European Oceans Pact Public Consultation

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Consultation response · February 2025

The Negative Emissions Platform (NEP) is a Brussels-based partnership of European and international organisations focused on carbon removals. Our members are primarily technology companies, but also include project developers, investors, carbon marketplaces, and buyers of carbon removals. We provide a forum in which diverse like-minded organisations actively collaborate to improve political and public recognition of carbon removals.

NEP welcomes the European Commission’s initiative to develop a comprehensive ocean policy in the European Oceans Pact and appreciates the opportunity to provide input. NEP calls on the European Commission to integrate marine carbon dioxide removal (CDR) into the EU’s ocean policy framework as an important contributor to the EU’s climate goals and to support climate mitigation efforts.

The Role of Marine CDR

Achieving net-zero emissions is impossible without large-scale CDR. Scientific consensus, including the IPCC’s 6th Assessment Report, confirms that in addition to deep emissions reductions, global CDR capacity must scale up to 10 gigatonnes per year by 2050 to stay within the 1.5°C climate target. In the near term, even with steep emissions reductions, an additional 2.9 gigatonnes of CDR by 2030 will be required compared to 2020 levels. Scaling the carbon removal industry to this level within decades demands substantial investment and political support now for a portfolio of different permanent CDR methods.

Despite increasing recognition of the need for CDR in EU climate policy, ocean-based approaches have received insufficient attention and investment compared to land-based solutions. Yet, the ocean covers 70% of the Earth and serves as its largest carbon sink, holding 42 times the carbon in the atmosphere. Moreover, Europe's extensive Exclusive Economic Zone (EEZ) presents a significant opportunity to leverage the vast potential of the ocean for large-scale marine CDR (mCDR). Therefore, advancing mCDR research and development represents a strategic investment in a high-impact climate solution with the potential to remove several gigatonnes of CO₂ per year.

Many companies are already actively engaging with marine CDR, contributing valuable expertise and innovative solutions. These companies have a crucial role to play in scaling up mCDR methods. To support their efforts, the EU should encourage public-private partnerships to accelerate the development of mCDR technologies. In addition, with some of the world’s leading mCDR scientists and companies based in Europe, the EU has a unique opportunity to lead in mCDR science and technology development.

Marine CDR encompasses a range of techniques that enhance the ocean’s natural ability to capture and store CO₂ for thousands of years. Key mCDR approaches include:

  • Ocean Alkalinity Enhancement: Adding alkaline substances to seawater to increase CO₂ absorption and counteract ocean acidification.

  • Direct Ocean Capture and Storage: Extracting CO₂ directly from seawater and storing it permanently, thereby enhancing the ocean’s ability to store carbon.

  • Ocean Storage of Biomass: Capturing carbon through the growth of biomass and sinking it into the deep ocean for long-term sequestration.

  • Artificial Upwelling and Downwelling: Modifying ocean currents to stimulate CO₂ uptake by marine ecosystems.

Marine CDR provides significant climate benefits, including carbon sequestration, mitigation of ocean acidification, and support for marine ecosystem health, while also having the potential to create 11,000–16,000 jobs per 100 MT of carbon removed. However, these methods vary in their readiness for deployment, and compared to other permanent carbon removal approaches, further clarity is needed regarding their cost, monitoring, environmental impact, and social acceptance. Expanding research and real-world testing is critical to ensuring these methods are effective and environmentally responsible.

Policy Recommendations to Support mCDR

To reach the EU’s climate targets, novel approaches, including marine CDR methods, must be recognised as critical climate solutions alongside deep emissions cuts and land-based carbon removals. The European Commission has already taken steps in boosting credibility in CDR through the Carbon Removals and Carbon Farming Certification (CRCF) Regulation. However, to enable the responsible scaling of mCDR, further policy integration is required.

  • Incorporation of mCDR: The European Oceans Pact should recognise the potential of marine CDR as a tool for climate mitigation and ocean ecosystem restoration, ensuring it is part of a holistic ocean policy framework.

  • Increased R&D Funding: The EU should increase R&D Funding for marine CDR and allocate resources through programs like Horizon Europe, the European Innovation Council, and the Innovation Fund to advance scientific understanding and real-world deployment. The European Commission’s recent report on R&I needs for climate neutrality highlights marine CDR as a key solution requiring greater focus and increased research and innovation support. It underscores the urgent need for investment in research, innovation, and tailored monitoring frameworks to ensure the responsible development of mCDR.

  • Streamlined Permitting: Regulatory uncertainty and slow permitting processes are major barriers to innovation. The EU should streamline environmental permitting for mCDR pilot projects to assess efficacy and potential impacts.

  • Regulatory Sandboxes: To facilitate innovation while ensuring environmental safety, the EU should implement regulatory sandboxes that allow for small-scale, controlled deployment of mCDR methods with relaxed regulatory barriers. This would enable real-world testing of potential impacts before scaling up, fostering scientific learning while maintaining oversight.

  • Methodology Development: The Commission should provide timeline clarity on developing robust methodologies for marine CDR under the CRCF in the next round of methodologies.

  • Global Governance: Given the transboundary nature of ocean ecosystems, the EU should support global governance frameworks for mCDR to ensure responsible deployment aligned with international climate commitments. The EU specifically has the chance to address how cross-boundary carbon uptake should be addressed within the context of NDCs.

  • Community Engagement: The EU should engage with coastal communities to raise awareness and foster education on mCDR, ensuring local stakeholders are informed and involved in its development. Strengthening these relationships can help pave the way for responsible deployment and public acceptance.

Conclusion

By incorporating mCDR into the EU’s Ocean policy framework, increasing funding for research and deployment, and streamlining regulatory pathways, the Commission can unlock the ocean’s potential to contribute to net-zero goals while ensuring ecological integrity. Investment in mCDR research is crucial to assess viability, optimise methods, and mitigate risks. Without the necessary policy support, mCDR may remain a theoretical solution rather than a scalable climate strategy. The Negative Emissions Platform urges the Commission to prioritise these actions and stands ready to support efforts to responsibly scale marine CDR solutions.