Eurogas Priorities for the CO2 Markets and Infrastructure Framework

Read full Eurogas recommendations here. 

Industrial carbon management (ICM) technologies are crucial for achieving the EU’s climate target by 2050, enabling emissions reduction while ensuring a globally competitive European economy. In particular, Carbon Capture, Utilisation and Storage (CCUS) technologies play an essential role in safeguarding competitiveness and enabling negative emissions, thereby complementing, emission reduction and deployment of renewable energy.

Eurogas welcomes the European Commission’s work on developing a regulatory framework for the CO₂ market and infrastructure, notably through the upcoming CO₂ Markets and Infrastructure Package. However, the market remains at an early stage of development, with limited projects and infrastructure currently in operation, largely due to the significant financial and regulatory challenges they face.

Existing frameworks, such as the CCS Directive, the Net-Zero Industry Act (NZIA), EU competition law, and the London Protocol, provide a solid foundation. However, to avoid overly prescriptive rules, in particular in the early phases, that could hamper the development of this market, the European Commission should adopt an approach whereby, in the short term, priority is given to funding and de-risking measures to enable early CO₂ market deployment.

Nevertheless, additional regulatory measures may be required in the longer term, particularly in the event of market failures. In this context, market needs should be regularly assessed, and identified issues addressed through a phased approach, allowing regulation to be tailored and adapted to evolving market conditions.

More broadly, a well-functioning CO₂ market and infrastructure framework should be designed on the basis of technological and sectoral neutrality, while ensuring non-discriminatory access to CO₂ transport and storage capacity for all emitters.

Finally, the European Commission's work should also consider developments in the EU Emissions Trading System (ETS), which remains the central instrument for driving decarbonisation and creating incentives for investment in CCS and CCU technologies. Ensuring coherence between the CO₂ market framework and the ETS will be key to maintaining a stable and predictable carbon price signal that supports long-term investment decisions.

Against this backdrop, we believe that the following recommendations should be taken into consideration to support the scale-up of the CO₂ market and infrastructure without hindering its development.

• Prioritise De-risking and Funding
  • Business Interruption Risk
  • Market Risk
• Regulatory certainty for existing projects
• Streamline the Permitting Process
• Ensure Cross-Border CO₂ Transport
• Incentivise the Demand for a CO₂ Market
  • CO₂ Transparency Platform
• Social Acceptance and Public Engagement

Download the recommendations below.