Legislative initiative on CO2 transportation infrastructure and markets

The role of the state is to set up the regulatory framework to achieve economic growth and the climate objectives. Companies should decide in which technology they would like to invest. One key challenge is that regulatory certainty is currently in the process of being developed in the Member States. Germany is just starting with its CCX regulation comprising CCU, CCS and pipeline infrastructure.

Oceana appreciates the opportunity to contribute to the European Commission's call for evidence on a legislative proposal on CO2 transportation infrastructure and markets. Oceana is significantly concerned that the EU is pushing strongly for carbon capture and storage (CCS) as part of its plan for achieving net zero emissions by 2050. CCS is extremely expensive, inefficient, and unproven at scale.

CRITICAL EVIDENCE Feedback to the EU Call for evidence on CO2 transport infrastructure and markets In this contribution we want to highlight the following: # The CLIMATE EMERGENCY we all are situated in, and towards which CCS is proposed as a tool for mitigation. This will inform if CCS can be viewed as such. # THE FRAMING OF THE NARRATIVE of CCS and the political and public reception of it.

Técnicas Reunidas (TR) is a global engineering and construction leader with more than 65 years of experience, having designed and built over 1,000 industrial plants in more than 50 countries. With a workforce of over 12,000 professionals and a strong track record in the petrochemical, oil, and natural gas sectors, TR is now leveraging its global capabilities to support Europes climate goals and industrial…

11th September 2025 EDF's position paper concerning an EC legislative initiative on CO2 transportation infrastructure and markets EDF group, which operates a largely decarbonized production fleet1, would like to share its positioning as a CO₂ emitter for the residual emissions from its thermal assets and as a potential user of CO₂ infrastructure.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Energie Beheer Nederland (hereafter: EBN) is a public company in the energy sector. We are committed to providing reliable, affordable, and sustainable energy now and in the future. As a state owned company of the Dutch government, we closely collaborate with industry partners and businesses, and contribute to the current security of energy supply in the Netherlands.

Aramis is a large scale CO2 transport project in the Netherlands that enables offshore storage. Aramis is developed in public-private cooperation between EBN, Gasunie, Shell and TotalEnergies, and develops an offshore CCS infrastructure with a capacity of 22mtpa. Please find enclosed our feedback to the Call for Evidence.

IOGP Europe input to the Call for Evidence on CO2 market and infrastructure Executive Summary To meet the EU climate 2050 neutrality objective, a robust and interoperable CO₂ transport infrastructure is essential.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Carbon Capture and Storage (CCS) is a critical enabler for Europes transition to a climate-neutral economy, particularly for hard-to-abate industrial sectors. For Tata Steel Nederland (TSN), CCS serves as both an intermediate solution to reduce emissions before low-carbon energy alternatives become widely available and as a pathway to achieve negative emissions when combined with biomethane.

We are an environmental association in the Havnsø area in Denmark, this area being the first in Denmark expected to receive CO2 for permanent storage underground. The plan is to store some 300 Mt of CO2 under populated areas including sizeable towns and under Natura2000 protected nature.

Attac Deutschland rejects Carbon Capture and Storage (CCS) as a process. The reason for this is as follows: CCS is already industrially used in the production of oil and gas: the captured CO2 is pumped back into the drilling fields for increased pressure and thus better extraction. For example, more oil and gas is being extracted, the combustion of which only releases new CO2 and an ecologically erroneous cycle.

Filed in German · English published by the European Commission

The Negative Emissions Platform (NEP) stresses that achieving climate neutrality by 2050 and moving toward net-negative emissions will require both Carbon Capture and Storage (CCS) and permanent Carbon Dioxide Removal (CDR) at industrial scale.

This comment recommends using biogenic content testing (Carbon-14) to determine the biogenic carbon content of CO2 captured and transported under a potential legislative proposal stemming from this call for evidence.

North Sea Port is a West European port that extends for more than 60 kilometers, 9.100 hectares, and across two countries: Belgium and the Netherlands. It includes a wide and diverse industrial cluster, with a clear ambition of becoming net zero by 2050. CCS is a crucial technology in order to reduce large amounts of CCS, a.o. in hard to abate industries.

Please find attached our detailed statement. The German Carbon Management Initiative welcomes the European Commissions plans to establish a European CO market and an integrated transport and storage infrastructure.

Filed in German · English published by the European Commission

Westenergy welcomes the European Commissions engagement in following the recommendations of the ICM strategy and launching the legislative initiative on CO2 transportation infrastructure and markets. We are pleased to see the acknowledgement of the importance of infrastructure access, as it is currently a major geographical barrier for decarbonisation within the European waste-to-energy (WtE) sector as well as many…

ESWET, the European Suppliers of Waste-to-Energy technology, strongly supports developing a comprehensive EU CO2 market and infrastructure framework enabling voluntary CCUS deployment across all sectors, including WtE. For further information, please refer to the attached document. WtE with CCUS represents a significant opportunity for negative emissions and circular economy.

The development of the CO2 infrastructure and market in the European Union which enables a significant reduction of carbon dioxide emissions into the atmosphere is of fundamental importance for achieving the EUs greenhouse gas reduction targets and, ultimately, for reaching climate neutrality.

FEEDBACK On the Commission’s “Call for evidence”: “CO₂ market and infrastructure in the EU“ Brussels/Berlin, September 11th 2025 Transparency register number: 1420587986-32 The German Association of Local Public Utilities „Verband kommunaler Unternehmen” (VKU) represents more than 1,600 local public utilities in Germany, operating in the sectors of energy, water/waste water, waste management and telecommunication.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eni S.p.A. response to the Call for evidence CO 2 Market and Infrastructure in the EU Eni welcomes the opportunity to provide feedback to the call for evidence for an impact assessment for the initiative CO₂ Market and Infrastructure in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CO2 Value Europe is the EU association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050.

The Polish Chamber of Chemical Industry appreciates the opportunity to provide input to the consultation CO2 transportation infrastructure and markets. The enclosed position paper outlines our key priorities and recommendations from the perspective of the Polish chemical sector.

The Aramis Launch Stores appreciate this opportunity to share our insights on the challenges related to realizing a CCS value chain as means for hard-to-abate industries to decarbonize and propose a potential solution to accelerate decarbonization efforts.

Legnica, 10th September 2025 ZPPM / 18S / IX / 2025 European Commission Directorate-General for Energy (DG ENER) Decarbonisation and Sustainability of Energy Sources (ENER.C.2) Rue Demot 24 / Demotstraat 24 1040 B - 1049 Brussels Belgium Position of the Polish Copper Employers Association on Legislative initiative on CO2 transportation infrastructure and markets (Ref. Ares(2025)6250488).

CONSULTATION RESPONSE September 2025 CO2 transport, the way forward for the chemical industry The chemical industry and many everyday products depend on carbon molecules. That carbon is and will remain at the very heart of our processes in the chemical sector. On the path towards climate neutrality, industrial carbon management and the EU CO2 market become ever more important to reduce and remove emissions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Economic and Main Committees of the district of Nordfriesland have the following comments on the project: The draft law submitted by the Federal Cabinet to the Bundestag for consultation and decision-making essentially provides for a legal framework for the authorisation of the permanent storage of carbon dioxide in underground rock layers of the continental shelf and the exclusive economic zone, no longer…

Filed in German · English published by the European Commission

Legnica, 10th September 2025 ZPPM / 18S / IX / 2025 European Commission Directorate-General for Energy (DG ENER) Decarbonisation and Sustainability of Energy Sources (ENER.C.2) Rue Demot 24 / Demotstraat 24 1040 B - 1049 Brussels Belgium Position of the Polish Copper Employers Association on Legislative initiative on CO2 transportation infrastructure and markets (Ref. Ares(2025)6250488).

Friends of the Earth Europe is deeply concerned that the European Commissions plans for CO2 transport and dumping and risk a further lock-in of fossil fuels in Europe, further support for the fossil fuel industry who are at the heart of the climate crisis, another distraction from the clean solutions which we need to pursue and yet another dangerous delay to the day when we exit all fossil fuels.

POSITION PAPER Ref. Ares(2025)7611054 - 11/09/2025 CEMBUREAU’S FEEDBACK TO THE EC CALL FOR EVIDENCE FOR THE CO2 MARKET AND INFRASTRUCTURE IN THE EU Brussels 11-09-2025 CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the opportunity to comment on the EC’s call for evidence for the CO2 market and infrastructure in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Bioenergy Association of Finland strongly supports the Commissions legislative initiative regarding CO2 transportation infrastructure and markets and appreciates the opportunity to contribute. The swift emergence of CO2 infrastructure and a well-functioning EU market for CO2 are crucial to enable the EU to reach its climate targets and to foster competitive development of carbon management value chains.

Hardly any technology is considered with as much advance vanberries, excessive expectations and false promises as carbon capture and storage (CCS). It greatly overstates the opportunities of CCS and underestimates the costs and risks to society and the environment. Greenpeace therefore strongly warns that the EU is putting the focus on CCS into a climate policy impasse and is violating its precautionary principles.

Filed in German · English published by the European Commission

Please see attached for EuLA's complete feedback. The European Lime Association (EuLA) welcomes the European Commissions initiative to establish an EU-wide CO market and infrastructure framework, aligned with the Industrial Carbon Management Strategy and the Clean Industrial Deal.

The European Industrial Gases Association represents providers/operators of carbon capture technologies. Our members have expertise in both the merchant CO2 market and major carbon capture and storage (CCS) projects, giving us a deep understanding of the challenges and opportunities in decarbonising hard-to-abate industries.

Repsol welcomes this public consultation laon the development of European CO transport infrastructure and markets, a key initiative to support the deployment of carbon capture and storage (CCS) technologies and advance towards climate neutrality goals.

ZEP welcomes the European Commissions intention to provide greater regulatory certainty for an EU CO market and infrastructure. This initiative is critical to safeguarding environmental objectives and economic welfare as industrial carbon management projects begin deploying around Europe.

EUTurbines welcomes the European Commission initiative aimed at developing competitive markets and transportation infrastructure for CO2 and agrees with the European Commissions view that carbon management is a key element for the decarbonisation of Europe.

The Global CCS Institute (Institute) welcomes the opportunity to offer its perspective in response to the call for evidence launched by the European Commission on the future legislative initiative on CO2 transportation infrastructure and markets.

CEWEP welcomes the opportunity to contribute to the call for evidence on the upcoming initiative on a CO market and infrastructure in the EU. The Waste-to-Energy (WtE) sector is ready to contribute to ensure that this framework delivers on Europes climate and circular economy objectives.

The rapid deployment of CO2 infrastructure is an important building block on the path to a carbon value chain to reach Net-Zero in 2045. During the market uptake phase, high costs should be compensated by funding. For rapid expansion, it is necessary to reduce the investment risk of network operators, for example through a payback account or direct support.

Filed in German · English published by the European Commission

It is extremely alarming that a consultation is taking place on a technology that already leads the EU to new builds of power plants and other sites with giant emissions, without the implementation of the promised CO2 reduction going beyond a laboratory nature.

Filed in German · English published by the European Commission

Port of Antwerp-Bruges welcomes the opportunity to respond to the public consultation on CO infrastructure and markets. CCUS (Carbon Capture, Utilisation & Storage) is one of the key strategies to help companies achieve net-zero emissions. The port has a clear ambition to become a CO hub, enabling companies to access exit routes for captured CO.

Bellona Europa [email removed] 42 Rue Breydel 1040, Brussels Call for evidence - CO2 transport infrastructure and markets in the EU Bellona welcomes the opportunity to provide input on the initiative to establish a wellfunctioning, EU, market-driven value chain for CO2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Celanese highly welcomes the European Commissions legislative initiative on CO2 transportation infrastructure and markets as a necessary first step of a fully-fledged EU CCUS policy framework. However, it is of critical importance for the upscale of CCUS technologies in Europe that this framework is completed with all necessary provisions encompassing the capture, transport, storage and utilisation of CO2 in all…

GIE, as EU association representing the interests of gas infrastructure operators active in transmission, storage and LNG regasification with assets and skills enabling also CCUS developments, welcomes this initiative and would like to provide the following recommendations: Access to affordable Carbon Capture Utilisation and Storage (CCUS) will be indispensable to allow EU industry to achieve European climate…

Fluxys c-grid welcomes the European Commissions initiative on CO2 transportation infrastructure and markets, recognising its vital role in delivering the EUs 2040 Climate Target and the objectives of the Net-Zero Industry Act (NZIA). Fluxys c-grid was founded in 2023 as a subsidiary of Fluxys Belgium, which holds a majority stake of 77.5%.

Heidelberg Materials welcomes the Commissions initiative to develop a legislative framework for CO transportation, infrastructure and markets. The next five years will be decisive in meeting the EUs climate targets for 2030 and 2040.

TITAN welcomes the opportunity to provide feedback to the European Commission on the forthcoming initiative concerning CO transportation infrastructure and markets. We support the Commissions efforts to establish a robust framework that will enable the timely deployment of Carbon Capture Utilisation and Storage (CCUS) across Europe.

Orlen sees the upcoming European Commission regulations on CO markets and infrastructure as a key chance to create a well-structured, investment-friendly system that encourages early adoption while building the groundwork for a stable, long-term CO market. Orlen would like to stress the importance of designing policies carefully to avoid locking in or limiting market development before it has fully matured.

Dear EU Commission. Thank you for the opportunity to provide feedback on the proposed legislative initiative concerning CO transport infrastructure and markets. We welcome the Commissions efforts to engage stakeholders in shaping policies that will determine the future of Europes climate and energy systems. However, we have serious concerns regarding the direction and implications of the current proposal.

Iberdrola supports the Industrial Carbon Management strategy, which establishes that (i) CCS must be deployed at large scale to complement other mitigation actions to address hard to abate emissions, in particular industrial process emissions, and to achieve climate neutrality by 2050, and (ii) To reach net-zero economy-wide GHG emissions by 2050, the EU could need carbon removals to balance out around 400 million…

The Federation of European Private Port Companies and Terminals FEPORT – Reply to the Call for Evidence on CO2 Markets and Infrastructure in the EU FEPORT represents the interests of private port operators and terminals performing cargo handling and logistics related activities in the seaports of the European Union, Norway, Turkey and Ukraine.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Port of Rotterdam welcomes the implementation of the Industrial Carbon Management Strategy with the announcement of a regulatory CCS package. European industry faces the challenge of decarbonising while remaining globally competitive.

The Carbon Capture and Storage Association (CCSA) welcomes the European Commissions initiative on CO transportation infrastructure and markets, recognising its vital role in delivering the EUs 2040 Climate Target and the objectives of the Net-Zero Industry Act (NZIA). A functioning, integrated, and competitive CO market is essential to enable large-scale decarbonisation of European industry.

Introduction bayernets GmbH is a leading energy infrastructure company based in Munich and an important part of the trans-European energy networks. Thanks to its close cooperation with local industry players, bayernets GmbH recognises the need for political action in the development of a CO2 market and CO2 transport infrastructure in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ISTE welcomes the European Commission’s intention to launch a legislative initiative on carbon markets and transport infrastructure. Emissions cannot be avoided in sectors such as cement, lime and waste incineration; CCS is essential in order to achieve climate neutrality. The concerns of parts of civil society that CCS could prevent effective climate protection are, in our view, unfounded.

Filed in German · English published by the European Commission

Snam, as leading multi-molecule infrastructure operator active also in CCS projects, welcomes this initiative and would like to provide the following suggestions for the establishment of a well-functioning CO2 internal Market and related Infrastructure. Further elements are provided in the attached Explanatory Note.

Royal Vopak welcomes the opportunity to provide input on the European Commission's Call for Evidence concerning the development of a CO market and infrastructure in the EU. We are committed to the energy transition, underscored by our pledge to invest EUR 1 billion in infrastructure for the energy and feedstock transition by 2030. Vopak is actively developing CO infrastructure solutions.

Lenzing AG welcomes the EU initiative to create a legislative framework for CO transport infrastructure and markets. As an energy-intensive industrial company with ambitious climate targets, we see Carbon Capture and Storage (CCS) as a potentially necessary technology for decarbonisation. However, for effective implementation, key conditions need to be met: 1.

Filed in German · English published by the European Commission

The Polish Ecological Club of Mazowiecki District has deep doubts and concerns about the proposed changes. In our view, solutions for capturing and storing CO2 and, in particular, transporting it over longer distances and injecting it into geological structures are examples of wishful thinking, focusing decision-makers on ways to maintain business as usual at all costs, the possibility of further using fossil fuels…

Filed in Polish · English published by the European Commission

The EU must ensure that CO infrastructure planning is aligned with emission reduction as the first priority. CCS and CCU must not deter from emission avoidance: A lock-in of abatable fossil emissions from fossil power generation or unsustainable biogenic emissions from forestry biomass combustion must be avoided.

CATF welcomes the opportunity to contribute to the call for evidence on the upcoming legislation for CO2 transportation infrastructure and markets, a key commitment in the Industrial Carbon Management Strategy. An appropriately designed EU regulatory framework will: Ensure that all emitters that need access to CO2 transport and storage infrastructure have access on equal terms (third-party access).

Die Entwicklung und vollständige Umsetzung neuer treibhausgasneutraler Technologien wird noch bis in die 2040er Jahre dauern. Neben der noch unzureichenden Technologiereife und dem hohen Investitionsbedarf in wirtschaftlich herausfordernden Zeiten limitiert vor allem die auf absehbare Zeit unzureichende Verfügbarkeit einer CO2-Infrastruktur sowie erneuerbarer Energie und CO2-neutralen Wasserstoffs zu…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

En2x welcomes the European Commission’s initiative on carbon market and infrastructure in the EU. Carbon management, i.e. carbon capture, transport, storage and use, is essential for the GHG-neutral future of today’s oil industry. On the one hand, captured CO2 is an important raw material for the many products that today are extracted from mineral oil to be able to provide low GHG emissions in the future.

Filed in German · English published by the European Commission

Gasgrid Finland Oy supports the initiative to develop legislation for EU-wide CO2 market and infrastructure, considering it crucial in advancing towards the EU's climate targets. When developing EU-wide regulation, we would like to emphasize the following considerations: It is vital to acknowledge the significance of biogenic CO2 in the future CO2 infrastructure and market.

We welcome the European Commissions initiative to gather evidence on CO transportation infrastructure and markets. Getting the framework right is essential to meeting Europes 2040 and 2050 climate goals and will strongly influence the trajectory of hydrogen deployment in the EU.

Please find attached Enagás' feedback on the legislative initiative concerning CO transportation infrastructure and markets. A summary of the key points is provided below. To ensure the successful deployment of CO2 infrastructure and the emergence of a well-functioning European CO2 market, it is essential to adopt a pragmatic and flexible approach.

We support the Commission's Industrial Carbon Management Strategy published in 2024, and the subsequent initiative to develop a regulatory framework for CO2 infrastructure and markets. An efficient low carbon industry indeed relies on the development of CO2 infrastructure and an appropriate regulatory framework that can facilitate the uptake of CCS, including for example for the decarbonization of existing hydrogen…

Gassco - as project manager on behalf of the CO2T project. The CO2T project consists of companies considering possibilities for CO2 storage on Norwegian Continental Shelf and are exploring the feasibility for CO2 transport solutions from emission sources in Germany and other locations in North-West Europe for permanent storage in sub-seabed aquifers offshore Norway.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Through its entities Supply & Energy Management (gas midstreamer), NaTran (gas TSO), and Elengy (LNG terminal operator), ENGIE is committed to supporting the development of a competitive European CO market, underpinned by infrastructure for CO transport, storage, and utilisation. Access to affordable and reliable CCUS is essential for EU industry to meet EU climate objectives.

Investments in CO2 transport infrastructure risk diverting critical time and resources away from more effective climate action, while simultaneously prolonging reliance on fossil fuels. Building large-scale CO2 transport infrastructure to support Carbon Capture & Storage (CCS), Carbon Capture & Utilisation (CCU) or Carbon Dioxide Removal (CDR) approaches like Bioenergy with CCS (BECCS) or Direct Air Capture with CCS…

Comments from the Norwegian Environment Agency 11. September 2025 Legislative initiative on CO2 transportation infrastructure and markets We welcome the European Commission’s initiative on CO2 market and infrastructure in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ENTSOG welcomes the development of a new legislative initiative for EU CO Markets and Transportation Infrastructure. ENTSOG also supports the EU Grid Package, enabling CO infrastructure alongside CH4, H2, biogases and electrons. This integrated approach to EU networks addresses investment barriers, noting that delays in infrastructure development could undermine the cost-efficiency of the energy transition.

PTECO2 welcomes the opportunity to provide feedback through this call for evidence to the upcoming legislative initiative on CO transport infrastructure and markets. PTECO2 an initiative promoted by the private sector, research centers, and Spanish universities aimed at fostering the development and implementation of CCUS technologies and CO uses, with the goal of helping Spain meet its emission reduction…

Exolum, a leading European bulk liquid logistics company, presents its feedback on the EUs legislative initiative for CO transportation infrastructure and markets. With nearly a century of experience, Exolum is developing strategic CO hubs in Spain (La Coruña and Huelva) to connect captured CO from multiple emitters with permanent storage sites and e-fuel production facilities.

CCUS technology can play a pivotal role in the energy transition and the decarbonisation of European industry, while making a significant contribution to the overarching objectives of EU climate policy. The establishment of coherent, transparent and EU-wide regulatory frameworks should enable the dynamic development of this technology which is particularly relevant for the decarbonisation of hard-to-abate sectors.

Elyse Energy fully supports the Commission’s initiative and its commitment to a harmonised and robust framework for CO2 transport, storage and capture infrastructure. This framework seems to us to be essential for the emergence of a robust, competitive and sustainable European market for CO needed to achieve the climate neutrality objectives in 2050.

Filed in French · English published by the European Commission

CCS Europe welcomes the opportunity to contribute to the European Commissions call for evidence on the forthcoming legislation for CO transportation infrastructure and markets. The capture of CO2 for permanent storage or use with a climate benefit is recognised by the European Commission as essential to achieve net-zero emissions by 2050.

As a an environmental organisation with over 500.000 members in Germany, BUND strongly opposes the plans of de-risking and deregulating CO2-transport infrastructure in the EU, Instead of gambling on CCS, the EU must phase out all fossil fuels, fully and fast. +++Together with more than 100 organizations, experts, companies and citizens' initiatives we have expressed opposition to the German CO2 infrastructure law.

Equinor response to EU Commission Call for Evidence for an Impact Assessment CO2 market and infrastructure in the EU Equinor is an international energy company headquartered in Norway, with the ambition to be a leading force in the energy transition by making sustainable energy available to all.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PRIMIGEA welcomes the opportunity to provide its input on the European Commissions legislative initiative regarding CO transport and storage infrastructure. We positively receive this consultation as a means to defend the legitimate interests of our members in the extractive industries of mineral raw materials. In this context, we wish to present the following considerations.

Carbon Capture and Storage implies that the captured CO2 must be transported from the industry to the end destination, in many cases through a seaport, where it might be temporary stored. This transport usually requires a pipeline system and/or other modes of transport (rail, road, inland barge) and often liquefaction, unloading and loading facilities and dedicated CO2 terminals, all within, towards, and/or from the…

Europe is setting the course for infrastructure rules that will underpin its carbon management system for decades. The upcoming Regulation will make up the network blueprint that will define who gets to participate in Europes carbon management and who is left behind.

Ørsted welcomes the EU Commissions prioritization of a legislative initiative on CO transportation infrastructure and markets. We view the deployment of carbon capture and storage (CCS) as essential for achieving EU and national climate targets in a cost-efficient manner and we remain fully committed to CCS and CDR as essential parts of Europes climate toolbox.

EdEn believes CO2 capture and storage will be needed to offset residual emissions from hard-to-abate industrial sectors. Industrial carbon removals from biogenic and possibly from atmospheric sources will also be an essential component in the manufacture of chemicals, plastic products and synthetic fuels.

Gemeinde Dagebüll 25899 Dagebüll Sehr geehrte Damen und Herren, Wir lehnen das von der EU geplante Hochfahren von CCS ab, denn CCS ist nicht klimaneutral, sondern beschleunigt die Klimakatastrophe. Ein weiterer Meeresspiegelanstieg wäre für die Küste, viele Hafenstädte und manche Länder eine Katastrophe. 1. Das CO2 wird nur unvollständig bisher zu maximal 85% abgeschieden 2.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sehr geehrte Damen und Herren, vielen Dank für die Möglichkeit zur Stellungnahme. Die grundsätzliche Frage ist: Warum CCS? Im Gegensatz zu allen anderen Industrien gibt es bei CCS keinerlei Wertschöpfung, sondern nur eine Kapitalvernichtung und Müllerzeugung. Die Gefahren und Kosten durch CCS werden vollkommen ausgeblendet. CCS ist eine Klimalüge und ein gefährlicher, unumkehrbarer Irrweg für Menschen und Umwelt.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Carbon Capture, Transport, Storage and Utilisation (CCUS) are indispensable components of the EU climate strategy. Time is short: The construction of a functioning CO transport infrastructure and value chain must be fast. Investment readiness and concrete project planning depend directly on a reliable financial, policy and regulatory framework.

Filed in German · English published by the European Commission

Shell appreciates the opportunity to share our views on the development of a CO transportation network in the European Union. We welcome the Commissions recognition of Carbon Capture and Storage (CCS) as a strategic technology under the Industrial Carbon Management Strategy (ICMS).

The European Biogas Association (EBA) welcomes the Commissions initiative to establish a legislative framework for a well-functioning EU CO market and infrastructure. We consider EU-level action crucial to harmonise and scale up the sector, remove barriers to cross-border trade, lower costs, boost competitiveness and reinforce investor confidence. The attached document sets out EBAs related recommendations.

Düsseldorf, 11.09.2025 Ref. Ares(2025)7589671 - 11/09/2025 STELLUNGNAHME zur Initiative „CO2-Markt und CO2-Infrastruktur in der EU“ ITAD e.V. ist die Interessengemeinschaft der Thermischen Abfallbehandlungsanlagen in Deutschland. Über 90 Thermische Abfallbehandlungsanlagen (TAB) mit rund 95 % der bundesdeutschen Behandlungskapazität sind Mitglied. Sie verwerten mit über 7.000 Mitarbeitern jährlich über 25 Mio.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

RWE supports the development of a CO2 network to facilitate the integration and adoption of Carbon Capture and Storage (CCS) and Carbon Capture and Usage (CCU) in hard-to-abate/decarbonise sectors, and to enable BECC(U)S or DACC(U)S projects to generate carbon removals. Regulation should be targeted to support market and infrastructure development. Please find our detailed response attached.

Feedback on the Call for Evidence for a CO₂ market and infrastructure The Norwegian Shipowners’ Association (NSA) appreciates the opportunity to provide feedback on the European Commission’s initiative to develop a CO₂ market and infrastructure. NSA represents 130 members with 1400 ships and rigs operating around the globe. Measured by value, the Norwegian fleet is the fifth largest in the world.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This evidence is submitted on behalf of NRDC (Natural Resources Defense Council). As a North American environmental NGO we are concerned about the EU’s use of woody biomass for energy from North American forests, as well as the impacts on the EU’s own forests and ecosystems. Any promotion of carbon capture systems could encourage the use of biomass for Bio-CCS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dagebüller National Park Watt Leader Dr Walther Petersen-Andresen [address removed] ladies and gentlemen, We oppose the EU’s planned ramp-up of CCS and instead call on the EU to take immediate action to effectively slow down the climate catastrophe by: (1) to consistently save energy, as only the energy saved is truly climate neutral. 2.

Filed in German · English published by the European Commission

My feedback on CO2 transportation and infrastructure include the EU's CO2 Transport Infrastructure Initiative, which ensures fair access to infrastructure, aims to prevent high user tariffs, and promotes a safe and cost-efficient network; and Norway and the Netherlands' Joint CO2 Project, which is a memorandum of understanding to jointly develop infrastructure to transport CO2 for storage in the Danish North Sea.

NET4GAS is in full support of Commission's intention to establish a framework enabling the emergence of CO2 infrastructure and a well-functioning market for CO2. Please find below the list of principles and mechanisms the proposal shall include. Regulatory Framework and Governance The regulation of CO2 transport infrastructure would depend on market maturity and size.

European CO2 transport framework – position paper Belgium 1 CONTEXT The European Commission is currently preparing a regulatory framework on CO2-transport. The aim of this initiative is to provide regulatory certainty to the sector at a European scale and facilitate the necessary emergence of cross-border infrastructure.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The CCUS Poland Association welcomes the Commissions initiative to remove barriers to the development of CO infrastructure and the EU carbon market. Based on analyses of Polands regulatory needs, our members present the following key requests to the Commission. a. Infrastructure planning We call for mandatory preparation of national CO infrastructure development plans by all EU Member States.

Date: 19 August 2025 Typ behandelaar Subject: Porthos – Feedback on Legislative initiative for CO2 Transport Infrastructure and Markets Dear reader, Porthos is the first large-scale CO₂ transport and storage project in the European Union. It will transport CO₂ from industry in the Port of Rotterdam and store it in depleted gas fields under the North Sea.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We acknowledge the need for carbon management to capture unavoidable emissions. However, as a regulatory authority we do not consider comprehensive regulation of the CO2 transport and storage structure to be appropriate or legally necessary at the present time. There is no market for CO2 yet. Introducing regulation at the present time may be detrimental to development.

The Duisburger Hafen AG (Duisport) welcomes the EU initiative to create a single legal framework for CO transport infrastructure and a functioning European carbon market. This is seen as a crucial building block for European climate goals, especially in emission-intensive industries, where Carbon Capture, Utilisation and Storage (CCUS) is central.

Filed in German · English published by the European Commission

Carbon capture and storage (CCS) is extremely expensive, cannot actually capture sufficient emissions or store them safely, and will expose local communities and nature to risk across Europe if a CO2 transport network is built.

Stellungnahme der MVV Energie AG zur Initiative CO2-Markt und CO2-Infrastruktur in der EU Art des Rechtakts: Thema: Vorschlag für eine Verordnung Energie Über die MVV Energie AG Mit über 6.600 Beschäftigten sowie einem Jahresumsatz von rund 7,2 Milliarden Euro im Geschäftsjahr 2024 ist MVV eines der führenden Energieunternehmen in Deutschland.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We support a European coordinated initiative for the ramp-up of CO2 infrastructure. As an input to the Call for Evidence, our map provides an overview of the locations of CCU/CCS projects currently under discussion (with a focus on North Rhine-Westphalia): https://www.google.com/maps/d/u/0/viewer?mid=1prz_ns6tdj_1kacbrcm47q_299-3QxA&ll=36.756327410170066%2C15.217670839265146&z=5 Furthermore, we would like to see our…

Filed in German · English published by the European Commission

DIHK Feedback on the planned EU initiative CO Market and CO Infrastructure. As the largest business organization in Germany, the Association of German Chambers of Commerce and Industry (DIHK) strongly supports the European Commissions initiative to establish a functioning CO market and an integrated CO infrastructure in the EU.

MAGES appreciates the opportunity to contribute to the European Commissions public consultation on the Legislative initiative on CO transportation infrastructure and markets. Our position paper outlines actionable steps for a coherent, cross-border CO transport and storage framework, and we look forward to working with the Commission on next-stage design and delivery.

OFICEMEN is pleased to have the opportunity to contribute to the European Commission's public consultation on the legislative initiative on CO2 transportation infrastructure and markets. The attached position paper is submitted to support the establishment of a coherent, cross-border framework that will enable the timely, safe and cost-effective transport and storage of CO for hard-to-abate industries.

SOMO strongly cautions against the European Commissions plans to scale up Carbon Capture and Storage (CCS) infrastructure. The proposed legislation may lead to scientifically unsound and dangerous CO2 pipelines and will support carbon markets that are based on colonial, unjust and exploitative structures. unfair carbon markets.

Teréga welcomes the upcoming legislative initiative on CO2 transportation infrastructure and markets and the current call for evidence. The development of a competitive Carbon Capture, Utilisation, and Storage (CCUS) value chain is an essential pillar for achieving the EU's decarbonisation goals, particularly for hard-to-abate industries and for the production of sustainable aviation fuels (e-SAF) leveraging…

Seas At Risk welcomes this opportunity to share its insights on CO2 transportation infrastructure and markets. The past decade, several scientific warnings have been issues about the significant risks that Carbon Capture and Storage (CCS) poses to the marine and coastal environment. These include risks related to pipeline construction, port expansion, seismic surveys, increased ship traffic, and ocean storage.

Our feedback to the European Commission links the development of a CO Market and Infrastructure with the EU Trade Framework 2025 (EUTIR), advocating for a unified digital trust backbone. We demonstrate how EUTIRs secure, interoperable registry can provide legal certainty, reduce risks, and enable SME access for cross-border carbon transport and storage.

EPICO KlimaInnovation welcomes the Commissions initiative to establish a comprehensive CO market and infrastructure framework for CCUS. Carbon management is a central pillar of Europes net-zero pathway, particularly for the most hard-to-abate sectors.

Unfortunately, the punctuation on our previous submission was lost when pasting into the online form,. Therefore, please also find attached a copy of the original file. It is the same text as previously submitted, but hopefully is easier to read, with all the punctuation and formatting in place.

Stellungnahme der Stadtwerke München GmbH zu einer Folgenabschätzung der Europäischen Kommission zur Initiative „CO2-Markt und CO2Infrastruktur in der EU“ Transparenzregisternummer (EU): 17284292859-45 Positionspapier EnWG Novelle I. Einleitung Die Stadtwerke München (SWM) begrüßen die Initiative der EU-Kommission, eine Folgenabschätzung zu den Themen CO₂-Markt und CO₂-Infrastruktur in der EU durchzuführen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The International Chamber of Shipping welcomes the European Commissions consultation on this matter. We offer the following comments: This initiative is focused on CO2 capture and geological sequestration. Indeed , this is currently the most mature technological pathway for shipping and is well suited to the liner trade where ships regularly operate on one or more set routes.

The Major River-Sea Port of the Seine Axis HAROPA PORT has united the ports of Le Havre, Rouen, and Paris under one public authority since 2021. As Frances largest port, it handles 102 million tonnes of annual maritime and inland traffic, generating 7.3 billion in economic value and supporting around 160,000 jobs. Attached, our contribution in both French and English.

Dansk Offshores comments to the Call for evidence Dansk Offshore, the Danish Industry Association for CO2 storage license holders, welcomes the opportunity to comment on the Commission’s call for evidence. For Dansk Offshore it is vital to emphasize that Carbon Capture and Storage (CCS) is a new industry that needs to find its feet too. Hence the development must be driven by market forces.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ladies and Gentlemen, we thank you for the opportunity to comment. Please also refer to the pdf attached. In 2009, the European Commission called for commercial CCS capability in 1 015 years up to 2020 and supported billions of euros. The IEA also noted in 2009 that CCS must be established by 2020 or that the fight against climate change would come too late.

Filed in German · English published by the European Commission

I am very pleased that I can provide feedback for our Renewable Energy Roundtable (RT-EE, www.energiewende-2030.de). Openly in DE, we have been intensively involved in the effort, risks and benefits of large-scale industrial processes for the capture and permanent storage of ‘C’ for a few years with science and engineering knowhow.

Filed in German · English published by the European Commission

We reject the proposals to remove barriers to and de-risk CCS in the EU. Based on the evidence gained over years and decades of CCS, we cannot see how it can ever play a role in a meaningful response to the climate crisis. The actual barriers to CCS are interconnected technical, economic and safety problems.

UPRIGAZ shares the EC’s position on the need for CCUS to meet its 2050 climate targets, as a complement to the lattenuation of GHG emissions. We welcome the EU’s initiatives to move towards greater use of the CCUS, be it the Directive on the geological storage of carbon dioxide, the Net-Zero Industry Act, which aims to create an EU market for CO2 storage services, sets a legally binding target of 50 Mt of annual CO2…

Filed in French · English published by the European Commission

Bigger climate benefits (CCS) and energy savings can be gained from coupling the biogas and geothermal sectors. This will allow geothermal wells to be drilled much shallower, reducing well costs, and to produce artificially hot reservoir fluids for power production.

The development of markets and infrastructure for the transport and storage of CO in the EU is associated with many risks and open questions, which should be examined in an Impact Assessment. In the current debate, the potential of the technology is emphasized, while its limitations and risks for humans and the environment tend to be underestimated.

The Czech Gas Association fully supports the Commissions intention to establish a framework enabling the emergence of CO infrastructure and a well-functioning market for CO. Please find below the list of principles and mechanisms that the proposal should include. The full version of the feedback from the Czech Gas Association is attached.

As an actor engaged in the development of the first CO2 transport infrastructure in France, we welcome the European Commission’s initiative to establish a legislative framework for industrial carbon management. To ensure a rapid and economically viable deployment of a CCUS value chain in the Rhône Valley, SPSE would like to stress the need for a clear and stable regulatory framework, which would take into account…

Filed in French · English published by the European Commission

The European heavy industry is currently facing an unprecedented crisis, mainly due to environmental challenges as well as unsustainable energy and raw material costs, which also heavily affects all of the downstream industrial sectors.

The Government of the Canary Islands, as an outermost region recognised in Article 349 TFEU, has made comments on European initiatives linked to zero emissions industry and CO management, stressing that the geographical, geological and industrial characteristics of the archipelago limit its participation in this area.

Filed in Spanish · English published by the European Commission

Vantaan Energia (VE) welcomes the Commissions plan for a legislative initiative on CO transportation infrastructure and markets and appreciates the opportunity to contribute. VE would like to highlight the significance of its Carbon Capture and Storage (CCS) project for creating a CO value chain Nordic countries and supports the development of a regulatory framework that enables competitive EU-wide CO markets and…

* CO2 Pipeline Network Planning: CO transport infrastructure requires long-term strategic planning due to its scaling effect and investment needs. EU-level planning is vital for cross-border coordination and decarbonization, while national-level planning ensures local relevance and implementation.

Von Wirtschaftskammer Österreich Bundessparte Industrie An Europäische Kommission GD ENER – Referat C2 Ihr Zeichen, Ihre Nachricht vom Sparte Industrie Wirtschaftskammer Österreich Wiedner Hauptstraße 63 | Postfach 330 1045 Wien T [phone removed] E [email removed] W wko.at/industrie Unser Zeichen/Sachbearbeiter Durchwahl Datum WoBre 3076 8.9.2025 CO2-Markt und CO2-Infrastruktur in der EU Sehr geehrte Damen und…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We must express our deepest concerns about this consultation. There is no evidence that establishing a CO2 infrastructure in the EU would help to combat climate change. On the contrary, it would undoubtedly cause additional CO2 emissions, thereby undermining climate protection efforts.

Legislative initiative on CO2 transportation infrastructure and markets Estonia has accumulated over 1 billion tons of industrial waste, including 500 million tons of oil shale ash, which burdens the environment. These ash deposits now present an opportunity to reclaim critical raw materials like silica, magnesium, and aluminium, reducing EU dependence on imported resources through recycling.

Call FOR A IMPACT ASSESSMENT – Carbon Market and Carbon Infrastructure in the EU CCS Carbon Capture and Storage entails significant costs, risks and implementation barriers. The technology remains expensive, vulnerable to disruption and impossible to implement without government subsidies.

Filed in German · English published by the European Commission

The German NGO Forum on Environment and Development is gravely concerned that this legislation could pave the way for reckless and unscientific schemes involving dangerous and wasteful CO pipelines, as well as unfair carbon markets. Such measures would entrench Europes dependence on fossil fuels for decades to come. The planned CO pipeline network for industrially captured CO would not carry pure CO.

It is surprising, and even scandalous, that this consultation on CCUS is happening. The fossil fuels industry has been pushing the concept in policy for at least three decades, arguing this would be a way to produce low carbon fossil fuels and that CCS technologies would be needed to reach climate goals.

Carbon Capture and Storage (CCS) threatens climate goals and the transformation to a future-proof economy While governments are rightly committed to achieving their climate targets under the Paris Agreement and moving towards net zero by 2045, the growing emphasis on CCS and Carbon Capture and Utilization (CCU) as essential instruments is misguided.

The Nordic Carbon Removal Association Supports a Coordinated EU Strategy for CO Transport and Storage Infrastructure. The Nordic Carbon Removal Association (NCRA) is the voice of the Nordic carbon dioxide removal (CDR) sector. Our mission is to drive strong and sustained demand for, and supply of, high-quality carbon removal in the Nordics while fostering a globally competitive Nordic CDR industry.

As an e-fuel (RFNBOs) project developer, MGH Energy welcomes this call for evidence which implements commitments made in the EU Carbon Management Strategy (ICM) of 6 February 2024: - Propose a future CO2 transport regulatory package; - Propose an EU-wide CO2 transport infrastructure planning mechanism.

Energinet welcomes the development of a new legislative initiative for the establishment of rules for an EU CO Market and Infrastructure. It is important to acknowledge that the CO market and related infrastructure remain at a very early stage of development, with significant uncertainty about how it will evolve.

The European Advanced Carbon and Graphite Materials Association (ECGA) recognises the Commissions intention to implement the CO transport infrastructure as part of the EUs efforts to achieve climate neutrality. While the objective is understood, there are reasons for concern that warrant careful consideration.

Chemelot welcomes the European Commissions initiative to create a strong framework for CO transport infrastructure and market design. Without large-scale Carbon Capture, Utilisation and Storage (CCUS), the EU will not meet its 2050 climate neutrality target. CCUS is particularly essential for hard-to-abate sectors such as chemicals, cement and steel.

Legislative initiative on CO2 transportation infrastructure and markets Position of the Czech Chamber of Commerce The Czech Chamber of Commerce welcomes the opportunity to comment on the call for evidence on legislative initiative on CO2 transportation infrastructure and markets. You can find the comments of our members below.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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.

Wiener Stadtwerke Input for the Commission’s initiative on CO2 transportation infrastructure and markets September 2, 2025 The Wiener Stadtwerke Group welcomes the Commission's ambition to develop markets and transportation infrastructure for CO2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CCS, as a technology to capture CO2 and store it in deep earths on land or under the sea, is not sustainable as such. This is through the analysis of entropie production (see various publications: https://www.bernhard-wessling.com/nachhaltigkeit_und_entropie) became clear.

Filed in German · English published by the European Commission

The North Rhine-Westphalia Regional Association of the Federal Union for the Environment and Nature Conservation Germany (BUND) sees the initiative for a carbon market and carbon infrastructure as a major risk for real climate protection and fears massive environmental impacts.

Filed in German · English published by the European Commission

Zero Waste Europe welcomes the opportunity to contribute to the call for evidence on the upcoming initiative on a CO market and infrastructure in the EU. We recognise that carbon management will play a role in the EUs 2040 and 2050 climate objectives.

VDZ thanks for the opportunity to provide additional input on the development of a robust European CO infrastructure and welcomes the EU Commissions intention to establish, if necessary, a new legislative initiative with rules for an EU CO2 market and a CO2 infrastructure. This shall also consider, that time is of essence. Appropriate measures should at best speed-up, not hinder nor delay a fast built-up.

Brussels, February 2025 Position Paper on Carbon Capture, Utilisation and Storage Main Recommendations ECSA calls on the Commission to: • Accelerate the implementation of the Net-Zero Industry Act, in particular the establishment of a single market for CO2 and guidelines for maritime transport of CO2 as well as accelerate the work on carbon credits.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Barge Union EBU, representing the barge owners and operators in Europe, welcomes the call for evidence on the CO2 market and infrastructure in the EU and is pleased to provide its input with the attachment position paper as Inland Waterway Transport is predestined to absorb new cargo flows like CO2 on the European waterways while guaranteeing the highest safety standard.

To ensure effective and proportionate CCS regulation that enables timely infrastructure deployment across all Member States, including smaller markets relying on terminals, we would like to provide the following comments: 1.