CO₂ Transportation Infrastructure Legislative Package

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Consultation response · September 2025

Introduction

Achieving climate neutrality by 2050 and progressing toward net negative emissions thereafter will require both Carbon Capture and Storage (CCS) and permanent Carbon Dioxide Removal (CDR) at industrial scale. CCS prevents new emissions from entering the atmosphere, while CDR actively removes CO₂ already present, addressing residual and historical emissions and tackling climate overshoot.

In practice, CCS and CDR often overlap: some CDR pathways, such as Direct Air Carbon Capture and Storage (DACCS), Bioenergy with Carbon Capture and Storage (BECCS), and Direct Ocean Capture and Storage, share substantial infrastructure needs with CCS, particularly CO₂ transport networks and geological storage sites. In some cases, CCS and CDR happen at the same capture facility (e.g., waste-to-energy plants), where both fossil and biogenic CO₂ are captured together.

By 2040, the EU will need between 465–501 MtCO₂e in removals, with a significant share coming from permanently stored CDR. Designing transport and storage systems to serve both CCS and CDR from the outset will maximise efficiency, reduce long-term costs, and avoid infrastructure lockout. Without this integrated approach, the permanent removals sector could be left without access to critical networks, slowing deployment and undermining the EU’s ability to meet its climate targets.

The economic opportunity is equally compelling: by 2050, the European carbon removal industry is projected to reach €220 billion annually and create 670,000 jobs, while driving green innovation, strengthening industrial competitiveness, and positioning Europe as a global leader in climate solutions.

The forthcoming CO₂ Transportation Infrastructure Legislative Package must explicitly include CDR to ensure transport and storage systems are future-proof, cross-sectoral, and capable of delivering both CCS and CDR at scale.

Recommendations

1. Explicitly Include Permanent CDR in the Legislative Scope and Infrastructure Planning

The legislative framework should make clear that CO₂ transport and storage infrastructure is intended for atmospheric, biogenic, and fossil-origin CO₂ from the outset, and that any new streamlined or accelerated permitting framework applies to CDR. This is critical to ensuring that infrastructure planning, capacity allocation, and market access rules do not exclude or disadvantage removals. For the permanent CDR sector, market certainty is particularly important. It is an emerging industry without strong demand signals, making it more vulnerable to being crowded out by established industrial CCS projects if rules do not explicitly recognise its needs. Early clarity will give investors confidence that infrastructure access will be available, supporting deployment and cost reduction.

The Scientific Advisory Board’s recent report warns that the EU’s current CO₂ infrastructure policy is insufficient to deliver the scale-up of permanent removals needed for net zero and net negative emissions, and calls for accelerated investment in storage capacity. Crucially, it also highlights that the EU still lacks rules prioritising infrastructure access for removals and for carbon capture from activities with no or limited mitigation alternatives, as well as measures to address disparities in storage access. While prioritisation of removals is important, large industrial fossil emission point sources will remain the primary drivers of investment in transport and storage infrastructure, providing the scale needed to enable both CCS and CDR deployment. Reserving infrastructure exclusively for biogenic or atmospheric CO₂ could slow investment if capture volumes are not yet available, leaving capacity underutilised at significant socioeconomic cost. Instead, a focus on regulated third-party access would ensure that all parties (fossil, biogenic, or atmospheric CO₂) can connect to available infrastructure at fair prices. At the same time, early coordination between Member States and industrial sites, taking into account expected volumes of CO₂ from CCS-based CDR methods, is key to avoiding costly retrofits and ensuring that pipelines and storage facilities can efficiently accommodate future volumes.

The Net Zero Industry Act (NZIA) set a target of 50 Mt annual CO₂ injection capacity by 2030, marking important progress in scaling CO₂ storage infrastructure. However, the final text notably failed to include permanent CDR within the list of net-zero technologies, despite clear scientific consensus on CDR’s indispensable role in achieving net-zero emissions. This exclusion was a missed opportunity to cement the EU as a global leader in permanent removals. The upcoming CO₂ Transportation Infrastructure legislative initiative can build on NZIA’s foundation by ensuring that infrastructure planning explicitly accounts for atmospheric and biogenic CO₂ captured through CDR, and by considering specific infrastructure targets for removals to clearly differentiate between emission reductions via CCS/CCU and actual removals.

2. Launch Two IPCEIs: One for CO₂ Transport & Storage, and one for Permanent CDR Scale-Up

To deliver both CCS and CDR at the scale required for climate neutrality and net negative emissions, the EU should launch two Important Projects of Common European Interest (IPCEIs):

  • An IPCEI for Permanent CDR Scale-Up: This would support coordinated RD&I investment, generate strong demand signals, and foster collaboration between Member States to develop integrated value chains for European-made CDR technology and projects.

  • An IPCEI for CO₂ Transport & Storage: A competitive, integrated CO₂ transport network is vital for both CCS and CDR deployment. This IPCEI would enable coordinated EU-wide planning, pooled investments, and shared development of cross-border infrastructure. For CDR in particular, where capture sites are often geographically dispersed, flexible and interoperable networks are essential to connect to suitable storage sites. Harmonising cross-border CO₂ transport rules within this IPCEI would reduce costs, simplify permitting, and remove administrative burdens that disproportionately affect CDR SMEs, while ensuring fair access for all operators.

Both IPCEIs should be explicitly supported through existing and new EU funding programmes, including Horizon Europe, the Recovery and Resilience Facility, the Innovation Fund, and the European Competitiveness Fund. The latter’s mandate is particularly relevant as it aims to strengthen strategic European industries, making it an ideal source to prioritise CO₂ transport and storage infrastructure and accelerate the transition to a low-carbon economy.

Together, these IPCEIs and aligned funding would provide the backbone for a competitive, integrated European carbon management system that supports both emission reductions and permanent removals at scale.

3. Develop an EU Strategy for Permanent CDR

Despite permanent CDR’s key role to deliver on the EU’s climate targets, to date European policy on carbon removals has been fragmented and ad hoc. For example, despite EU technological leadership, permanent CDR was not included on the list of net-zero technologies in the Net Zero Industry Act. Similarly, proposed high-level actions to scale-up CDR in the EU Industrial Carbon Management Strategy have not materialised. And while negative emissions look set to be included in the EU ETS, an ongoing consultation on the closely-related Carbon Border Adjustment Mechanism (CBAM) makes no reference to carbon removals.

Scaling up a new climate technology will require a comprehensive set of both demand and supply-side policy measures, which will have to be implemented across different DGs and at both a European and national level. Coordination and a clear plan for permanent CDR will be critical to inform the post-2030 climate framework.

An EU permanent CDR Strategy, as a ‘soft’ policy measure, could set out:

  • Indicative deployment targets to define Europe’s ambition level and attract investment;

  • A clear indication of the required RD&I support that will be needed across EU and national levels, and the role that EU funds like the Industrial Decarbonisation Bank will play;

  • Clarity on how the EU and national governments will close CDR’s ‘green premium’, which will remain as the industry scales up, even once negative emissions are integrated into the ETS, and the role that EU funds like the Industrial Decarbonisation Bank will play;

  • Clarity on the EU’s vision for negative emissions at an international level;

  • How the most engaged Member States could coordinate their planning to cooperate on permanent CDR and to develop complementary national strategies. This could include a new forum for national CDR policy experts.