, e-fuels are needed to guarantee/achieve a sufficient supply of SAFs in the medium and long-run to replace fossil aviation fuels. E-Fuels, whose resources are renewable electricity, water and CO2 are the only scalable alternative for aviation without resource constraints and sustainability issues. The utilisation of CO2 also contributes to a circular CO2 economy if CO2 captured from air is used as a feedstock. Moreover, e-fuels from renewable electricity are chemically superior to fossil kerosene as they contain fewer soot particles and aromatics and thus lover the indirect climate impact of aviation. In any case they allow blending with conventional kerosene as drop-in fuel or replace it altogether. Apart from reducing GHG emissions (up to 84% CO2 emissions reduction with Direct Air Capture (ICCT 2019)), e-fuels would also benefit the air quality through a reduction in particles emissions. The technology to produce e-fuels is ready: Power-to-Liquid-Demonstration projects have shown the readiness of the technology (e.g. Kopernikus-Projekt in Germany, George Olah renewable methanol plant in Iceland). Our members are currently engineering the first industrial plants for e-fuels in Norway. These include a project by Sunfire and Climeworks, with an output of 8,000 t/a to be commissioned in 2023 and, depending on regulatory support, a further scale up to 80,000 t/a by 2025. Another project is developed by Carbon Recycling International in collaboration with Statkraft, with an output of 100,000 t/a by 2023. They do this without a regulatory framework being in place at their own risk. Further scale-up however, would need regulatory support due to capital requirements. Several other projects within Europe are also ongoing such as Westküste100, Powerfuel and KEROSyN100. E-Fuel production up-scaling requires effective regulatory support: SAF market incentives, a robust regulatory framework for CCU/PtL-technologies and strong financing mechanisms will bring the necessary confidence to trigger large investments in industrial e-fuel production facilities. In this context, it is important to install regulatory instruments that target e-fuels and biofuels separately, e.g. by installing individual sub-quotas or central auctioning mechanisms. This will allow e-fuels to scale up in parallel and contribute to covering the SAF fuel demand in aviation in the years to come. If done right, e-fuels could significantly raise the SAF supply of the European market within a short time frame while achieving continuous price reductions. We are happy to assist with developing effective market incentives programs, regulatory framework improvements and financing mechanisms.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members along the CCU value chain, primarily industrial actors from different sectors. CVE welcomes the Commission’s initiative to revise the Industrial Emissions Directive (IED) and the opportunity to provide feedback on the roadmap. As the IED has proven effective in the struggle to reduce pollution from industry, CVE believes that the same instrument could also be used to both reduce the emission of greenhouse gases and promote circularity within industry. Therefore, CVE welcomes the exploration of how to include the elements of decarbonization and circularity in the IED. In alignment with the Master Plan for a competitive transformation of the EU energy-intensive industries, CCU technologies have a high potential for substantial emission reductions in energy intensive industrial processes (HLEG on EII, 2019) (source: https://ec.europa.eu/docsroom/documents/38403, p. 25-26). As such, CCU technologies can significantly contribute to the European Green Deal goals for decarbonization of heavy industry towards a carbon neutral economy by 2050. At the same time, CCU technologies contribute to the Circular Economy action plan by promoting CO2 circularity within the industry itself (e.g. e-fuel production from CO2 emitted and internal use) or through industrial symbiosis approaches, when the emissions of one industry become the feedstock of another for the production of fuels, chemicals and materials, thereby avoiding the use of fossil resources. We are therefore very interested to contribute to the discussion of how the element of decarbonization and circularity may be included in the revised EID while ensuring that these developments will be consistent with other policy instruments (e.g. ETS).
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

CO2 Value Europe (CVE) is the European association for Carbon Capture and Utilisation (CCU), representing over 65 members along the CCU value chain, primarily industrial actors from different sectors. CVE welcomes development of the sustainable finance package and the opportunity to deliver feedback on the climate change mitigation and adaptation criteria of the taxonomy. CVE is convinced that CCU contributes both to the objectives of climate change mitigation and the promotion of the circular economy. We believe that CCU can be an economic activity making a substantial contribution based on its own performance e.g. by permanently storing CCU in materials. In addition, CCU can also be an enabling activity that by provision of its products enables the decarbonisation of other activities e.g. when it concerns the production of carbon neutral or zero carbon products such as CCU fuels and chemicals, avoiding fossil fuel consumption in other sectors. While CVE supports the development of taxonomy, CVE is strongly concerned about the fact that CCU is not yet included and is in some cases even disincentivised. Meanwhile, the final compromise text of the Regulation on the establishment of a framework to facilitate sustainable investment (2018/0178) states in article 10 that increasing the use of environmentally safe carbon capture and utilisation that delivers a net reduction in GHG emissions can provide a significant contribution to climate change mitigation. In this light, CCU should be included as a priority in the upcoming delegated regulation that covers the taxonomy objective of climate change mitigation. This view that the upcoming platform on sustainable finance should cover CCU is supported by the Technical Expert Group (TEG) which wrote in its final report that it recommends the future platform on sustainable finance to consider “How and under what conditions to include CCU technologies in different manufacturing sectors, as well as the manufacturing of such equipment.”(page 160 of the TEG Final Report Technical Annex). CVE would be more than happy to contribute to this effort by offering its expertise for the development of the technical screening on CCU. As mentioned above, unfortunately the TEG Final Report’s Technical Annex at some points unjustly jeopardise the development of CCU. On point 5.11 (page 316) of the Technical Annex where the metrics and thresholds for the “transport of CO2” are specified it is stated “Assets or activities that enable carbon capture and use (CCU) will deem all the connected elements of an existing transport network ineligible” and that “Assets which increase the flexibility and management of an existing network, without expanding the network to include carbon capture and use activities is eligible.”. These metrics are to our knowledge unjustifiably discriminatory towards CCU. CCU activities deliver real climate benefits either by avoiding fossil resource consumption or by permanently sequestering CO2 in materials. In addition, connecting CCU to a CO2 transport network helps create a business case for the transport infrastructure by spreading its costs among more users. In a similar way, the technical screening criteria of point 5.10 (page 313) on the “Capture of Anthropogenic Emissions” need to be amended to allow for the inclusion of CCU. The metrics and thresholds currently read as follows “Capture of anthropogenic emissions is currently eligible provided that […] It shows that the captured CO2 will be offloaded to a Taxonomy eligible CO2 transportation operation and permanent sequestration facility”. These metrics and thresholds should be amended to allow for the CO2 to be used in a facility that uses CO2 as well as those which permanently sequester it. In conclusion, CVE urges to include CCU in the upcoming delegated act and remove the currently proposed metrics that unjustly jeopardise the development of CCU. We are happy to contribute into establishing the technical screening criteria.
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Response to A new Circular Economy Action Plan

20 Jan 2020

CO2 Value Europe very much supports the EU’s goals to increase the circularity of the EU’s economy, while preserving its natural environment and supporting the contribution of the EU’s industry to achieve a climate-neutral continent. Carbon Capture & Utilisation (CCU) covers a large set of innovative processes that can recycle CO2 into a variety of valuable products, such as organic compounds, chemical building blocks, synthetic fuels, and building materials. In essence, CCU is circular economy applied to carbon: CO2 is not be considered as a waste but as a resource . In CCU processes, CO2 is captured from industrial process emissions (or directly from the air) and recycled it into valuable products. A major part of our economy is based on indispensable carbon-containing products. In the future, such products will have to be manufactured using a sustainable -ource of carbon. There are only 3 sustainable (i.e. non-fossil) sources of carbon: the use of biomass (which contains carbon taken from the air by photosynthesis), the recycling of carbon-containing products (e.g. plastics) at the end of their useful lifetime (wherever this is possible), and the utilisation of CO2 taken from industrial emissions or captured directly from the air. To conclude: indeed, a fully circular carbon economy can emerge where CO2 is no longer considered as a waste emission but as a carbon source in replacement of fossil feedstock. CO2 mineralisation is a family of CCU processes that illustrate a “double” circular economy (circular economy for carbon + circular economy for solid waste materials). In such processes, mineral waste streams are put in contact with captured CO2 (in a reaction called “carbonation”) to create useful construction materials, and the carbon remains permanently sequestered into the product. Such a reaction is spontaneously exothermic, meaning that it does not require external energy input! Besides ensuring circularity for carbon, CO2 mineralisation into products also manages solid waste materials in a circular manner – as illustrated in the diagram on page 2 of the folder on https://www.co2value.eu/wp-content/uploads/2018/10/18-10-09_co2value_flyer_print.pdf. Indeed, mineral waste coming from various industry sectors are transformed into valuable construction materials, so they no longer have to be disposed of in landfills (waste management benefit). Similarly, construction and demolition waste can also be looped back into the production of fresh construction materials and diverted from landfills. This also reduces the need for extracting fresh mineral resources from quarries (natural resources benefit). In conclusion: CCU in general, and CO2 mineralisation in particular, can greatly contribute to two important challenges for Europe: the mitigation of climate change and the development of a circular economy. Policy makers at EU and Member State levels should work actively with industry to lift the existing regulatory and economic barriers that inhibit the rapid deployment of such technology solutions at industrial scale across Europe.
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