MGH Energy
La société MGH Energy (Mobility Green Horizon) est une société innovante qui se consacre principalement à la décarbonation des transports maritimes et aériens.
ID: 681868149500-49
Lobbying Activity
Response to Legislative initiative on CO2 transportation infrastructure and markets
5 Sept 2025
As an e-fuel (RFNBOs) project developer, MGH Energy welcomes this call for evidence which implements commitments made in the EU Carbon Management Strategy (ICM) of 6 February 2024: - Propose a future CO2 transport regulatory package; - Propose an EU-wide CO2 transport infrastructure planning mechanism. CCS and CCU: a concomitant rather than sequential development The Call for evidence considers that reutilisation of CO2 [will] only develop post-2040 and that in the ramp-up phases, CO2 will be nearly exclusively captured for permanent storage. To our mind, CCU and CCS will grow in parallel and placing the CCU in second place could slow down the implementation of certain projects. As an example, our project in Occitanie region (southwest of France) which will require 300kta of captured CO2 is to be commissioned in 2031. Facilitate CO2 transport by ship in and out the EU In the ICM strategy, the Commission indicates that she is going to promote through the International Maritime Organization the development of any necessary guidelines on safe transportation of CO2 by sea. In the call for evidence, the Commission recognises the need for the future initiative to remove the remaining barriers and legal uncertainty for cross-border CO2 transportation, such as those originating from international treaties. We fully support this approach. As an example, our e-SAF facility located in Morocco due to entry into service as of 2031 will require 300 kta of CO2 captured in Europe. The CO2 consumption will then gradually increase to reach 850 kta in 2034 (phase 1 of the project) followed by an additional requirement of 1 Mta in 2037 (phase 2 of the project), that is approximately 56 Mt over 30 years of overall operation. This requires the establishment of infrastructures enabling shared land transport (pipeline) of CO2 from the emitters' sites to the European ports and its liquefaction, intermediate stock of imported e-SAF and subsequent distribution to European domestic depots. To enable the advent of such a cross-border CO2 economy, the existing regulatory framework must be improved. We believe that this must be dealt with in two ways: - The EU should take an active part in the revision work of the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IMO IGC Code) aimed at including provisions that are more suited to CO2 than the current provisions of the code (sections 17.21 & 17.22). The fact that the new edition of the IGC code is not expected to be published before 2028 creates uncertainty and may slow down projects. Interim guidelines should be developed to cover the lack of regulation until that revision. - The EU should explore the possibility of signing framework agreements with countries such as Morocco likely to reuse CO2 originating from Europe and convert it into products such as e-fuels/RFNBOs, with a view to re-exporting them to Europe and contribute to the EU's decarbonisation objectives (RFNBO mandates). No market without traceability We welcome the ideas of the creation of a CO2 value chain and of an EU market for CO2. To make these ideas happen, we encourage the creation of a CO2 guarantee of origin system similar to guarantees of origin for renewable electricity or biogas. Such GO for CO2 would be based on a register and certificates that would have to indicate, in particular: - the category of CO2: captured from an EU ETS installation, biogenic, atmospheric, etc.; - the quality of the CO2, according to a standard; - the origin of the CO2; - the quantity of CO2.
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