Supporting the Development of CCUS Technologies in the NZIA DR on CO2 Injection Obligation

Read the full recommendations here.

Eurogas welcomes the publication for consultation of this Delegated Regulation, which supplements the rules under the Net Zero Industry Act (NZIA, Article 23) and aims at providing clarity on key aspects necessary to achieve the annual 50 Mt CO2 injection target by 2030 (Article 20) with oil and gas producers’ individual contributions.

Clear and transparent rules are essential for economic operators subject to this obligation, ensuring they can comply effectively and efficiently.

However, certain provisions of the draft Delegated Regulation lack clarity and may hinder the effective advancement of CCUS technologies. To ensure the regulation supports the development of CCUS, it is crucial to address these ambiguities and provide clearer guidance on implementation.

To this end, Eurogas has come up with four key recommendations:

1. The deadline for submitting plans under Article 23(4) NZIA should be postponed to 31st December 2025. This extension would provide entities with adequate time to adjust to the newly introduced requirements and to develop robust and well-structured strategies.
2. The threshold defining exempted entities should be carefully calibrated to strike a balance between safeguarding smaller entities and ensuring that the obligation is fairly distributed, while ensuring steady progress toward the 2030 CO2 injection target.
3. Increased transparency is encouraged regarding the methodology that the European Commission will use to determine the exemption threshold. This includes clarity on the conversion factors that will be applied.
4. Certain disclosure requirements raise concerns related to competitiveness and practical implementation. A careful and measured definition of the requirements set forth in Article 5 of this Delegated Regulation is therefore advised.

Read the full recommendations below for more details.