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Negative Emissions Platform

NEP

Negative Emissions Platform advocates for the political recognition and scaling of permanent carbon removal technologies.

Lobbying Activity

Meeting with Jens Gieseke (Member of the European Parliament)

10 Dec 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

5 Nov 2025 · Carbon removals

Meeting with Felix Leinemann (Head of Unit Maritime Affairs and Fisheries)

5 Nov 2025 · Exchange of views on marine carbon dioxide removals (mCDR) including ocean alkalinity enhancement, direct ocean capture and ocean fertilization.

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

2 Oct 2025 · Carbon removals

Meeting with Hildegard Bentele (Member of the European Parliament)

24 Sept 2025 · CO2 Removal

Negative Emissions Platform urges longer certification for carbon removals

22 Sept 2025
Topic — The Commission is establishing certification methodologies for permanent carbon removal activities like DACCS.
Message — NEP recommends extending the activity period to 15 years to align with financing. They also call for allowing storage providers to trigger credit issuance.12
Why — These changes would improve project bankability and provide greater regulatory certainty for developers.3
Impact — Traditional biomass users could face supply distortions if strict economic viability tests are removed.45
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Meeting with Peter Liese (Member of the European Parliament) and Liquid Gas Europe and FGS Global (Europe) GmbH

18 Sept 2025 · Austausch

Negative Emissions Platform wants removals in CO2 infrastructure laws

11 Sept 2025
Topic — A legislative initiative creating competitive markets and transportation infrastructure for carbon dioxide.
Message — NEP urges the inclusion of permanent carbon removal in upcoming infrastructure legislation. They call for two European-level investment projects and a strategy to scale up removal technologies.12
Why — Integrating removals early would reduce long-term costs and provide the certainty investors need.34
Impact — Smaller removal projects risk being crowded out of infrastructure by larger, established industrial emitters.56
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Negative Emissions Platform urges EU leadership on carbon removals

11 Sept 2025
Topic — This initiative establishes the EU strategy for global climate and energy engagement.
Message — The group calls for global targets for permanent carbon removals and their inclusion in carbon pricing schemes. They advocate for the international adoption of EU carbon removal certification standards.123
Why — International policy support would accelerate the commercial growth of carbon removal technologies.4
Impact — Developers of short-lived removal methods may lose market share to permanent solutions.5
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Meeting with Jens Geier (Member of the European Parliament)

10 Sept 2025 · Exchange on ETS and CBAM

Negative Emissions Platform demands separate targets for carbon removal

4 Sept 2025
Topic — Proposed amendments to the European Climate Law including new 2040 climate targets.
Message — The platform supports a 90% reduction target but requests separate goals for emissions cuts and permanent carbon removals. They also advocate for a technology-neutral portfolio approach and financial support beyond carbon market integration.123
Why — Distinct removal targets would provide the regulatory certainty and demand signals required to attract investment.4
Impact — Polluting industries lose the ability to use carbon removals as a substitute for direct decarbonization.5
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Negative Emissions Platform urges CBAM to include carbon removals

26 Aug 2025
Topic — The initiative extends the carbon border adjustment mechanism to downstream products to reduce leakage.
Message — The group argues the CBAM Regulation must recognize permanent carbon removals to meet climate goals. They request that the mechanism aligns with the EU Emissions Trading System and certification standards.12
Why — Integrating removals into trade policy creates international markets and attracts more private investment.3
Impact — Traditional carbon capture providers lose their exclusive status as the sole recognized mitigation technology.4
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Negative Emissions Platform seeks dedicated funding for carbon removal

7 Jul 2025
Topic — Evaluation of the Innovation Fund's role in supporting European climate action technologies.
Message — The Commission should earmark a dedicated share of the Innovation Fund for carbon removal. Evaluation criteria must recognize negative emissions potential and prioritize permanent carbon storage.123
Why — This support helps novel technologies bridge the gap between demonstration and commercial scale-up.4
Impact — Conventional carbon capture projects could lose funding priority as resources are diverted to removals.5
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Negative Emissions Platform urges permanent carbon removal in EU ETS

7 Jul 2025
Topic — A policy review evaluating the expansion and stability of the European Emissions Trading System.
Message — The organization advocates for integrating permanent carbon removal into the EU ETS via a phased approach. They demand separate legal targets for removals to prevent them from undermining urgent emission reductions. Additionally, they propose using public contracts to support the sector during early deployment phases.123
Why — Integration would provide the negative emissions industry with guaranteed demand and predictable revenue streams.4
Impact — Providers of temporary storage lose access to the carbon market due to permanence requirements.5
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Negative Emissions Platform urges EU to accelerate permanent carbon removal

7 Jul 2025
Topic — EU regulation supporting industrial decarbonisation and competitiveness in energy-intensive sectors.
Message — The organization requests streamlined permitting for carbon removal projects, integration of carbon removal into carbon intensity labels, and establishment of voluntary interim milestones for companies. They want 5% of the Industrial Decarbonisation Bank earmarked for permanent carbon removal.1234
Why — This would accelerate growth of the carbon removal sector projected to reach €220 billion annually by 2050.56
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Environmental Coalition on Standards and

7 Jul 2025 · Letter with 16 signatories for European Competitiveness Fund to deliver climate and energy security for EU citizens and SMEs

Negative Emissions Platform urges flexibility in carbon removal rules

27 Jun 2025
Topic — The Commission is establishing harmonised rules for third-party verification of carbon removal activities.
Message — They recommend revising rules to provide greater flexibility for certification scheme governance structures. The platform calls for clearer criteria regarding valid reasons for switching between schemes. They suggest reconsidering mandatory accreditation requirements to avoid potential bottlenecks and maintain scalability.123
Why — Reducing administrative requirements would lower compliance costs and speed up project market entry.4
Impact — Small verification firms lose market access if strict accreditation requirements create high entry barriers.5
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Negative Emissions Platform urges priority for permanent carbon removal

23 Jun 2025
Topic — The EU is revising its strategy for a circular and climate-neutral bioeconomy.
Message — They urge the Commission to anchor permanent carbon removal as a strategic priority. The group requests the inclusion of biochar and carbon capture technologies in agricultural subsidies.12
Why — This would scale up their market and attract more private finance for projects.34
Impact — Traditional biomass sectors could lose feedstock as market actors shift resources elsewhere.5
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Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

27 May 2025 · discussions on Green Claims Directive

Meeting with Andreas Glück (Member of the European Parliament)

14 May 2025 · Climate and Environment Policy

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

13 May 2025 · Clean Industrial Deal to deliver a Joint Decarbonisation and Competitiveness Roadmap

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

22 Apr 2025 · CDR, negative emissions

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

31 Mar 2025 · Incorporating Carbon Direct Removal (CDR) into the Decarbonisation Accelerator Act

Meeting with Radan Kanev (Member of the European Parliament) and Carbon Gap ASBL

18 Mar 2025 · Empowering Europe's Net Zero Future: Carbon Dioxide Removal as a catalyst for a competitive green transition

Meeting with Peter Liese (Member of the European Parliament)

18 Mar 2025 · Policy Workshop: Carbon removals as an enabler for a competitive green transition

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

The Negative Emissions Platform (NEP) underscores the critical need to support carbon dioxide removal (CDR) start-ups and scale-ups to meet the EUs climate neutrality goals and enhance industrial competitiveness. While European start-ups and scale-ups are leading in developing permanent CDR technologies, they face significant challenges, such as: - Access to Finance: Current EU funding mechanisms, such as Horizon Europe and the Innovation Fund, are fragmented, insufficient, and administratively complex. The high capital costs and long development timelines for CDR technologies create a severe valley of death for mid-readiness solutions, limiting scale-up potential. - Access to Markets: The absence of integration into compliance markets and carbon pricing mechanisms restricts market demand and reduces investment incentives. - Access to Talent and Infrastructure: The sector faces skills shortages, particularly in engineering and environmental sciences, while critical infrastructure, such as CO transport and storage, is underdeveloped. - Regulatory Barriers: Slow and inconsistent permitting processes, along with limited cross-border coordination, hinder project development. - Lack of Market Incentives: The absence of lead markets, public procurement mechanisms, and price support measures (e.g., carbon contracts for difference) restricts investment and growth opportunities. NEP recommends a comprehensive approach to overcome these barriers: - Boost Financial Support: Increase dedicated R&D funding through Horizon Europe and earmark a portion of the Innovation Fund for diverse CDR technologies. Establish an EU-wide purchasing programme for permanent removals to create demand signals and leverage the European Competitiveness Fund to drive public-private investments. - Develop Compliance Markets: Integrate carbon removal into EU compliance frameworks, including potential integration with the Emission Trading System and the introduction of sector-specific mandates or carbon takeback obligations for fossil fuel producers. - Streamline Permitting Processes: Simplify and accelerate permitting procedures to remove bottlenecks and promote faster project development. - Invest in Workforce Development: Launch education and training programmes to build skills aligned with CDR sector needs and facilitate workforce transitions from traditional industries. The EU Start-up and Scale-up Strategy presents a pivotal opportunity to strengthen the CDR sector, drive innovation, and support economic growth. NEP urges the Commission to adopt these measures and stands ready to support efforts to responsibly scale the sector. Please find attached our full response.
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Negative Emissions Platform urges EU to integrate marine carbon removal

13 Feb 2025
Topic — The European Oceans Pact establishes a coherent vision for EU ocean-related policy areas.
Message — NEP requests that marine carbon removal be integrated into the EU's ocean strategy. They demand increased research funding and streamlined permitting to scale these climate technologies.12
Why — This policy shift would secure investment and global market leadership for European technology developers.345
Impact — Environmental groups may fear that fast-tracked permitting processes reduce oversight of ecological risks.67
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Meeting with Michał Kobosko (Member of the European Parliament)

14 Jan 2025 · Permanent carbon dioxide removal technologies

Meeting with Radan Kanev (Member of the European Parliament)

6 Nov 2024 · CDR technologies

Meeting with Kurt Vandenberghe (Director-General Climate Action)

5 Nov 2024 · policy recommendations on revising the EU Climate Law; the need for a dedicated CDR Strategy; and the establishment of a compliance market for CDR

Meeting with Peter Liese (Member of the European Parliament)

18 Sept 2024 · Austausch

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

18 Sept 2024 · Carbon dioxide removal technologies

Meeting with Andrea Wechsler (Member of the European Parliament) and Wärtsilä Corporation and TransnetBW GmbH

17 Sept 2024 · EU Energy and Industry Policy

Negative Emissions Platform seeks harmonised carbon removal rules

15 Jul 2024
Topic — Establishing conditions for carbon storage in products under the EU emissions trading system.
Message — 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.123
Why — Classification as carbon removals would provide new financing and a stronger market demand signal.4
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Meeting with Esther De Lange (Cabinet of Commissioner Wopke Hoekstra)

23 Apr 2024 · NEP’s position paper on the topic which outlines our key priorities + 2040 Climate Target legislative package

Meeting with Mohammed Chahim (Member of the European Parliament)

28 Feb 2024 · 2040 Climate Targets

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra), Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

25 Jan 2024 · Carbon dioxide removal technologies

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

6 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Negative Emissions Platform Urges EU Leadership on Carbon Removals

30 Aug 2023
Topic — This consultation evaluates policies to deploy carbon capture and storage infrastructure by 2050.
Message — The EU should establish clear definitions for carbon removal and provide financial subsidies. They also recommend harmonising cross-border transport rules to benefit smaller technology companies.123
Why — This framework would provide the legal clarity and financing needed for sector growth.45
Impact — Fossil fuel companies lose the ability to classify their capture activities as carbon removals.6
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Industry Group Urges Binding EU Carbon Removal Targets for 2040

22 Jun 2023
Topic — Setting the EU's 2040 climate target toward climate neutrality by 2050.
Message — The organization requests separate binding targets for carbon removals, disaggregated by permanence. They propose a 10-15% target for hard-to-abate emissions, with EU-wide targets and Member State responsibilities.1234
Why — This would create market demand for their carbon removal technologies and services.56
Impact — Polluting industries lose flexibility to continue emissions without addressing residual pollution.78
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

8 Jun 2023 · Konferenz zu Kohlenstoffentnahmen (staff level)

Negative Emissions Platform urges broader permanent carbon removal labels

23 Mar 2023
Topic — The Commission is proposing a regulatory framework for certifying high-quality carbon removals.
Message — NEP asks that permanence labels include biochar and other novel removal methods. They also request alignment with existing EU laws to reduce administrative burdens.12
Why — Broadening labels allows NEP's diverse technology members to qualify for premium carbon certifications.3
Impact — Traditional geological storage providers would lose their exclusive status as the only permanent solution.4
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Response to Implementing regulation on the Member States’ reporting of information foreseen in the Governance of the Energy Union

9 Aug 2022

Negative Emissions Platform welcomes the Commission’s initiative to adopt an Implementing Regulation setting out the details for the information included in the integrated national energy and climate progress reports. Adjustments are necessary to reflect the latest scientific findings to limit climate change. We call for a better integration of CO2 removal by negative emission technologies into the EU analysis of national policy measures in order to promote their development and deployment ahead of 2030 and beyond. - We recommend the projected level of technological carbon removal becomes a customary and standalone element of national reporting to support operationalization of the net-zero target within EU legislation and keep track of the sum of national efforts towards the technological carbon removal objective, with a view of its upward revision post-2030. - We ask that Member States include technological removals: Pyrogenic Carbon Capture and Storage (PyCCS), Bioenergy with Carbon Capture and Storage (BECCS) and Direct Air Capture with Storage (DACS) in the updated integrated national energy and climate plans by 30 June 2024, and report on land-based and technological removals separately in the Annex I Table 1 and Table 4. - Within this reporting Members States should be invited to provide, wherever available, their estimates and objectives on technological removals with geological storage and permanent sinks with non-geological storage, as well as projected levels of CCU with fossil and non-fossil carbon capture. - Technological removal shall be reported by the Member State where the capture takes place upon confirmation of final storage, unless bilaterally agreed differently between the nations involved. It should be made clear in the reporting table which form of storage has been applied for the technological removal. - Additionally, Member States shall be invited to include the relevant R&D expenditure in the reporting lines of the Annex VII (Research, Innovation and competitiveness), and update on any regional cooperation initiatives with other Member States in the space of technological removal in Annex XXI (Implementation of regional cooperation). Read our full feedback in the attached doc.
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Negative Emissions Platform backs targets for sustainable carbon fuels

17 Jun 2022
Topic — The Commission is establishing rules for calculating greenhouse gas savings from synthetic fuels.
Message — NEP supports transitioning to sustainable CO2 by 2036 and carbon pricing for fuel imports. They also call for clear targets and support mechanisms for new synthetic fuel facilities.12
Why — This policy would lower costs for capture technologies and create a secure investment environment.34
Impact — Industrial emitters will lose a revenue stream as their carbon becomes ineligible after 2036.56
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Negative Emissions Platform seeks tailored rules for carbon removal certification

2 May 2022
Topic — The European Commission is proposing a regulatory framework for certifying sustainable carbon removals across Europe.
Message — NEP requests the timely implementation of a framework using method-specific assessments for different technologies. They advocate for a competitive verification system involving private companies and existing standards. The group emphasizes that industrial removals need dedicated rules to reflect their permanence.123
Why — Tailored standards and private verification would lower administrative costs and reduce regulatory uncertainty for developers.45
Impact — Providers of non-permanent storage solutions face implementation delays due to more complex monitoring and reporting requirements.6
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Response to Restoring sustainable carbon cycles

7 Oct 2021

We welcome the opportunity to respond to the roadmap on Restoring Sustainable Carbon Cycles and the inclusion of planning for development of technological removals therein. General comments: The Roadmap focuses in the first place on nature-based removals from land-use sector and indicates the timeframe of 2035 to achieve carbon neutrality in this sector. We see value in developing the framework for and incentivising carbon farming practices, however we see an equal if not greater urgency in developing an enabling policy framework for technological solutions that generate permanent carbon removals. We note that the recent proposal for LULUCF Regulation, which sets out the objective of a climate-neutral land sector by 2035 indicates also that beyond 2036 the combined AFOLU sector will need to generate further carbon removals ‘to balance remaining emissions in other sectors’. We believe that due to inherent reversibility and difficulty of monitoring of carbon farming practices this is a high-risk approach and there should be a greater focus in the upcoming Communication on technological removals as an at least equally important way of neutralising residual emissions. Most importantly, technological removals present the possibility to remove carbon and store it for climate-relevant timeframes (>100years). An enabling framework for technological removals should be put in place by 2025 at the latest to enable deployment at scale of DACS, BioCCS, Waste-to energy CCS projects, large scale production and application of biochar and an increase in enhanced weathering demonstration pilots, as well as generation of increasing volumes of air-captured CO2 to gradually replace fossil carbon in a range of products and materials. In order to present a viable business model and bridge the investment gap faced by technological carbon removal solutions a conditional role for permanent carbon removal (DACS and BioCCS, Waste-to energy CCS) under the EU Emissions Trading System could be introduced by 2025, additional to the reduction of greenhouse gas (GHG) emissions foreseen by the cap on GHG emissions. With regard to technological carbon removals the Communication should focus on a) on clarifying the interlinkages of the upcoming CRC-M with incentives and requirements under current climate policies, b) reviewing and submitting to a further public consultation a range of recommended policy instruments applicable at Member States level, and on c) strengthening of current EU instruments relevant to removals. Full response in the attachment.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Third Generation Environmentalism Ltd and

22 Mar 2021 · Industrial strategy; green transition

Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

We would like to share our feedback on the revised version of the Trans-European Networks for Energy (TEN-E) Regulation with reference to the exclusion of CO2 storage and CO2 transport modalities other than pipelines from its scope. Despite ongoing efforts by a number of stakeholder groups including NGOs and industry, the current proposal from the European Commission does not include these two key elements. As the representatives of an emerging carbon dioxide removal industry we join these calls and urge you to introduce relevant amendments during the upcoming negotiations of the dossier. The TEN-E proposal in its current form is not fit to support the achievement of the climate neutrality objective. See our letter to policymakers in the attachment.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

We are asking the Commission to urgently address the issue of exclusion of Direct Air Capture technology from the draft Delegated Regulation establishing technical screening criteria of the EU sustainable finance taxonomy. We urge the Commission reinstate the section covering Direct Air Capture (DAC) under chapter 5. Water, Sewerage, Waste and Remediation in line with the recommendation of the final report by the EU TEG on Sustainable Finance from March 2020. -> Carbon removals are a key part of mitigation efforts: We fully support the analysis by TEG on the importance of contribution of Direct Air Capture, among other carbon removal technologies, towards the net-zero GHG emissions target by 2050. These findings are in line with the IPCC’s 1.5 °C Report, the Commission’s own 1.5 TECH scenario, the recent IEA’s Energy Technology Perspectives, and many other energy transition modelling exercises. -> Carbon removal technologies and solutions contribute to decarbonisation of other sectors: Alongside the role of Direct Air Capture with storage in permanent removal of CO2 emissions, we need to underscore, too, a substantial contribution of air-captured CO2 to de-fossilization of the hardest-to-abate sectors, in line with the Commission’s initiative on Sustainable Aviation Fuels, and other sectoral initiatives on liquid and gaseous fuels or building materials where the origin of CO2 as a feedstock (atmospheric vs. industrial) heavily influences the overall GHG-intensity of the production processes. Similarly, the bio-energy with CCS (BECCS) can help decarbonise power generation and the emission intensive industries, while the applications of biochar and olivine hold the potential to contribute to carbon removals in agriculture. -> The EU’s leadership in clean technology and climate action is at stake: The technologies that remove CO2 from the atmosphere will provide a crucial waste management service in public interest of us all and the future generations. If we are to avoid the worst effects of climate change this reality needs to be made clear by the policy makers towards the wider finance community through adoption of a holistic and Paris-aligned taxonomy. The UK and the US are rapidly advancing their regulatory and financing frameworks to enable market uptake of sufficiently mature technological carbon removals like DACCS and BECCS, and to support R&D&I of less mature promising removal solutions - the EU too needs to put in place the right tools to empower its innovators and investors in this global cleantech ‘race to the top’. -> The EU needs a workable portfolio of carbon removal technologies and solutions by 2030: The EU’s contribution to global carbon removal efforts in the IPCC scenarios is calculated at 7.5 GtCO2 by 2050, and 50 GtCO2 by 2100 cumulatively. Comparison of the projected European contribution with the carbon removal potential of individual projects shows the scale of the challenge - Drax is a large bioenergy power plant (2.5 GW) in the UK, which aims to become the world’s first large-scale BECCS plant by late 2020s by capturing 16 MtCO2/year when fully retrofitted with CCS by 2034. In order for Europe to achieve its share of carbon removal target by 2050, more than 23 Drax plants need to come online by 2030. This rough calculation underscores the urgency to deploy a full portfolio of negative emissions technologies in the next decade - including DACCS, BECCS and other engineered, hybrid and nature-based approaches. This will not materialise without an enabling public and private finance framework in the early 2020s. Therefore, we urge the Commission to include the a separate section in the Delegated Regulation Annex 1 chapter 5, based on the previous TEG’s analysis, In the absence of this, the flagship European carbon removal/management projects, such as Orca or Norsk e-fuel initiative, would not be classified as sustainable by the finance community - > see the attachment.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

We welcome the Commission’s initiative to streamline the objectives of RED II with recent initiatives to increase the 2030 target, promote hydrogen and sector integration. This review should encompass: 1) An increase of the RED II targets and sub-targets. The nominal sub-target of 14% for renewable energies in the transport sector should be increased to at least 23% in 2030. The overall target should be supplemented by a minimum quota of 5% for e-fuels (including hydrogen) in 2030. To further incentivise the reduction of carbon intensity of e-fuels an obligation should be placed on producers to source an increasing share of CO2 from the atmosphere. Starting from a minimal level (ex. 5%) in the 2020s the share would be gradually increased in line with atmospheric CO2 removal cost reductions, to reach 100% in 2050 in line with the EU long-term climate-neutrality objective. The obligation could be delivered either by production or blending of atmospheric CO2-derived fuels or through purchase of credits from other suppliers. The promotion of air-to-fuels production would bring about the economies of scale of atmospheric CO2 removal processes. This in turn would improve the overall economics of atmospheric CO2 removals as the ultimate technological option to deliver net-negative emissions. If the e-fuels industry is scaled up based on industrial CCU only, without a clear plan to phase in atmospheric CO2-derived fuels, the overall climate-neutrality target by 2050 will not be delivered or will require huge additional carbon removal capacity in other sectors. 2) Amendments to RED II reflecting the measures proposed in the Hydrogen Strategy and Sector Integration Strategy The methodology for GHG emissions saving and sustainability criteria must clearly differentiate between the CO2 from industrial sources and the atmospheric CO2. At present, the methodology falsely indicates that the effect on climate is the same whether the CO2 is captured from the air or from the flue gases with CCU method.The application of atmospheric CO2 removal delivers genuinely carbon circular fuels keeping the concentration of atmospheric CO2 at a steady level, whereas the CCU approach merely moves the release of CO2 in time and space, while in the same time risking a lock-in of fossil sources of CO2 for years to come and potentially delaying application of alternative decarbonisation technologies in concerned industries. An indicative classification of ‘green gases’ established by the Florence School of Regulation provides a good example of valuation of CO2 by source - with the synthetic methane from renewable hydrogen and atmospheric CO2 scoring higher on the Green Value index than synthetic methane derived from industrial CO2. Additionally, if hydrogen’s feedstock is biomass, which contains the naturally-captured atmospheric CO2, the first methanation process is considered carbon negative. Similar approach to valuation of CO2 is necessary with respect to e-fuels 3) Transparency for end-users A straightforward classification and terminology would help consumers better understand differences between various types of fuels and enable them to make a right choice depending on individual decarbonisation needs and priorities. Labels and certification schemes will be particularly important for industrial end-users subject to the EU ETS while the reform of the EU ETS Monitoring and and Reporting Regulation is still pending. Moreover, a direct link between GOs and other labels and certificates would be an effective tool to prevent false or double claims on the origin of energy. In that respect we recommend that CO2 captured from industrial fossil point sources covered by the EU ETS and sold to e-fuels suppliers should still require the industrial actor to pay for allowances under the EU ETS. In that way the ‘CO2 laundering’ - whereby the captured CO2 is passed on to non-ETS actors - would be prevented. Check the attachment for our full response
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