To: The Contracting Parties to the Helsinki Convention and HELCOM Secretariat

Dear Contracting Parties to the Helsinki Convention and HELCOM Secretariat,

We, the undersigned organisations across, manufacturing sectors, sector associations, civil society organisations, and research institute underline the critical importance of enabling CO2 storage in the Baltic Sea under the Helsinki Convention. While we welcome HELCOM's efforts to seek a legal review in support of policy discussions on carbon capture and storage (CCS) in the Baltic Sea Area, we are concerned that this process alone will not unlock geological carbon storage in this area in the near term. Additional action by the Contracting Parties will therefore be necessary.

CCS is widely recognised as an essential component to achieve Europe's climate objectives and preserve the competitiveness of European industry. The Industrial Carbon Management Strategy and the Net-Zero Industry Act (NZIA) set out a vision of a single European market for CO₂ transport and storage services. Achieving this vision requires removing the legal and regulatory barriers hindering the development of CO₂ transport and storage infrastructure across Europe.

Access to environmentally sound and safe geological carbon storage will be critical for many countries in the Baltic Sea region, particularly to support the decarbonisation of energy-intensive industries with significant process emissions. Moreover, several Member States have limited suitable geological formations for permanent storage and will therefore depend on access to storage capacity elsewhere. The Baltic Sea Area has the potential to provide such capacity and can play an important role in supporting European decarbonisation efforts.

Facilitating access to storage capacity is also important in light of Article 20 of the NZIA, which establishes a Union-wide objective of at least 50 million tonnes of annual CO₂ injection capacity by 2030. Several Contracting Parties to the Helsinki Convention host obligated entities that are required to contribute to this target and will need access to sufficient CO₂ storage capacity across Europe.

However, the legal framework under the Helsinki Convention presents challenges to the development of offshore CO₂ storage projects in the Baltic Sea Area. As a result, potential storage resources remain inaccessible, investment in storage infrastructure stalls, and industries in the region face fewer pathways to decarbonise. This risks slowing down progress towards European climate targets and the development of a single market for CO₂ transport and storage services - as foreseen by the European Commission’s forthcoming CO2 transport infrastructure and markets package.

Similar barriers existed under other international treaty frameworks and were successfully addressed. For example, the London Protocol, where Parties took proactive steps to overcome obstacles that were preventing cross-border CO₂ transport and storage projects. When formal treaty processes stalled, they found a practical solution to enable CCS international cooperation.

We therefore call on the Contracting Parties, together with HELCOM Secretariat, to explore mechanisms to address the challenges currently preventing CO₂ storage in the Baltic Sea Area. Any such mechanism should ensure that carbon geological storage complies with robust environmental safeguards and remains consistent with the Convention's objectives and standards for the protection of the Baltic Sea marine environment. This is essential to enable the environmentally safe deployment of CO₂ geological storage under the Helsinki Convention.