The International Association of Independent Tanker Owners
INTERTANKO
INTERTANKO (the International Association of Independent Tanker Owners) is a trade association that has served as the voice for independent tanker owners since 1970, representing the interests of its Members at national, regional and international levels.
ID: 144683049447-90
Lobbying Activity
Response to Legislative initiative on CO2 transportation infrastructure and markets
3 Sept 2025
INTERTANKO welcomes the renewed momentum for CCS/CCU in current EU policy discussions. This technology is critical to decarbonise hard-to-abate heavy industries, and it will be absolutely instrumental for the EU to successfully reach net-zero emissions by mid-century. This renewed momentum calls for a well-functioning EU internal market for the entire CO2 value chain (removal, capture, transport and storage / utilisation). In particular, CO2 transportation is a critical enabler for the further roll-out of CCS/CCU. The legislative initiative on CO2 transportation that was announced in the Industrial Carbon Management (ICM) Strategy and is expected for Q3 2026 is an essential and urgent step, for the EU to reach the ambitious CO2 injection capacity targets set by the Net-Zero Industry Act (NZIA). INTERTANKO wants to respond to the call for evidence on the forthcoming legislative initiative on CO2 transportation infrastructure and markets, to highlight the central role that shipping is to play on this market. The Commissions internal roadmap outlines the main outstanding barriers to cross-border CO2 transportation and issues that the legislative initiative will aim to resolve - very much reflecting what last years ICM Strategy tackles. As indicated in the internal roadmap, the initiative will take due account of the fact that in the ramp-up phases, CO2 will be nearly exclusively captured for permanent storage and a level-playing field between pipelines and alternative means for CO2 transportation needs to exist. While welcoming this important point, INTERTANKO urges the European Commission to explicitly recognise the central role that shipping is to play for CO2 transportation between capture and storage / use locations in full consistency with the definition of CO2 transport infrastructure provided in Regulation (EU) 2024/1735 on establishing a framework of measures for strengthening Europes net-zero technology manufacturing ecosystem (the Net-Zero Industry Act). Besides, the central role of shipping is duly recognised by the Joint Research Centre (JRC) in its study on Shaping the future CO2 transport network for Europe, in which it underlines that to enable the deployment of CCS in Europe at a larger scale, we need networks comprising primarily pipelines and ships for transporting captured CO2 from its sources to suitable storage sites. It appears that the EUs legislative framework and ongoing discussions on the issue focus mainly on hard infrastructure (i.e. CO2 networks / transport via pipeline), while shipping has so far been overlooked despite its clear and much needed potential. INTERTANKO wants to emphasise the critical importance of allowing CO2 transport by ship, both between EU Member States and EEA countries, but also between Member States and third countries (outside the EU/EEA), under certain strict conditions - i.e. provided that these countries apply the same climate and safety standards as in the EU/EEA. Indeed, there is vast CO2 storage potential in countries outside the EU/EEA, and allowing the safe transport and storage of CO2 in such locations would help the EU decarbonise its industry faster and stay on track to carbon neutrality by 2050. INTERTANKO wants to thank the European Commission for the opportunity to submit feedback on its internal roadmap document as part of this call for evidence, and will also respond to the formal public consultation that will be carried out later this year. INTERTANKO is very keen to engage in a continuous dialogue with the European Commission and EU policymakers on this important matter in the months and years to come.
Read full response9 Jul 2024
INTERTANKO wants to respond to the invitation for feedback on the European Commissions draft revision of the Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions (Monitoring and Reporting Regulation, MRR), in particular to make comments and suggestions regarding the transport of CO2 for geological storage. INTERTANKO fully supports Recital (20) in the draft MRR revision, recognising that CO2 for geological storage is expected to be transported by a variety of modes and that it is therefore necessary to revise the monitoring and reporting provisions related to the CO2 transport activity to ensure that they are applicable to a CO2 transport infrastructure based on any transport modes. In line with the definition of CO2 transport infrastructure provided in Art.3(29) of the Net-Zero Industry Act (NZIA), the revised MRR should explicitly mention all available means of CO2 transportation, beyond CO2 networks/pipelines - i.e. ships, but also rail and road transport. INTERTANKO particularly wants to emphasise the critical importance of allowing CO2 transport by ship both between EU Member States and EEA countries, but also between Member States and third countries (outside the EU/EEA), under certain strict conditions - i.e. provided that these third countries apply the same climate and safety standards as in the EU/EEA. Indeed, there is vast CO2 storage potential in countries outside the EU/EEA, and allowing the safe transport and storage of CO2 in such locations would help the EU decarbonise its industry faster and stay on track to carbon neutrality by 2050. This should be explicitly recognised in the revised MRR, as well as in the forthcoming legislative package on CO2 transport that has been announced in the EU Industrial Carbon Management Strategy published in February 2024. More detailed recommendations are provided in our attached position statement.
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