Towards a European cross border CO2 transport and storage infrastructure Recommendations ahead of the EU Industrial Carbon Management Strategy.pdf

Ref. Ares(2023)6340073 - 19/09/2023

Towards a European cross-border CO2 transport and storage
infrastructure: Recommendations ahead of the EU Industrial Carbon
Management Strategy

Report of the CCUS Forum Working Group on CO2 Infrastructure

September 2023

EXECUTIVE SUMMARY
Reducing  emissions  by  2030  and  reaching  climate  neutrality  by  2050  is  the  main  objective  of  EU
climate action and the most important global challenge. There is evidence that carbon capture and
storage (CCS) and some applications of carbon capture and utilisation (CCU) can effectively contribute
to  climate  change  mitigation  efforts.  These  technologies  are  crucial  for  the  decarbonisation  of
industry,  in  particular  the  harder-to-abate  sectors  –  and  enable  carbon  dioxide  removal  (negative
emissions) which can balance out residual emissions – contributing to economic growth, sustaining
current jobs, and creating new ones.
Recent developments in industrial carbon management testify to the strong momentum for CCS and
CCU in Europe. While industry is ready to deploy, political support has not  always been sufficient,
leading to uncertainty and delays. At the same time, technical, regulatory, and economic challenges
still hinder the development and scale-up of these technologies in Europe.
We welcome the establishment of the CCUS Forum which, through the established working groups,
can  identify  the  actions  that  are  urgently  needed  to  support  the  deployment  of  CCS  and  CCU  to
decarbonise industry. This paper identifies and describes the key technical, regulatory, and economic
challenges  to  the  development  of  a  robust,  non-discriminatory,  open-access,  cross-border  CO2
transport and storage infrastructure in Europe. It is critical that the European Commission responds
to this paper with concrete measures, supporting European global leadership in innovative low-carbon
technologies, in line with the objective to be the first climate-neutral continent by 2050.
The key findings and recommendations of this paper can be summarised as follows:
•  A  non-discriminatory,  open-access,  cross-border  Europe-wide  CO2  transport  and  storage
infrastructure, with unbundling between transport and storage, is crucial for Europe to reach
climate neutrality.
•  There  is  an  urgent  need  for  a  fit-for-purpose  EU  regulatory  framework  for  CO2  transport
infrastructure to complement the CO2 Storage (CCS) Directive.
•  The directive 2009/31/EC CO2 storage (CCS) Directive is a good basis for CO2 storage. This
Directive’s Guidance documents are being revised but the Directive itself should not, at this
time, be opened for review.
•  There  is  a  need  for  clarity  regarding  the  conversion  of  hydrocarbon  fields  from  oil  &  gas
operations to CO2 storage reservoir operations in terms of liability.
•  Interoperability is crucial for the development of the Europe-wide CO2 transport and storage
infrastructure.  Standards/network  codes  are  needed  for  CO2  specifications,  addressing  the
different  technologies  and  segments  of  the  CCUS  value  chain,  also  bearing  in  mind  cost
effectiveness considerations. The report of the CCUS Forum expert group highlights that safe
transport of impure CO2 streams is possible today and recommends the European Commission
to  develop  a  strategy  and  clear  targets  for  a  common  European  CO2  transport  network;
develop as rapidly as possible a network code and standards for a multimodal CO2 transport
network in the EU/EEA; and to support and prioritise research in this field.
•  Limited access to information is a barrier to CO2 storage appraisal and characterisation. Access
on a non-reliance basis to crucial (non-confidential) information in areas where CO2 storage
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sites can be permitted is a must to support the development of storage sites in Europe, and
an integral part of a European Storage Atlas.
•  Capacity building within competent authorities, efficient permitting processes and ensuring a
sufficient  number  of  permitting  and  licensing  rounds  is  crucial.  Early  engagement  –  and
ongoing interactions and discussions – between competent authorities and project promoters
is vital to the success of CCUS projects.
•  All  relevant  EU  and  national  funding  programmes  should  be  adapted  to  maximise  their
potential to fund CO2 infrastructure projects and to avoid ‘chicken and egg’ challenges along
the value chain.
•  There is a need to further clarify the legal basis for the export of CO2 for offshore storage,
linked  to  the  London  protocol  application  within  the  EU/EEA  area,  to  enable  large-scale
development of CO2 transport networks in Europe.
•  It is important to resolve the EU-UK cross-border issues – enabling CO2 captured in the EU and
stored in the UK without having to submit emission allowances under the EU ETS, and vice
versa – to ensure the development of a Europe-wide CO2 market.
•  Successful deployment of CO2 capture, transport and storage at scale will depend on a proper
allocation of liabilities and contracts  between the entities operating along the value  chain.
Risk-sharing  and  transfer  of  liabilities  between  the  storage  developer  and  the  regulatory
authority/the state is key to balance risks and rewards and de-risk the needed investments,
supporting project development.
It should be noted that experience is and will continue to evolve with early CCS and CCU projects.
These  projects  will  allow  the  identification  of  new challenges/barriers  and  it  is  important  that  the
European Commission keeps engaging with industry players to create favourable conditions for the
development and operation of these projects, along with civil society and the research and innovation
(R&I) community. Similarly, different initiatives and programmes that are already in place should be
reviewed as a way to identify possible learnings and best practices.

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1.  Introduction
1.1 Scope
The objective of this paper is to provide clear recommendations to the European Commission (EC) on
how to sustainably develop and deploy European CO2 transport and storage infrastructure to reach
climate neutrality by 2050. In this context, the report identifies key regulatory and technical challenges
to be addressed to enable the development of an integrated CO2 network.
The  paper  focuses  on  the  CO2  transport  and  storage  components  of  the  value  chain  (and  not  on
capture), highlighting their technical, regulatory and economic dimensions. Recognising the efficiency
gains of developing broad CO2 markets, the paper takes a wider European perspective, rather than
focusing only on EU Member States.
This  paper  does  not  attempt  to  describe,  in  detail,  the  challenges  faced  by  each  individual  carbon
capture  and  storage  (CCS)  and  carbon  capture  and  utilisation  (CCU)  technology.  Similarly,  it  is
recognised  that,  compared  to  CCS  and  carbon  dioxide  removal  (CDR),  CCU  solutions  involve  more
complex value chains, with implications for the planning of transport infrastructure. Nevertheless, all
CO2  flows  –  CCS,  CDR,  CCU  etc.  –  need  to  be  taken  into  account  in  infrastructure  planning  and
development,  which  calls  for  continued  investigation  of  the  challenges  and  needs  of  different
technologies. In addition, at the basis of infrastructure development must be a rigorous assessment
of the contribution of the different technologies/projects to climate change mitigation, based on best
available  scientific  evidence,  a  full  life-cycle  assessment  (including  energy  use  and  end-of-life)  and
thorough carbon accounting, scalability potential within a relevant timeline, and relevance compared
to  counterfactual  scenarios.  Similarly,  environmental  and  energy  efficiency  principles  are  to  be
preserved, ensuring that infrastructure development promotes the most efficient solutions for climate
neutrality.
The working group (WG) on CO2 infrastructure urges the EC to respond to this paper with concrete
action,  by  filling  in  the  policy  gaps  and  by  addressing  the  technical  and  economic  constraints  that
hinder the development and scale-up of CO2 transport and storage infrastructure.

1.2 Work process
The report is developed by the WG on CO2 infrastructure, based on discussions and input received
from  a  broad  membership,  including  stakeholders  from  industry,  energy,  researchers,  and
environmental NGOs, as well as on existing work that reflects information and research (e.g., reports,
studies). The report builds on the issue paper developed by the WG in December 20221, presented at
the 2022 CCUS Forum Plenary (27-28 October 2022)2.
To prepare this report, the WG held four meetings between July and November 2022, three thematic
workshops – dedicated to the regulatory, technical, and economic dimensions respectively – in the
beginning  of  2023,  and  a  final  meeting  in  June  2023.  The  WG  benefited  from  active  and  fruitful
participation, reflecting the urgency of sustainably developing and scaling up CCUS in Europe.

1 Available here.
2 More on the European Commission’s CCUS Forum here.
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In addition, given the critical importance of standards/network codes for the CCS value chain, the WG
established, in the beginning of 2023, an expert group to work on the technical components, e.g., CO2
specifications.
The report should be seen as an integral part of the work conducted under the three CCUS Forum
WGs, engaged by the EC. Notably, the WG on CO2 infrastructure has coordinated with the WG CCUS
Vision.  The  WG  has  also  coordinated  with  and  provided  input  to  the  EC  technical  and  regulatory
studies on CO2 infrastructure by EnTEC and the Joint Research Centre (JRC) and the DNV review of the
CO2 Storage (CCS) Directive’s Guidance Documents.

1.3 Statement of the challenge
Reducing  emissions  by 2030  and  reaching  net-zero greenhouse  gas  emissions by  2050  is the  main
objective of EU climate action and the most important global challenge. To achieve these objectives,
urgent actions must be implemented, based on clear scientific evidence about the role of the different
technology  solutions.  There  is  evidence  that  CCS  can  contribute  to  significantly  reduce  carbon
emissions  into  the  atmosphere,  being  employed  in  the  majority  of  decarbonisation  scenarios
consistent with the 1.5°C and 2°C global temperature targets. Some CCU applications can effectively
contribute to mitigation3.
The findings of the 6th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC)
working group III4 show that:
•  “CCS  is  an  option  to  reduce  emissions  from  large-scale  fossil-based  energy  and  industry
sources,  provided  geological  storage  is  available.  When  CO2  is  captured  directly  from  the
atmosphere (DACCS), or from biomass (BECCS), CCS provides the storage component of these
CDR methods”
•  “The deployment of carbon dioxide removal (CDR) to counterbalance hard-to-abate residual
emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved. (…) CDR refers
to  anthropogenic  activities  that  remove  CO2  from  the  atmosphere  and  store  it  durably  in
geological, terrestrial, or ocean reservoirs, or in products”
•  “(…) not all end-uses are expected to be commercially electrifiable in the short to medium
term  {11.3.5},  and  many  will  require  low  GHG  liquid  and  gaseous  fuels,  i.e.,  hydrogen,
ammonia, and biogenic and synthetic low GHG hydrocarbons made from low GHG hydrogen,
oxygen and carbon sources (the latter from CCU, biomass, or direct air capture”
•  "Carbon  is  a  key  building  block  in  organic  chemicals,  fuels  and  materials  and  will  remain
important (high confidence). In order to reach net zero CO2 emissions for the carbon needed
in society (e.g., plastics, wood, aviation fuels, solvents, etc.), it is important to close the use
loops  for  carbon  and  carbon  dioxide  through  increased  circularity  with  mechanical  and
chemical  recycling,  more  efficient  use  of  biomass  feedstock  with  addition  of  low-GHG
hydrogen  to  increase  product  yields  (e.g.,  for  biomethane  and  methanol),  and  potentially
direct air capture of CO2 as a new carbon source”

3 For a revision of the role of CCS and CCU in the EU decarbonisation scenarios, see: Butnar, I., Cronin, J., & Pye,
S. (2020). Review of Carbon Capture Utilisation and Carbon Capture and Storage in future EU decarbonisation
scenarios. UCL Energy Institute (part of the CCUS SET-Plan Implementation Plan work).
4 Intergovernmental Panel on Climate Change (2022). Climate Change 2022: Mitigation of Climate Change.
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•  “Reducing emissions from the production and use of chemicals would need to rely on a life
cycle approach, including (…) carbon sourced through biogenic sources, and, depending on
availability, carbon capture and use (CCU), direct air CO2 capture, as well as CCS”.
The majority of European countries benefits from favourable conditions for CO2 storage5. While the
storage potential is large, Europe still needs to realise projects to meet the predicted demand from
emitters6. The European Commission foresees that 30 projects in preparation will be  able to store
approximately 50 million tonnes per year by 2030 but emphasises that reaching climate neutrality will
require at least six times more CO2 to be stored per year by 20507. At the same time, the European
Commission  proposal for a  Net Zero Industry Act (NZIA)8  sets out an annual CO2  injection capacity
target of 50 million tonnes by 2030, to be achieved through individual contributions from oil and gas
license holders.
Recent developments are encouraging with Denmark9 and the United Kingdom10 recently awarding
their first CO2 storage licenses in the North Sea, including both saline aquifers and depleted oil & gas
fields. The Norwegian Petroleum Directorate has also recently offered two new exploration licenses
for CO2 storage on the Norwegian continental shelf in the southern part of the North Sea a license for
CO2 storage in the North Sea11, adding to the five licenses previously awarded in 2019 and 202212.
Furthermore, the world's first open-source CO2 transport and storage infrastructure, Northern Lights13
is  expected  to  start  operations  in  2024  and  is  being  built  ready  for  expansion  to  accommodate
increasing storage demands. In the Netherlands, the Aramis project14 will allow several CO2 storage
sites to connect to its offshore transport backbone.
Developments  in  CO2  storage  infrastructure  can also be  seen  in regions other than the  North Sea.
Recent project developments in the Mediterranean and the Black Sea lay the ground for significant
offshore storage capacity in the rest of Europe. Furthermore, smaller, but still relevant onshore project
initiatives are evolving and are expected to facilitate CO2 abatement in landlocked regions.
Nevertheless, limited progress in storage development translates into difficulties for capture projects
and vice versa. Notably, identifying storage options has been highlighted as a key hurdle for Innovation
Fund projects.

5  Clean  Air  Task  Force  (2023).  Unlocking  Europe’s  CO2  Storage  Potential:  Analysis  of  Optimal  CO2  Storage  in
Europe.
6 Clean Air Task Force (2022). The gap between carbon storage development and capture demand.
7 Presentations by DG CLIMA regarding the Innovation Fund and the Projects of Common Interest.
8  Proposal  for  a  regulation  of  the  European  Parliament  and  of  the  Council  on  establishing  a  framework  of
measures for strengthening Europe’s net-zero technology products manufacturing ecosystem (Net Zero Industry
Act) (here).
9 Danish Energy Agency (2023). The Ministry of Climate, Energy and Utilities grants Denmark’s first full-scale CO2
storage permits in the Danish North Sea.
10 North Sea Transition Authority (2023). Huge net zero boost as 20 carbon storage licences offered for award.
11  Norwegian  Petroleum  Directorate  (2023).  Award  of  two  new  licences  for  CO2  storage  on  the  Norwegian
continental shelf.
12 Norwegian Petroleum Directorate (2022). Licenses for carbon storage.
13 More information about Northern Lights on the project website.
14 TotalEnergies (2021). Netherlands: TotalEnergies, Shell Netherlands, EBN and Gasunie Form Partnership to
Develop the Offshore Aramis CO2 Transport and Sequestration Project.
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Referring  to  CO2  utilisation,  the  Nova-institute  has  estimated  that  the  global  need  for  embedded
carbon in chemicals and derived materials will increase to 1 Gt per year by 205015. The Nova-institute
further states that sharing, reusing, and recycling will play the main role in keeping carbon in a closed
loop. The report adds that, as it is not possible to keep the entire carbon in a cycle, there is a need for
alternative carbon sources that can be partially covered by CO2. A rigorous and standardised carbon
accounting  methodology  is  a  prerequisite  when  determining  any  technology’s  contribution  to
emission reductions.
The  North  Sea  region  benefits  from  neighbouring  European  industrial  regions  and  ports  such  as
Aberdeenshire, Amsterdam, Antwerp-Bruges, Dunkirk, Le Havre, North Sea Port, Rotterdam, Ruhr, the
UK  East  Coast,  and  Wilhelmshaven.  In  recent  months  there  has  been  a  positive  momentum  for
European CO2 infrastructure projects with several key announcements, including the Wintershall Dea-
Fluxys cooperation agreement on a cross-border CO2 pipeline network connecting southern Germany
and Belgium16, an offshore pipeline ‘heads of agreement’ between Equinor and Wintershall Dea17 to
connect Germany  and  Norway,  a  new  1,000  km  onshore  pipeline  project  by  OGE  in  Germany18  to
connect  industries  to  the  port  of  Wilhelmshaven,  and  ‘heads  of  agreement’  between  Equinor  and
Fluxys to connect Belgium and Norway through an offshore pipeline19.
Developments in international cooperation should also be noted, including the bilateral arrangements
signed between Belgium and  Denmark20  and between Belgium and the Netherlands21  to allow  the
cross-border transport of CO2 for the purpose of permanent geological storage, the memorandum of
understanding  (MoU)  between  Denmark  and  the  United  Kingdom  on  cooperation  in  the  energy
transition, including CCUS22, the joint declaration of intent between Denmark and Germany on CCUS
cooperation23, and the MoU between Norway and Belgium on energy-related cooperation including
CCS24.  These  are  a  key  steppingstone  for  the  development  of  cross-border  projects;  notably,  the
bilateral arrangement between Belgium and Denmark allowed the kickstart of the pilot phase of the
Greensand project25, a clear landmark in CCS projects landscape.

15 Kähler, F., Carus, M., Porc, O. & vom Berg, C. (2021). Turning off the Tap for Fossil Carbon – Future Prospects
for  a  Global  Chemical  and  Derived  Material  Sector  Based  on  Renewable  Carbon.  nova-Institute  (Ed.),  Hürth,
Germany.
16 Wintershall Dea (2023). Wintershall Dea and Fluxys jointly investigate options for transport of CO2.
17 Wintershall Dea (2022). Wintershall Dea and Equinor partner up for large-scale CCS value chain in the North
Sea.
18 OGE (2022). OGE and TES join forces to develop a 1,000 km CO₂ transmission system.
19 Fluxys (2022). Fluxys and Equinor launch solution for large-scale decarbonisation in North-Western Europe.
20 Memorandum of Understanding (MoU) between the Minister for Environment of the Flemish Region and the
Federal Minister for the North Sea of Belgium and the Minister for Climate, Energy and Utilities of Denmark on
Cross border transportation of CO2 with the purpose of permanent geological storage.
21 Memorandum of Understanding (MoU) between the Minister for Environment of the Flemish Region and the
Federal Minister for the North Sea of Belgium and the Minister for Energy and Climate of the Walloon Region
and the Minister of Economic Affairs and Climate Policy of the Netherlands on Cross border transportation of
CO2 with the purpose of permanent geological storage.
22 GOV.UK (2023). Cooperation in the energy transition: UK - Denmark memorandum of understanding.
23 Joint Declaration of Intent between the Federal Ministry for Economic Affairs and Climate Action of the Federal
Republic of Germany and the Ministry of Climate, Energy and Utilities of Denmark on the Cooperation on Carbon
Capture Utilisation and Storage (CCUS).
24 Memorandum of Understanding (MoU) between the Government of the Kingdom of Norway and the Federal
Government of the Kingdom of Belgium on Energy cooperation on the North Sea.
25 INEOS (2023). INEOS led consortium announces breakthrough in carbon capture and storage.
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This momentum will need to be preserved and enhanced through conducive regulatory conditions
and EU and national/multilateral funding programmes. While the industry is ready to deploy at large
scale,  there  is  a  need  to  put  in  place  a  robust,  non-discriminatory,  open-access,  cross-border  CO2
transport and storage infrastructure that enables emitters to connect to sinks, as and where needed.
In addition, the development of full-scale commercial projects will require all parts of the value chain
to be operational which implies that the different components must be developed and implemented
in  tandem  so  that  capture  facilities  can  be  confident  that  transport  and  storage  facilities  will  be
available and vice versa.
A robust CO2 infrastructure network is key to enable the development of low-carbon and competitive
industrial sectors, provide clean flexibility to the energy sector, and allow to unlock early large-scale
volumes  of  low-carbon  hydrogen  and  carbon  dioxide  removals.  This  integration  implies  that  CO2
infrastructure  needs to be developed in parallel and in alignment with the necessary expansion of
hydrogen and renewable energy infrastructure. Ports need to be equipped with means for handling
CO2,  including  CO2  captured  from  exhaust  gases  of  ships  and  need  to  be  integrated  into  the  CO2
infrastructure  to  enable  effective  access  to  storage  sites.  Moreover,  a  CO2  transport  network  can
enable the supply of necessary CO2 raw materials, for example, for the chemicals industry.

1.4 International perspective
The  Communication  on  Sustainable  Carbon  Cycles  published  by  the  European  Commission  in
December  202126  highlights  the  ambition  to  make  the  EU  a  leader  in  innovative  low-carbon
technologies and in CCUS, putting forward several proposals to create an internal market for capture,
use,  and storage  of  CO2, supported by  an open-access and cross-border transport network.  At the
same time, important political developments at the international level are bringing unprecedented
support to CCUS technologies. For instance, in August 2022, President Joe Biden signed the Inflation
Reduction Act27, increasing the already available tax credits (known as 45Q) for CCS and CCU and for
the capture of CO2 via Direct Air Capture (DAC). While this represents a positive signal for the global
development  of  CCUS,  it  should  at  the  same  time  call  on  Europe  to  raise  its  support  to  unlock  its
potential to build industrial, economic, and political leadership in innovative low-carbon technologies
in line with the objective to be the first climate-neutral continent by 2050.

26 Communication from the Commission to the European Parliament and the Council Sustainable Carbon Cycles
(here).
27 Inflation Reduction Act of 2022.
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2.  The structure of the CO2 infrastructure market
2.1 The CO2 Storage Directive
The current legal basis for the storage of CO2 in Europe is the Directive 2009/31 on the Geological
Storage  of  carbon  dioxide  (hereinafter  ‘CO2  Storage  Directive’)28which  includes  provisions  on  site
selection  and  characterisation,  conditions  for  permitting,  as  well  as  monitoring  and  reporting
requirements to verify storage, including remediation obligations in case of leakage. It also includes
some  requirements  on  providing  third-party  access  (TPA)  to  infrastructure.  The  EC  publishes
biannually reports on the implementation of the CO2 Storage Directive29 which highlights progress in
EU Member States.
Experience with storage permit applications in the Member States and at EU level is currently evolving
under the directive and its Guidance Documents. There is a clear consensus that the Directive itself
should not be opened for review, however, some elements of the Guidance Documents could benefit
from an update as highlighted in a recent ZEP report30. Notably, the Guidance Documents are currently
being reviewed by the European Commission, supported by DNV. A first draft version of the updated
Guidance Documents has been made available for stakeholder review31.

2.2 The proposed Net Zero Industry Act
In March 2023, the European Commission put forward a proposal for a 'Net-Zero Industry Act' (NZIA)
aimed  at  expanding  the  manufacturing  capacity  of  net-zero  technologies  in  the  EU.  The  proposal
recognises  CCS  as  a  strategic  net-zero  technology  and  CO2  storage  projects  as  net-zero  strategic
projects, eligible for streamlined permit-granting procedures. In addition, the NZIA sets out an annual
CO2  injection  capacity  target  of  50  million  tonnes  by  2030,  to  be  achieved  through  individual
contributions of authorised oil and gas producers.

2.3 CO2 transport infrastructure is crucial to connect emitters across Europe with storage
Some elements of the CO2 Storage Directive cover CO2 transport and the TEN-E regulation32 focuses
on  CO2  infrastructure  development  in  a  bottom-up  process,  via  the  development  of  projects  of
common interest (PCI). According to the TEN-E regulation, the selection process of cross-border CO₂
PCI  candidates  is  based  on  a  system-wide  harmonised  Cost-Benefit-Analysis  methodology  (CBA)
established by the European Commission33.

28 Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage
of  carbon  dioxide  and  amending  Council  Directive  85/337/EEC,  European  Parliament  and  Council  Directives
2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC, 2008/1/EC and Regulation (EC) No 1013/2006 (Text with
EEA relevance) (here).
29 Reports on the implementation of the CO2 Storage Directive (here).
30 Zero Emissions Platform (2022). Experience in developing CO2 storage under the Directive on the geological
storage of carbon dioxide.
31 More information can be found at the DNV website.
32 Regulation (EU) 2022/869 of the European Parliament and of the Council of 30 May 2022 on guidelines for
trans-European  energy  infrastructure,  amending  Regulations  (EC)  No  715/2009,  (EU)  2019/942  and  (EU)
2019/943 and Directives 2009/73/EC and (EU) 2019/944, and repealing Regulation (EU) No 347/2013 (here).
33 Joint Research Centre (2023). Harmonised system-wide cost-benefit analysis for candidate cross-border
carbon dioxide network projects: After Public Consultation 22 May 2023.
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link to page 19
Rather than fragmented initiatives, there is a need to develop an overarching regulatory framework
for CO2 transport infrastructure with flexibility regarding implementation in Member States (this is
further developed in chapter 4.1.1). The regulatory framework would support the development of a
non-discriminatory, open-access, multimodal CO2 transport network, would establish a clear legal and
regulatory basis for planned projects, in particular for cross-border cooperation, and would enable
coordinated  CO2  infrastructure  planning,  regional  cooperation  and  harmonised  standards  on  the
transport  part  of  the  CCUS  value  chains  (e.g.,  Monitoring  Reporting  and  Verification,  CO2  quality
specifications), in line with the CO2 Storage Directive and the Monitoring and Reporting Regulation.
This is further explored in the complementary report.
As noted above, most large-scale geological storage projects are currently concentrated in the North
Sea, while CO2 emitters are widely spread across Europe, including in hinterland areas far from the
coast, requiring the development of corresponding storage capacity across Europe. Thus, there is a
crucial need for European CO2 transport infrastructure to connect dispersed emitters across Europe
to storage facilities.
While technologies have reached a stage of maturity that allows the value chain to be implemented
and operated, there are remaining challenges that can hinder the scale-up of CCUS to the levels that
are  needed  for  decarbonisation.  The  following  chapters  assess  the  main  technical,  regulatory  and
economic challenges faced by CO2 transport and storage operators and proposes possible solutions.
Importantly, while this report sought to be forward looking, it is important to note that experience is
and will evolve with the ongoing and soon to start projects. These projects will allow the identification
of new challenges/barriers and it is important that the European Commission keeps engaging with
industry  actors  and  leveraging  on  Europe’s  science  and  innovation  expertise  to  create  favourable
conditions for development and operation. Similarly, there is some experience on how to deal with
some  of  the  technical,  regulatory,  and  economic  issues  identified.  The  different  initiatives  and
programmes that are already in place should be reviewed as a way to identify possible learnings and
best practices.

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3.  Technical dimension
This chapter presents the main technical barriers to large-scale deployment, focusing on the transport
and storage components of the value chain. The chapter draws on WG discussions, notably, on the
technical workshop held in February 2023 with the JRC, Fluxys and DNV, as well as on the findings by
the CCUS SET-Plan Implementation Plan work34.

3.1 Transport
CCUS projects, both cross-border and domestic, will rely on different modalities for the transport of
CO2 such as pipelines, rail, ships, barges, and trucks. While most of the CO2 transport is currently done
via pipeline, other transport modalities will become equally important (see boxes 1 and 2 below for
an overview of ongoing work regarding CO2 transportation).
The transport of CO2 in a multi-modal, multi-origin, cross-border, fit-for-purpose and flexible open-
access network will present technical challenges, as it will require handling CO2 streams from different
technologies and  different  sources35.  Although initial transport projects and contracts will likely be
between a given emitter and a specific sink, there is a need for standardisation of CO2 specifications
(gaseous and liquid), taking into account the different technologies and addressing matters such as
composition,  purity,  pressures  and  temperatures,  as  well  as  standards  for  the  design  of  pipelines,
valves,  ships,  and  other  parts  of  the  transport  value  chain  (e.g.,  loading  and  off-loading).  This  will
support  interoperability and interconnections across  Europe,  across  national  borders and different
transport  modalities.  As  highlighted  in  a  recent  report36,  given  the  similarity  between  CO2  phase
behaviour and Liquified Petroleum Gas (LPG), existing standards for transport of LPG by ship can be a
good  starting  point  for  liquified  CO2  and,  potentially,  for  dual  use  shipping.  Global  standards  are
relevant for the application of CCS technologies to the exhaust gases of ships, which need to be able
to unload captured CO2 in ports all over the world.
Developing CO2 transport networks will also involve dealing with complex issues such as liabilities for
transport owners / operators, requiring entry/exit tracing of CO2 sources and composition.
The development of CO2 transport networks must consider connections to small and isolated emitters
which are far away from CCUS/industrial clusters, as they account for a substantial proportion of global
CO2 emissions. As a direct connection to pipeline infrastructure may not be feasible for those emitters,
viable  alternatives  can  involve  transporting  CO2  via  low-pressure  pipelines  (in  case  of  repurposed
pipelines  or  unprocessed  CO2),  truck  or  rail.  While  processing  those  CO2  streams  at  central  hubs
(clusters) is likely to be an economically attractive option for small emitters and for CO2 captured on
board of ships, it also increases the transport challenges due to varying levels of impurities which leads
to more complex phase behaviour of the unprocessed CO2.

Box 1: JRC study on the evolution of a trans-European CO2 transport network

34 CCUS SET-Plan Implementation Plan work (2020/21): Report on key enablers and hurdles impacting on CCUS
deployment with an assessment of current activities to address these issues, and CCUS Roadmap to 2030.
35 Zero Emissions Platform (2020). A Trans-European CO2 Transportation Infrastructure for CCUS: Opportunities
& Challenges.
36 Zero Emissions Platform & Carbon Capture and Storage Association (2022).  Guidance for CO2 transport by
ship.
11

Following a mandate from the European Commission’s Directorate General for Energy (DG ENER),
the Joint Research Centre (JRC) is currently updating its study ‘The evolution of a trans-European
CO2 transport network’. The study, which focuses on EU member states plus CO2 storage options in
the UK and Norway, will map optimal routes linking CO2 sources to stores. By building a European
sources-to-stores map, the study will provide a first indication of the potential routing of pipelines
as well as of the potential volumes required for CO2 transport by other transport modalities.
The report is expected to be published by the end of summer 2023.

Box 2: Developments on CO2 transport by ship
CO2 transport by ship is expected to be an essential component of the European transport network,
with both inland and maritime shipping solutions having been identified by both cross-border and
domestic CCS projects, including candidate projects to PCI/PMI status.
Recognising that further work is needed to describe the scope of CO2 transport by ship in the future
European transport market, the Zero Emissions Platform (ZEP) and the Carbon Capture and Storage
Association (CCSA) set up a working group on CO2 transport by ship which is developing a report to:
•  Investigate the scope and trade routes for CO2 transport by ship and their evolution over
time, based on a European sources-to-stores map.
•  Follow-up  on  interoperability  and  the  work  that  is  being  done  by  the  International
Organization for Standardization (ISO), International Maritime Organization (IMO), and the
Society of International Gas Tanker and Terminal Operators (SIGTTO), and identify potential
elements that are not yet addressed by those organisations.
•  Describe existing barriers to commercialisation and provide recommendations to address
them.
The  aims  to  provide  companies,  regulators,  and  decision-makers  with  greater  certainty  and
facilitate the emergence of the market.  So far, the work has resulted in the following early draft
recommendations:
•  European  countries  that  are  parties  to  the  London  Protocol  to  deposit  a  notice  to
provisionally  apply  the  CO2  export  amendment  with  the  International  Maritime
Organization (IMO) to enable cross-border CCS projects in Europe.
•  Standardisation of ship-shore interface by the appropriate shipping organisation (SIGTTO),
to  enable  compatibility,  destination  optionality  and  ultimately  increase  market
competition.
•  Standardisation  of  CO2  specifications  for  shipping,  liquefaction,  and  onshore  storage  to
ensure compatibility and consistency between CCS projects  (see  complementary report).
Acceleration  of  the  cross-border  CO2  shipping  transportation  regulatory  framework,
including  UK/EU/European  Economic  Area.  Besides  the  ratification  of  the  article  6
amendment  to  the  London  Protocol,  progress  could  be  achieved  through  country-to-
country  agreements  and  through  mutual  recognition  and  mechanisms  for  credits  and
liability transfer between the EU and UK ETS systems.
•  Create  the  right  business  environment  enabling  multiple  international  CO2  shipping
providers to invest and offer services on a competitive basis.
12

•  Develop effective safety and environmental footprint performance in early phases of CCS
and CO2 shipping as a pre-condition to License to Operate.
The report is expected to be published in autumn 2023.

3.2 Storage
This  section  describes  current  challenges
regarding  CO2  storage,  focusing  in  particular
on:
•  The types of storage
•  The potential for CO2 storage in Europe
•  The stages of a typical CO2 geological
storage project

3.2.1  Types of storage
A number of CO2 storage options exist37, such
as  storage  in  on-  and  offshore  geological
formations deep underground (including oil &
Figure 1 - Countries where CO2 storage is permitted and
prohibited. Source: CO2GeoNet (2021). State-of-play on CO2
gas  fields  and  saline  formations).  When
geological storage in 32 European countries — an update. Note:
describing  storage  solutions,  mineralisation
since the publication of the report, Denmark has changed its
law, permitting storage.
should also be mentioned.
These options may operate under different timescales, present different characteristics, risk profiles,
availability and implications for regulatory frameworks. It is important that these implications are duly
considered,  and  that  the  regulatory  approaches  taken  are  in  synergy  with  relevant  EU  pieces  of
legislation.
Deep  saline  formations or  saline  aquifers  are  expected  to offer  the  largest  CO2  storage  capacity38.
These options are being explored in the North Sea, where Sleipner, Snøhvit, Longship, the UK East
Coast Cluster and ACORN are either storing or planning to store CO2 in saline aquifers.
Depleted oil & gas fields, especially in the North Sea have been and are being appraised by oil & gas
operators and can be viable solutions to store large quantities of CO2. Offshore storage is particularly
suitable for countries where onshore storage is banned or may encounter public acceptance issues
with onshore storage. In many European countries, mainly in the central, eastern, and south-eastern
part of the continent, depleted and nearly depleted onshore oil & gas fields can offer early CO2 storage
solutions.  The  potential  use  of  existing  wells  and  surface  facilities  also  presents  cost  saving
opportunities for storage developers but can also raise issues related to the age of these facilities.

3.2.2  The potential for CO2 storage in Europe, site appraisal and characterisation

37  For  an  overview  of  types  of  CO2  storage  resources,  see  International  Energy  Agency  (2022).  CO2  storage
resources and their development: An IEA CCUS Handbook.
38 Global CCS Institute (2022). Global Status of CCS 2022.
13

While there is no lack of potential  for CO2  storage in Europe,  significant investments decisions are
needed  to  transform  this  potential  into  marketable  storage  capacity.  At  the  technical  level,  this
involves  supporting  prospective  storage  promoters  to  swiftly  identify  suitable  storage  sites.
Experience indicates that pre-competitive, publicly available, storage appraisal supports and increases
the rate of the development of storage projects. Publication of a European Storage Atlas, providing
detailed information on storage opportunities, will greatly support storage development. This can be
supported by national initiatives, such as the storage atlas published by the UK and Norway.
The  limited  access  to  information  has  also  been  highlighted  as  a  key  barrier  in  site  appraisal  and
characterisation. Thus, there is a need for competent authorities to outline a reliable pathway that
enables the future storage operator to access non-confidential information and raw geological data
required to undertake site appraisal activities (e.g., re-use of wells, well maintenance records, annulus
pressure data, etc.).
While it is outside the scope of this work to identify a single best option to access crucial information
for site appraisal, it is noted that this would benefit the development of storage sites in Europe and
should be an integral part of a European Storage Atlas39, to support investment decisions. The CO2StoP
database40 provides pan-European coverage of CO2 storage potential; however, as highlighted by a
recent CO2GeoNet report41, new storage assessments and new data have become available in at least
25 European countries since preparation of the database and an updated and maintained European
Storage Atlas would enable CCS project developers to identify storage resources for further appraisal
and prepare for the development of larger storage capacities42.
It is also noted that there are existing classifications systems aiming at reporting CO2 storage resources
and to understand the remaining actions that are required to advance from storage potential to stored
CO2.  For  example,  the  SPE  SRMS43   is  a  two-axis  system  (resource  uncertainty  and  commerciality)
following the approach taken by the oil and gas industry while the UNECE UNFC44  is a more complex
three  axis  system  (economic  and  social  viability,  field  project  status  and  feasibility,  and  geological
knowledge) applicable to all sorts of resources. Those classification approaches can be considered in
the development of a European Storage Atlas.

3.2.3  The stages of a typical CO2 geological storage project
Geological storage development is a prerequisite of the CCS value chain and is on average more time
consuming than developing CO2 capture. A geological storage project may take anywhere between 4
to 15 years to mature, involving many steps between inception and the start of injection, including
the identification of storage resources, exploration and appraisal, licensing, signing up of emitters, and

39  The  ‘Storage  Atlas’  concept  is  further  developed  in  the  CCUS  SET-Plan  Implementation  Plan  work  (2022):
Recommendations on the steps to establish a R&I Activity 4 European Storage Atlas.
40 More information and maps with geological data can be accessed here.
41 CO2GeoNet (2021). State-of-play on CO2 geological storage in 32 European countries - an update.
42 For more information on storage appraisal, see: Unlocking European CO2 storage capacity: recommendations
on  the  steps  required  to  deliver  target  7  of  the  SET  Plan’s  Implementation  Working  Group  on  CCS  and  CCU
(2022).
43 CO2 Storage Resources Management System. Available here.
44 More information about the UNFC system and UNFC documents available here.
14

securing transport connections45. Moreover, it is important to take into account site closure, including
a clear understanding of regulatory and financial barriers and liabilities including after closure of site
(stemming from the CO2 Storage Directive and its Guidance Documents).
Building technical capacity and expertise within governments and competent authorities is crucial to
streamline the licensing process and to the operationalisation of storage sites.

Figure 2 - The stages of a CO2 storage project. * Post-closure timeframes are jurisdictionally dependent and range from
being unspecified to being over 50 years. Notes: FEED = front-end engineering design; SRMS = Storage Resource
Management System. Assessment and development activities carry exploration risk and assessed resources may be defined
as undevelopable or not commercially viable. Investment needs are relative to overall costs. Source: IEA (2022). CO2 storage
resources and their development: An IEA CCUS Handbook. Note: the figure, as shown here, depicts only part of the original
figure in the IEA report.

45 For an overview of the regulatory landscape on CO2 storage, see: Zero Emissions Platform (2022). Experience
in developing CO2 storage under the Directive on the geological storage of carbon dioxide.
15

4.  Regulatory dimension
This chapter focuses on the regulatory dimension, drawing on WG discussions, notably the regulatory
workshop held in January 2023 with presentations from ENTSO-G and the Energy Transition Expertise
Centre (EnTEC). The main conclusions and recommendations of the EnTEC study on the regulatory
environment for CO2 transport and storage infrastructure are presented in Box 3 below.
A stable policy and regulatory framework is key for the large-scale development of CCS and CCU within
this decade. While industry is ready to deploy, the political support for the technology has not always
been sufficient, leading to uncertainty and delays.
Box 3: EnTEC conclusions on a regulatory framework for CO2 transport and storage infrastructure
The European Commission has commissioned a study from the Energy Transition Expertise Centre
(EnTEC)46 to analyse options for a regulatory framework supporting the development of the CO2
transport  and  storage  infrastructure  as  well  as  business  models47.  Notably,  the  study  finds  that
emitters, despite being ready to invest in CCS, face uncertainties about the transport and storage
possibilities. At the same time, transport and storage operators hold back on investing in future
infrastructure capacity. The following key recommendations are presented, based on the identified
challenges:
•  Ensure adequate and future-proof capacity for transport and storage (T&S) infrastructure
to allow access for all interested emitters.
•  Support early development of large stores.
•  Provide further regulatory guidance on CO2 transport and CO2 certification at EU-level to
ensure harmonisation.
•  Decouple the T&S network from emitters to ease contract development.
•  Planning and developing infrastructure with a European Vision.
•  National governments play a key role in streamlining project development.
•  Support  emitters  that  are  located  at  large  distances  from  storage  hubs  currently  in
development.

To support the development of CO2 networks in an environmentally safe and secure manner, a best-
available-technology approach (relevant to the risks associated with CO2) is required (regulated by the
Paris  Agreement  and  the  UNFCCC).  Moreover,  contracts  between  emitters,  transport  owners  and
operators, and storage and utilisation operators need to ensure a proper allocation of liabilities across
the CO2 value chain as well as tracking of CO2 volumes.
The level of regulation will depend on the market, its maturity and size and may change over time
while the network is developing. Developing a CO₂ network could be possible under different levels of
regulatory  intensity, reflecting the local/regional conditions.  However, to prevent  fragmentation,  a
minimum set of regulatory principles for CO2 transport infrastructure such as transparent and non-
discriminatory open access, should be established in the EU to provide Member States with a baseline

46 Energy Transition Expertise Centre
47 European Commission, Directorate-General for Energy, Bolscher, H., Guevara Opinska, L., Finesso, A. et al.,
(2023). EU regulation for the development of the market for CO2 transport and storage.
16

to  build  on,  while  securing  equal  access  and  transparent  cross-border  transportation  in  order  to
support the internal market structure.
The first question to ask is if there would be a natural monopoly or not. For a pipeline network this
would  likely  be  the  case,  depending  on  competition  from  other  transport  modalities.  The  second
question is if the monopoly would need to be regulated – for example with a regulated tariff and third-
party access terms. Where tariffs for onshore pipelines are regulated at national levels, EU regulation
should establish a common framework – like for natural gas. Ship or truck transportation could be
fully commercial business depending on the local circumstances.
If the future CO₂ pipeline network would be regulated, there are two main options for open access
and openly published procedures:
•  nTPA - where the conditions are specifically determined by the infrastructure operators
•  rTPA  -  where  the  conditions  are  determined  by  the  National  Regulatory  Authority  (if
applicable, also for tariffs based on regulated revenues).
Different regulatory approaches can co-exist in the EU, reflecting the local/regional conditions. Gas
Transmission System Operators (TSOs) are open to all options supporting CCS/CCU and CO₂ pipeline
transport developments. As infrastructure operators, TSOs can enable the green transition, are fit to
transport CO2, and can take advantage of existing gas pipelines for CO₂ transport (not excluding build-
up of new pipelines in duly justified cases).
Multiple storage sites are being developed across Europe and these will per definition compete with
each other. The basis for competition on CO2 storage is a Europe-wide market that is unbundled from
the transport infrastructure. Consequently, access to storage should be based on  publicly available
tariffs  from  different  storage  operators  in  order  to  ensure  the  development  of  a  competitive  and
efficient  Europe-wide  CO2  storage  market.  Offshore  CO2  pipelines  should    be  compared  with
‘upstream  pipeline  networks’  in  the  natural  gas market  and  a  EU  regulatory  framework  should  be
comparably ‘light touch’(with transparent, non-discriminatory access terms being in place.
Cross-border  transport  of  CO2  for  offshore  storage  is  regulated  under  the  London  Protocol  of  the
International Maritime Organisation (IMO), namely, Article 6. Since 2019, a provisional solution (i.e.,
pending  entry  into  force  of  the  2009  amendment  to  Article  6)  allows  CO2  export  for  sub-seabed
storage for countries that enter into bilateral IMO agreements. In the European Economic Area (EEA),
a simplified process may apply, according to a recent analysis paper48 published by DG CLIMA. Under
this process, a notification to the IMO would be sufficient for the export of CO2 for sub-seabed storage.
However, the legal status and implications of the analysis paper, and which aspects that can still be
dealt with via bilateral treaties in the EEA, must be clarified. Furthermore, incentives to ratify the 2009
amendment must be maintained, allowing its entry into force and enable CO2 cross-border flows for
offshore storage, also connecting countries outside of the EEA.
Legal frameworks should enable the development of a competitive and efficient Europe-wide market,
by enabling access to storage opportunities across the EU, its EEA partners and the UK. As an example,
the  UK  part  of  the  North  Sea  has  a  large  potential  for  CO2  storage  that  can  be  an  alternative
competitive option for emitters in the EEA. In this context, the recognition of CO2 exported to the UK
for permanent storage under the EU ETS system (and vice versa) would facilitate CO2 flows between

48 Commission services analysis paper for the Information Exchange Group (IEG) under Directive 2009/31/EC.
Available here.
17

the  EU  and  the  UK  and  unlock  access  to  competitive  storage  options  for  emitters.  The  above-
mentioned analysis paper maintains that the exception to surrendering emission allowances does not
apply to EU ETS installations that export CO2 for storage outside the EEA (e.g., the UK). Such a legal
landscape could effectively create an obstacle to the development of a wider (European) market for
CO2 transport and storage and should be carefully assessed and further clarified.

4.1 Transport
4.1.1  A regulatory framework for CO2 transport infrastructure
As stated in previous chapters, the European Commission should develop a regulatory framework for
CO2  transport  infrastructure,  focused  on  the  development  of  non-discriminatory,  open  access  and
multi-modal  CO2  transport  infrastructure  with  flexibility  for  the  member  states  to  adopt  further
regulation  to  accommodate  national  market  developments  and  ownership  models49.  Such  a
regulatory  framework  would  complement  the  CO2  Storage  Directive  and  establish  a  legal  and
regulatory  basis  for  all  planned  projects,  domestic  and  cross-border.  This  is  essential  to  provide  a
degree of predictability for long-term investments.
A regulatory framework should include the following elements:
•  CO2 infrastructure network operator
Deployment of new CO2 transport corridors and networks would benefit from integrated planning
and consultation processes, in a similar way to those  established for the gas, electricity  sectors
(ENTOS-E and ENTSO-G) and to be established for the hydrogen sector based on the final outcome
of  the  Hydrogen  and  Decarbonised  Gas  Package.  An  equivalent  entity  for  CO2  –  incorporating
emitters, transport providers and utilisation and storage operators and with a mandate to consider
value-chain regulatory issues and make recommendations to the European Commission – would
enable  coordinated  CO2  infrastructure  planning,  network  design,  and  facilitate  cross-border
cooperation, thereby supporting the deployment of new CO2 networks. As an existing example,
ENTSOG has shown long term experience in planning and  preparation of network codes for gas
transportation, and possible synergies should be investigated.  This entity could address regulatory
and permitting barriers and promote relevant standardisation across the value chain, including on
CO2 quality specifications and shipping of CO2.
•  The CCUS Forum as an EU regulatory and stakeholder forum for CO2 networks
The CCUS Forum can act as the body to take stock of the experience developed under a regulatory
framework, in a similar approach to that of the Madrid Forum for Gas and the Florence Forum for
Electricity.  A  joint  approach  to  developing  Forum  Conclusions  can  be  helpful  in  achieving
transparent  alignment  on  the  work  programme.  The  Forum  would  be  well  placed  to  provide
recommendations  to  national  and  European  policy  makers,  supporting  progress  on  specific
regulatory / policy challenges.
•  Integrated network planning

49 Zero Emissions Platform (2021). ZEP proposal for a regulatory framework for CO2 transport infrastructure

18

An important element under the Hydrogen and Gas Decarbonisation Package proposals is fostering
integrated network planning and interaction between the electricity, gas and hydrogen sectors, in
order to promote flexibility and resilience in the EU energy system. Work to integrate the role and
scope of CO2 transport infrastructure into energy network development planning, such as the 10-
year network development plans (TYNDP), could be undertaken as part of a regulatory framework
for CO2 transport infrastructure. This scope could cover both localised CO2 grids (e.g., in coastal
areas / ports) and cross-border / regional CO2 backbone infrastructure.
As established by the TEN-E, network planning shall involve a participatory approach, whereby all
relevant stakeholders, including CO2 infrastructure stakeholders and civil society organisations, are
invited to provide input through consultation.
•  Regional cooperation
A  regional  approach  for  discussions  around  CO2  infrastructure  could  trigger  more  efficient
infrastructure cooperation and deployment, with a particular focus on integration between cross-
border CCUS systems. This could be facilitated by the European Commission and policy makers in
Europe, either under the CCUS Forum or as part of any new platform for  CO2 infrastructure, as
included in the TEN-E regulation.
Planning  and  investment  in  infrastructure  can  be  supported  by  regional  development
organisations, functioning as market makers, sitting between industrial CO2 sources and CO2 users
and stores. Such organisations would coordinate development and take responsibility for risks50.
•  Public perception and acceptability
The development and construction of new, large and costly infrastructure often faces challenges
regarding public acceptance. Mechanisms and best practices for inviting public consultation and
integrating  feedback  into  CO2  transport  infrastructure  planning,  including  the  development  of
guidance  on public  engagement  and support  for new and repurposed infrastructure,  will be  an
important element of the broader policy framework and must be integrated into the scope of the
CO2 infrastructure network operator.
•  Flexibility of approach
Experience in CCUS is evolving, with potential for innovation to drive efficiency, cost reductions
and enhance integration. For this reason, regulatory flexibility – while prioritising environmental
integrity – must be preserved, such that CO2 infrastructure providers and operators are not faced
with unnecessary complexity, investment gaps not covered by users or public policy, and costs that
are detrimental to efficient project implementation. The regulatory sandbox approach under the
Innovation Fund could serve as a testing ground for approaches that could then be supported more
broadly under the regulatory framework for CO2 transport infrastructure.
Moreover, it is important to ensure that an EU regulatory framework for CO2 transport does not
create  barriers  for  projects  that  were  initiated  under  a  different  legislative  setting.  Regulatory
sandboxes – can also play an important role to encourage research and development. Costs for

50 Bellona Europa (2016). Manufacturing Our Future: Industries, European Regions, and Climate Action.
19

this would be taken into account by the National Regulatory Authority as necessary infrastructure
investment.
Regulatory  support  schemes  could  be  envisaged  also  to  cover  the  residual  investment  gap  for
operators  and pipeline owners  not  covered by (initial) CO₂ users (e.g.,  via CO₂-connected funds
facilities, like ETS allowance funds). Flexibility at Member State level might be required to address
the  funding  gap  (not  restricted  to  public  funding  schemes  –  like  ETS  allowance  funds  or  other
supporting mechanisms – like CCfDs or CfDs).
•  Supporting delivery of Trans-European Network provisions on CO2 infrastructure and NECPs
Recent integration of CO2 storage into the TEN-E Regulation and incorporation of CCUS in National
Energy  and  Climate  Plans  (NECPs)  has  helped  to  better  support  the  role  of  CCUS  in  achieving
decarbonisation targets in Member States and at the EU level. The Hydrogen and Decarbonised
Gas  Market  Package  contains  provisions  to  assist  Member  States  with  implementation  of  the
hydrogen provisions of TEN-E, as well as supporting delivery of the hydrogen components of the
NECPs. Since CO2 infrastructure is a part of the revised TEN-E regulation as well as a number of
NECPs,  a  similar  link  should  be  established  between  the  regulatory  framework  for  CO2
infrastructure  and  achieving  the  CCUS  elements  of  the  new  TEN-E/  NECPs,  in  order  to  support
successful delivery.
•  Facilitating sharing of best practices at EU level
The  cross-border  transport  of  CO2  and  the  coordination  of  CO2  streams  from  different  sources
brings about technical challenges. Facilitating the sharing of best practices at EU level is needed to
address  existing  differences  in  technical  requirements  with  regards  to  the  construction  and
characteristics of pipelines for cross-border pipeline projects.

4.1.2  Multi-modality
CO2 infrastructure projects require that all existing legislation – such as the TEN-E regulation, TEN-T
Regulation and EU  ETS Directive  –  have  an adequate extended scope to prepare  for the  rollout of
large-scale, shared CO2 infrastructure. The EU Taxonomy recognises all modes of CO2 transportation
– pipeline, ship, barge, rail, truck. This outcome is critical and should be preserved and reflected in all
revised relevant legislation, as it will allow near-ready CO2 transport and storage projects to be realised
and to create opportunities for numerous CO2 emitters throughout the EU/EEA area to have access to
low-cost decarbonisation pathways.

4.1.3  Standards/network codes
Developing a common understanding of specifications for CO2 transport is crucial to ensure that the
CO2 transport network is safe, cost-efficient, interoperable, and accessible to industrial emitters of
different sizes. The development of standards would thus complement the regulatory framework for
the transport of CO2.
20

link to page 10
Point-to-point connections, where large emitters are directly connected with sinks, can define their
own  specifications  regarding  the  characteristics  of  the  transported  CO2  (pressure,  temperature,
impurities, etc.).
Developing an open-access multimodal European transport network, on the other hand, requires an
agreed international network code that specifies CO2 characteristics for the different transport modes.
Requirements related to permanent storage must be considered if they exceed the requirements of
the  transport  infrastructure  (for  instance,  regarding allowable  impurities).  The specification of  CO2
characteristics  should  provide  the  lowest  possible  costs,  taking  into  account  the  entire  chain  from
capture to storage as well as different CO2 applications.  Specifications should be based on verified
knowledge  and  must  be  stricter  when  scientifical  evidence  cannot  provide  sufficiently  accurate
answers to ensure safety.
With this in mind, the European Commission has set up an expert group on CO2 specifications in early
2023 to complement the work of the CCUS Forum working group on CO2 infrastructure and provide
clear recommendations on specifications for CO2 transport. Recognising that existing standardisation
bodies  like  the  International  Organization  for  Standardization  (ISO)  are  well  placed  to  establish
standards, the objective of the expert group was to:
•  provide  clear  recommendations  on  specifications  for  CO2  transport,  focusing  on  CO2
composition, pressure, purity and temperature;
•  summarise the knowledge base on which stakeholders can base their convergence efforts for
a network code;
•  identify potential knowledge gaps and recommend research efforts, leveraging on previous
work51.
The recommendations and findings of the expert group can be found in the complementary report of
the CCUS Forum expert group on CO2 specifications.

4.2 Storage
As noted in chapter 2.2, the European Commission’s proposal for a NZIA introduces an annual CO2
injection capacity target of 50 million tonnes by 2030. While this is crucial to the development of CO2
storage capacity in Europe, there is a strong consensus that the NZIA should be carefully amended to
ensure that the storage injection capacity objective can be achieved. This for instance means, first of
all, adopting a value chain approach so as to ensure that the CO2 capture and transport infrastructure
are developed in parallel with storage to avoid the so-called ‘chicken and egg’ challenge. This would
mean including CO2 transport and considering CO2 capture and transport in addition to CO2 storage as
net zero strategic projects with facilitated provisions regarding infrastructure planning and permitting.
In  addition,  the  development  of  the  CCS  market  in  Europe  would  benefit  from  further  long-term
predictability, going into the post-2030 period, the NZIA could help to facilitate this by including the
possibility to set new CO2 injection capacity targets for the period post-2030. This should be done in

51  See,  for  example,  IOGP  (2022).  Gap  analysis  of  standards  and  guides  for  carbon  capture,  transport,  and
storage.
21

link to page 14
close  consultation  with  stakeholders  and  building  on  the  findings  of  the  impact  evaluation  of  the
initiative.
As described in chapter 3.2 above, different types of on- and offshore storage sites exist and their
different characteristics, risk profiles, and availability must be duly considered under the regulatory
framework.
Regulatory  challenges  related  to  storage  concern  both  EU  and  national  legal  frameworks.  The
following  paragraphs  describe  the  challenges  that  have  been  identified  and  reflect  the  evidence
gathered in a recent ZEP report52.
Permitting processes tend to be quite lengthy and complex in most EU member states, usually taking
between 18 months and 2 years (compared to 6 to 9 months in the UK). Besides providing guidelines
to  speed  up  permitting  –  while  maintaining  environmental  safeguards  –  the  EU  can  improve  the
current permitting procedures by striving to provide a timely opinion for  Member States’ licensing
decisions.
In  addition,  there  should  be  an  increased  number  of  regular  permitting  and  licensing  rounds  in
Member States to increase the potential for storage site development and support the achievement
of the CO2 injection capacity objective set out in the NZIA.
More guidance is also needed on the transfer from oil & gas operations to CO2 storage operations in
hydrocarbon  fields.  There  might  be  an  incompatibility  between  operators’  preference  for  rapid
removal of an oil and gas platform, due to high maintenance costs and/or regulatory requirements,
on  the  one  hand,  and the  desire  to  adapt  multiple  platforms,  pipelines,  and wells  for  CO2  storage
service in an orderly manner, on the other. Notably, guidance is needed on transfer of liabilities as
well  as  on  the  role  of  the  different  stakeholders  –  competent  authorities,  owners,  and  future
developers – during the transfer process.
There  is  also  a  need  for  clarity  about  converting  producing  hydrocarbon  fields  to  CO2  storage
reservoirs. While early CO2 storage projects in (offshore) depleted hydrocarbon fields start injection
after the end of oil or gas production, there may be advantages in merging the tail end of hydrocarbon
production with the first phase of CO2 injection in cases where this is an option (not including EHR).
For  access  to  new  geological  CO2  storage  capacity,  it  could  be  helpful  to  assess  the  synergies  and
potential  mutual  relevance  of  the  EU  Hydrocarbons  Licensing  Directive53  and  the  CO2  Storage
Directive, supporting access to information and site characterisation, and provide clarity regarding the
risk allocation between the oil & gas and storage operators.
Early engagement between competent authorities and project promoters is needed to provide clarity
(e.g.,  on  the  required  level  of  detail  in  the  interim  documents/plans,  including  the  criteria  for  the
demonstration of permanent storage which should be agreed with operators on a case-by-case basis)
and guidance where needed, avoiding misunderstandings and delays. Moreover, ongoing interactions
and discussions between project operators and competent authorities have been identified as critical
to the success of CCS projects.

52 Zero Emissions Platform (2022). Experience in developing CO2 storage under the Directive on the geological
storage of carbon dioxide.
53  Directive  94/22/EC  of  the  European  Parliament  and  of  the  Council  of  30  May  1994  on  the  conditions  for
granting and using authorizations for the prospection, exploration and production of  hydrocarbons. Available
here.
22

Financial  securities  for  storage  sites  can  vary  considerably  depending  on  the  interpretation  of
regulations and can be particularly prohibitive for smaller operators. It is crucial to assess how private
investors and governments could share long-term CO2 storage risks. A number of countries (e.g., the
UK  and  Norway  with  the  Longship  project)  have  developed  options  that  enable  risk-sharing  and
transfer of liabilities between storage developers and regulatory authorities. Possible avenues that
could be pursued include national funds for pooled liabilities for storage resources, international funds
for cross-border transport liabilities, creating a post-closure company, and insurance systems, based
on a robust and independent review of risks.
The  ongoing  review  of  the  CO2  Storage  Directive  Guidance  Documents  provides  an  opportunity  to
address these issues and challenges. Moreover, there is an opportunity to share learnings and identify
best practices from licensing procedures that have already been conducted. Building knowledge and
capacity within competent authorities will also be crucial to streamline project development.

23

5.  Commercial models and considerations on funding mechanisms
This chapter draws on the discussions held in a workshop dedicated to business models and funding
frameworks,  held  in  February  2023,  with  presentations  from  the  Netherlands  and  IOGP  Europe
framing those discussions.

5.1 Commercial models
CCUS  value  chains  typically  include  multiple  separate  business  entities  such  as  industry  emitting,
capturing and processing CO2, infrastructure operators transporting CO2 (whether through pipelines
or by other modes), operators managing interim storage (e.g., ports), entities aggregating CO2 flows
from multiple emitters, CO2 storage operators and CO2 users. Successful deployment of CCUS at scale
will depend on the ability to put in place commercial solutions that balance risks and rewards along
the full value chain, underpinning and de-risking the needed investments.
When developing commercial models and de-risking measures, there are two key commercial risks
that  should  be  carefully  considered:  price  risks  and  volume  risks.  These  risks  are  explored  in  the
subsequent sub-chapters.

5.1.1  Price (variation) risks
For  CO2  emitters,  the  value  of  capturing,  transporting,  and  storing  CO2  largely  depends  on  the
alternative cost of emitting CO2. The costs of emitting CO2 have historically been relatively low (aided
by  free  allocation  of  EU  ETS  allowances),  thus  not  driving  sufficient  investment  in  CO2  capture.
However,  prices  have  increased  and  become  more  volatile  over  the  past  years.  De-risking  the
investment in CO2 capture suggests the need for business models which can guarantee stable revenue
streams  over  longer  time  periods,  e.g.,  a  possibility  for  emitters  to  enter  carbon  contracts  for
difference  (CCfD)  with  an  entity  which  can  assume  the  corresponding  price  risk  and  guarantee
investors stable returns on their investments. Such entity could be at Member State or EU level.
Similarly,  companies  transporting  and/or  storing  CO2  typically  require  some  form  of  long-term
commitment  to  guarantee  their  revenues  and  thus  be  able  to  invest  in  the  corresponding
infrastructure. Since long-term agreements can be commercially difficult to achieve, there is as in any
market,  an  interest  for  and  from  aggregating  stakeholders  –  that  takes  on  risk  by  entering  into  a
contract with the transport or storage operators on behalf of CO2 from emitters – to engage.

5.1.2  Volume (certainty) risks
CO2  emitters  that  wish  to  invest  in  CO2  capture  and  linked  processing  facilities  will  likely  require
certainty over the possibility to dispose of the captured CO2 over the lifetime of the emitting asset.
The emitters may, at the same time, not possess the certainty to guarantee the supply of captured
CO2 over a period longer than a few years, due to circumstances outside of their own control. This
may  result  in  a  mismatch,  where  emitters  are  only able  to  commit  for  shorter  periods  than  those
required  by  investors  in  transport  and  storage  infrastructure.  Entities  in  the  value  chain  (e.g.,  an
aggregator)  that  are  exposed  to  this  mismatch  risk  may  find  the  need  to  establish  de-risking
mechanisms with external bodies before concluding commercial agreements with emitters, transport
companies and/or storage operators.
24

These de-risking mechanisms can be set up in many different ways, where the default option is to let
each  component  of  the  value  chain  develop  a  market-based  hub/pool/exchange  to  connect  and
secure demand and supply. One other option – similar to the EU Energy Platform – includes the role
for a fit-for-purpose regulated entity to take on the main commercial risks and be in charge of de-
risking  individual  businesses:  contracting  CO2  emitters  to  create  demand,  transport  companies  to
underpin their investments, and storage operators thereby underpinning their investments.

5.2 Funding mechanisms
Funding mechanisms need to address the different commercial risks along the value chain and over
the projects’ lifetime. There are already several existing EU funding mechanisms that can contribute
to the development of a European CO2 transport and storage infrastructure network54. It is crucial that
these funding mechanisms – and additional funding and de-risking mechanisms yet to be established
–  are  coherent  and  coordinated  both  across  funds  and  between  the  EU  and  national  levels,  for
targeted and efficient deployment55.

5.2.1  Existing funding mechanisms
The  EU  ETS  Innovation  Fund  is  the  most  relevant  EU  funding  programme  for  CO2  infrastructure
projects, with many such projects already being funded through both its small- and large-scale calls.
The Connecting Europe Facility (CEF) is also a key EU funding instrument supporting the development
of cross-border energy and transport infrastructure projects. The TEN-E regulation and CEF funding
has already proved  instrumental  in financing pioneer midstream CO2  transport infrastructure (e.g.,
terminals in Antwerp, Ghent, part of Northern Lights). In addition, Horizon Europe provides funding
for technologies at an early stage of development, including specific calls for CO2 transport and storage
demonstration projects, specific CCS and CCU industrial applications, and DACCS and BECCS56.
While the Innovation Fund can fund CCS and CCU projects through its general call topics, investors in
these technologies would benefit from separate funding windows. This would simplify the application
process  and  avoid  timing  issues  when  establishing  back-to-back  contractual  rights  and  obligations
between the different actors in the value chain. Introducing the possibility of sequenced funding for
CCS projects should also be considered to address ‘chicken and egg’ challenges – i.e., to enable the
development of CO2 transport and storage infrastructure so this can be ready for usage by CO2 capture
projects. This upfront investment can protect large-scale investments in CO2 capture projects, as also
noted by the EnTEC study mentioned earlier in the report.
The  description  of  innovation,  as  an  eligibility  criterion,  could  also  be  broadened  to  recognise
innovation beyond the technology itself, by considering the application of technologies to different
sectors, commercial / value chains and regions.
Given the critical need for CO2 storage and the experience collected from Innovation Fund calls, the
European Commission should assess other funding possibilities for infrastructure projects, particularly

54 Bellona Europa (2018). An industry's guide to climate action.
55  The  Just  Transition  Platform,  managed  by  DG  REGIO,  which  includes  working  groups  relevant  to  CO2
infrastructure,  can provide a good basis for such coordination. More information about  the Platform can be
found here.
56 The Horizon Europe Work Programme 2023-2024 can be consulted here.
25

during this year’s mid-term review of the Multi Financial Framework and the future preparation of the
post  2027  EU  funding  programmes.  Other  funding  programmes,  such  as  the  LIFE  Programme,  the
Modernisation  Funds,  regional  ERDF  Programmes  and  Next  Generation  EU  Funds  (distributed  by
Member States’ Recovery and Resilience Plans), should also enable the possibility to fund CCS and
CCU projects.
There can also be lessons to be learned from successful funding mechanisms for other low-carbon
technologies.  Examples  include  the  Hydrogen  Bank  and  the  new  competitive  bidding  mechanisms
included in the Innovation Fund. The evaluation of those initiatives and learnings could prove useful
in establishing the suitability of supporting CCS and CCU projects through equivalent mechanisms.
At the same time, it is important to recognise that Member States will have a very important role to
play in supporting CCS and CCU projects through their own support schemes, where also CCfD models
can be explored. Coordination between national and EU level support schemes is crucial and can be
addressed through EU legislation in order to make the most of potential synergies.

5.2.2  Additional funding /de-risking mechanisms
De-risking  long  term  revenue  streams  for  investors  along  the  CCUS  value  chain  beyond  the  initial
projects  phase  and  thus  supporting  a  fast  scale  up  requires  measures  which  address  both  price
(variation)  risk  and  volume  (certainty)  risks.  Tools  that  can  successfully  achieve  this  include  CCfDs,
private-public partnerships, blended financing schemes and project development assistance funding.

5.2.3  Liability risks
CO2 and related liabilities need to be clearly defined and clarified across the different entities along
the  value  chain.  In particular,  it must  be ensured that  liabilities are  transferred  once  CO2  injection
operations  cease.  Uncertainty  on  liabilities  can  create  commercial  risks  and  consequently  increase
costs to investors. Referring to the CO2, liabilities and allowances under the EU ETS must all be aligned,
including, where appropriate, the development of optimised or new financial security instruments.

5.2.4  Other funding considerations
The  European  Commission  should  support  cross-border  transport  of  CO2  to  enable  access  from
emitters in one country to storage sites in another, thereby supporting the fast scaling up of CCUS
value  chains.  Hurdles  associated  with  multi-country  funding  and/or  state  aid  guidelines  should  be
reviewed and adjusted to allow and facilitate the creation of cross-border value chains.
Support learnings from initial projects, for example, by providing incentives for the funding of first-
generation infrastructure projects to develop targeted research on open questions so as to support
the economics and environmental benefits of next generation infrastructure.
The  development  of  business  models  and  potential  tariffs  should  reflect  the  different  risks  and
conditions along the CCUS value chain. For instance, in the case of remote sites it will be important to
ensure that the decarbonisation remains possible at an affordable cost for emitters.
26

Experience developed with financing tools outside of Europe (e.g., the US 45Q) can also provide
important insights that can feed into the development of financing mechanisms in Europe.

27

6.  Guidance for Governments and NECP revision
The most recent Guidance57 published by the European Commission in December 2022 provides clear
guidance for Members States to include capture, transport and storage of CO2 in their National Energy
and Climate Plans (NECPs). Draft NECPs cover energy and climate plans to 203058, whereas long term
strategies cover the period until 205059. It is notable that CCUS is included in fewer NECPs than long
term strategies. Strategic development of European transport and storage infrastructure for CO2 could
help bridge this emerging gap between expected need for storage and current projects60 and provide
the required step change in the deployment of these technologies. In this context, the working group
welcomes the inclusion in the latest European Commission Guidance for updated NECPs 2021-203061
of a section, recommending to Member States to include in their updated NECPs the efforts planned
towards capture and storage of CO2.
To complement this process, it will be crucial to focus on building capacity at the national, regional,
and local level, as well as on awareness raising among national and regional administrations. Capacity
building of competent authorities will be crucial to mitigate current and potential future bottlenecks
as  well  as  to  reduce  unnecessary  delays  as  more  CCS  projects  come  into  play.  This  includes  staff
recruitment  and  staff  training  on  CCS.  National  governments  and  competent  authorities  need  to
ensure that sufficient resources are built up to work on new CO2 storage applications linked to the
CO2 storage injection target proposed in the Net-Zero Industry Act. This process should also ensure
that  the  CO2  Storage  Directive  is  implemented  effectively  at  the  national  level.  The  forthcoming
update of the guidance documents and the capacity building workshops that are planned for 2024
should also provide a good basis for coordinated implementation.
Raising awareness and understanding of the technology is crucial. The IPCC Sixth Assessment Report,
‘Climate Change 2022: Mitigation of Climate Change’ stated that the public is largely unfamiliar with
CCUS, and that strong local resistance can contribute to the cancellation of CCS projects.
Limited incentives to accelerate societal support represents another significant risk. Member States,
European policymakers and all relevant stakeholders must collaborate to ensure that there is a robust
understanding  of  public  perception  regarding  the  development  of  storage  infrastructure  and  that
acceptability is not threatened by false perceptions or confusion. Opposition from local communities
represents  a  legal  risk  that  should  be  taken  into  account.  Therefore,  early  engagement  with  local
communities  by  trusted  and  reputable  entities  raising  awareness  and  reinsuring  the  public  on  the
CCUS technologies could help improve public perception and understanding of CCUS.

57 European Commission (2022), Commission Notice on the Guidance to Member States for the update of the
2021-2030 national energy and climate plans here.
58 More information about the NECPs and the Member States’ NECPs can be found here.
59 More information about the long-term strategies and the Member States’ national long-term strategies can
be found here.
60 The Carbon Sequestration Leadership Forum (2021). 2021 Carbon Sequestration Technology Roadmap.
61 European Commission (2022). Communication and annex - Guidance to MS for updated NECPs 2021-2030.
28

7.  Reference list
Bellona  Europa  (2016).  Manufacturing  Our  Future:  Industries,  European  Regions,  and  Climate
Action.
Bellona Europa (2018). An industry's guide to climate action.
Butnar, I., Cronin, J., & Pye, S. (2020). Review of Carbon Capture Utilisation and Carbon Capture
and Storage in future EU decarbonisation scenarios. UCL Energy Institute.
CCUS Forum Working Group on CO2 Infrastructure (2022). Towards a European cross-border CO2
transport and storage infrastructure.
CCUS SET-Plan Implementation Plan (2020). Report on key enablers and hurdles impacting on CCUS
deployment with an assessment of current activities to address these issues.
CCUS SET-Plan Implementation Plan (2021).CCUS Roadmap to 2030.
CCUS  SET-Plan  Implementation  Plan  (2022).  Recommendations  on  the  steps  to  establish  a  R&I
Activity 4 European Storage Atlas.
CCUS  SET-Plan  Implementation  Plan  (2022).  Unlocking  European  CO2  storage  capacity:
recommendations on the steps required to deliver target 7 of the SET Plan’s Implementation
Working Group on CCS and CCU.
CCUS SET-Plan Implementation Plan (2022).Recommendations on the steps required to deliver the
R&I activities 3: EU Projects of Common Interest for CO2 transport infrastructure.
Clean Air Task Force (2022). The gap between carbon storage development and capture demand.
Clean  Air Task  Force  (2023).  Unlocking  Europe’s  CO2  Storage  Potential:  Analysis  of  Optimal  CO2
Storage in Europe.
CO2 Storage Resources Management System. Available here.
CO2GeoNet (2021). State-of-play on CO2 geological storage in 32 European countries - an update.
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2009/31/EC. Available here.
Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  Sustainable
Carbon Cycles.
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full-scale CO2 storage permits in the Danish North Sea.
Directive  2009/31/EC  of  the  European  Parliament  and  of  the  Council  of  23  April  2009  on  the
geological  storage  of  carbon  dioxide  and  amending  Council  Directive  85/337/EEC,  European
Parliament  and  Council  Directives  2000/60/EC,  2001/80/EC,  2004/35/EC,  2006/12/EC,
2008/1/EC and Regulation (EC) No 1013/2006 (Text with EEA relevance).
Directive 94/22/EC of the European Parliament and of the Council of 30 May 1994 on the conditions
for  granting  and  using  authorizations  for  the  prospection,  exploration  and  production  of
hydrocarbons.
European  Commission  (2022).  Communication  and  annex  -  Guidance  to MS  for  updated  NECPs
2021-2030.
29

European Commission, Directorate-General for Energy, Bolscher, H., Guevara Opinska, L., Finesso,
A. et al., (2023). EU regulation for the development of the market for CO2 transport and storage.
Fluxys (2022). Fluxys and Equinor launch solution for large-scale decarbonisation in North-Western
Europe.
Global CCS Institute (2022). Global Status of CCS 2022.
GOV.UK  (2023).  Cooperation  in  the  energy  transition:  UK  -  Denmark  memorandum  of
understanding.
INEOS (2023). INEOS led consortium announces breakthrough in carbon capture and storage.
Inflation Reduction Act of 2022. Available for consultation here.
Intergovernmental Panel on Climate Change (2022). Climate Change 2022: Mitigation of Climate
Change.
International Energy Agency (2022). CO2 storage resources and their development: An IEA CCUS
Handbook.
IOGP (2022). Gap analysis of standards and guides for carbon capture, transport, and storage.
Joint Declaration of Intent between the Federal Ministry for Economic Affairs and Climate Action
of the Federal Republic of Germany and the Ministry of Climate, Energy and Utilities of Denmark
on  the  Cooperation  on  Carbon  Capture  Utilisation  and  Storage  (CCUS).  Available  for
consultation here.
Joint Research Centre (2023). Harmonised system-wide cost-benefit analysis for candidate cross-
border carbon dioxide network projects: After Public Consultation 22 May 2023.
Kähler, F., Carus, M., Porc, O. & vom Berg, C. (2021). Turning off the Tap for Fossil Carbon – Future
Prospects for a Global Chemical and Derived Material Sector Based on Renewable Carbon. nova-
Institute (Ed.), Hürth, Germany.
Memorandum of Understanding (MoU) between the Government of the Kingdom of Norway and
the Federal Government of the Kingdom of Belgium on Energy cooperation on the North Sea.
Available for consultation here.
Memorandum  of  Understanding  (MoU)  between  the  Minister  for  Environment  of  the  Flemish
Region  and  the  Federal  Minister  for the  North  Sea of  Belgium  and  the  Minister  for  Climate,
Energy  and  Utilities  of  Denmark  on  Cross  border  transportation  of  CO2  with  the  purpose  of
permanent geological storage. Available for consultation here.
Memorandum  of  Understanding  (MoU)  between  the  Minister  for  Environment  of  the  Flemish
Region and the Federal Minister for the North Sea of Belgium and the Minister for Energy and
Climate of the Walloon Region and the Minister of Economic Affairs and Climate Policy of the
Netherlands on Cross border transportation of CO2 with the purpose of permanent geological
storage. Available for consultation here.
North Sea Transition Authority (2023). Huge net zero boost as 20 carbon storage licences offered
for award.
Norwegian Petroleum Directorate (2022). Licenses for carbon storage.
30

Norwegian  Petroleum  Directorate  (2023).  Award  of  two  new  licences  for  CO2  storage  on  the
Norwegian continental shelf.
OGE (2022). OGE and TES join forces to develop a 1,000 km CO₂ transmission system.
Proposal  for  a  regulation  of  the  European  Parliament  and  of  the  Council  on  establishing  a
framework  of  measures  for  strengthening  Europe’s  net-zero  technology  products
manufacturing ecosystem (Net Zero Industry Act).
Regulation  (EU)  2022/869  of  the  European  Parliament  and  of  the  Council  of  30  May  2022  on
guidelines for trans-European energy infrastructure, amending Regulations (EC) No 715/2009,
(EU) 2019/942 and (EU) 2019/943 and Directives 2009/73/EC and (EU) 2019/944, and repealing
Regulation (EU) No 347/2013.
Reports on the implementation of the CO2 Storage Directive. Available here.
The  Carbon  Sequestration  Leadership  Forum  (2021).  2021  Carbon  Sequestration  Technology
Roadmap.
TotalEnergies  (2021).  Netherlands:  TotalEnergies,  Shell  Netherlands,  EBN  and  Gasunie  Form
Partnership to Develop the Offshore Aramis CO2 Transport and Sequestration Project.
Wintershall Dea (2022). Wintershall Dea and Equinor partner up for large-scale CCS value chain in
the North Sea.
Wintershall Dea (2023). Wintershall Dea and Fluxys jointly investigate options for transport of CO2.
Zero  Emissions  Platform  &  Carbon  Capture  and  Storage  Association  (2022).  Guidance  for  CO2
transport by ship.
Zero  Emissions  Platform  (2020).  A  Trans-European  CO2  Transportation  Infrastructure  for  CCUS:
Opportunities & Challenges.
Zero  Emissions  Platform  (2021).  ZEP  proposal  for  a  regulatory  framework  for  CO2  transport
infrastructure.
Zero Emissions Platform (2022). Experience in developing CO2 storage under the Directive on the
geological storage of carbon dioxide.

31

8.  Glossary/Definitions
BECCS – Bioenergy with carbon capture and storage refers to the combustion or conversion of biomass
with carbon capture and storage. Depending on the total emissions of the BECCS supply chain, carbon
dioxide (CO2) can be removed from the atmosphere.
CCS  – Carbon capture and storage  refers to the  capture (separation) of carbon dioxide  (CO2) from
various  sources,  followed  by  its  transport  and  injection  into  a  suitable  underground  geological
formation for the purposes of permanent storage.
CCU – A process in which carbon dioxide (CO2) is captured and the carbon then used in a  product.
CCUS – Carbon capture, utilisation and storage encompasses the suite of technologies used to capture,
transport, utilise, and store CO2, including CCU, CCS, BECCS, and DACS, for the purposes of emissions
reduction or CO2 removal from the atmosphere.
CDR  –  Carbon  dioxide  removal  refers  to  anthropogenic  processes  which  remove  CO2  from  the
atmosphere  and  durably  store  it  in  geological,  terrestrial, or  ocean  reservoirs, or  in  products.  Also
referred to as negative emissions.
Cluster  –  Multiple  carbon  dioxide  emitters  geographically  located  near  each  other,  sharing  CO2
transport and storage infrastructure.
CO2 Storage Directive – Directive 2009/31/EC of the European Parliament and of the Council of 23
April 2009 on the geological storage of carbon dioxide and amending Council Directive 85/337/EEC,
European  Parliament  and  Council  Directives  2000/60/EC,  2001/80/EC,  2004/35/EC,  2006/12/EC,
2008/1/EC and Regulation (EC) No 1013/2006 (Text with EEA relevance).
DACCS  –  Direct  air  carbon  dioxide  capture  and  storage  is  the  separation  of  CO₂  from  ambient  air
followed by permanent geological storage. DACCS is a CO2 removal technology, provided value chain
emissions are accounted for.
Isolated emitters – Carbon dioxide emitters that are distant from CCUS/industrial clusters, ports, and
other CO2 transport modes.
LCA – Life cycle assessment, a methodology to evaluate the environmental impacts of a product or
process throughout its life cycle.
Open access / third-party access – in accordance with Chapter 5 of the CO2 Storage Directive, open
access or third-party access is here conceptualised as the guarantee that “potential users are able to
obtain access to transport networks and to storage sites for the purposes of geological storage of the
produced  and  captured  CO2”  and  that  such  access  “shall  be  provided  in  a  transparent  and  non-
discriminatory manner”.
Technology-based  removals  (also  called  engineered  removals)  encompasses  technologies  such  as
DACCS and BECCS, as opposed to nature-based removals.

32

ANNEX 1:  Working group members
Members of the CCUS Forum working group on CO2 infrastructure include stakeholders from industry,
energy,  utilities,  technology  and  equipment  suppliers,  researchers,  and  environmental  NGOs.  This
report benefitted from the active engagement and the input of these various members, who kindly
contributed with their useful comments and materials. Some of the contributing organisations listed
below also contributed to the report of the CCUS Forum expert group on CO2 specifications.

Co-chairs
•  Bellona Europa
•  International Association of Oil & Gas Producers (IOGP)
•  Zero Emissions Platform (ZEP)

Contributing organisations
•  AB Achema
•  Agora Energiewende
•  Air Liquide
•  Air Products
•  Airfix
•  Aker BP
•  Aker Carbon Capture
•  Altera Infrastructure
•  ArcelorMittal
•  Association of the Austrian Cement Industry
•  AxcelFuture
•  Baker Hughes
•  Bastas Cement
•  Bellona
•  Bellona Deutschland
•  BKC MAKINA AS
•  Bond Beter Leefmilieu
•  bp
•  BrinkmannGroup
•  British Geological Survey
•  Carbon Capture Cluster Copenhagen
•  Carbon Clean
•  Carbon Gap
•  Carbon Limits
•  carboneer
•  carbonengineering
•  CarbonGeo/ CCUS Norway
•  Carmeuse Europe
•  CCS management/MOL
33

•  Carbon Capture & Storage Association
•  Cefic
•  CEMBUREAU
•  Centre for Energy and Natural Resources Innovation and Transformation
•  Confederation of European Waste-to-Energy Plants
•  Chevron
•  Ciaotech
•  CIMPOR/ATIC
•  CINEA
•  Clean Air Task Force
•  Clean Energy Ministerial
•  ClientEarth
•  CO2 Management AS
•  CO2 Value Europe
•  CO2GeoNet
•  Coalition for Carbon Capture
•  Confederation of Norwegian Enterprise
•  Corporate Department of Regulations and Public Affairs
•  Crédit Agricole Corporate and Investment Bank
•  CRH
•  CVE
•  Czech Geological Survey
•  Danish CCS alliance
•  Danish Energy Agency
•  Danish Ministry of Energy and Climate
•  DanishShipping
•  Dansk Fjernvarme
•  DC & P GmbH
•  Department of Climate Change, Energy, the Environment and Water (Australia)
•  Directorate-General for Climate Action (European Commission)
•  DGMK e.V.
•  Dioxycle
•  Dow
•  Drax
•  E3G - Third Generation Environmentalism
•  EBN / Aramis project
•  EBRD
•  EcoEnergy
•  European Energy Research Alliance (EERA)
•  EFTA Surveillance Authority
•  eFuel Alliance
•  EIB
•  enagas
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•  Endrava
•  Eni
•  ENTSOG
•  EPCM Global Engineering
•  Equinor
•  Equinor & Offshore Norway CCS Forum
•  ERCST
•  ETH Zürich
•  EuLA - The European Lime Association
•  EUROFER
•  Eurogas
•  EUROPA Danismanlik
•  European Parliamentary Research Service
•  EUTurbines
•  Evida
•  ExxonMobil
•  ExxonMobil Low Carbon Solutions
•  fetsa
•  Flemish Energy and Climate Agency
•  Fluxys
•  FSR
•  Galiboff
•  Gas Infrastructure Europe
•  Gassnova SF
•  Gasunie
•  General Electric
•  GEOMAR Helmholtz Centre for Ocean Research Kiel
•  German Energy Agency (dena)
•  German Federal Minsitry of Economic Affairs and Climate Action
•  German Institute for International and Security Affairs (SWP)
•  Germanwatch
•  Global CCS Institute
•  Göteborg Energi
•  grtgaz
•  Heidelberg Materials
•  Heirloom Carbon
•  Holcim
•  Horisont Energi
•  Innovation Norway
•  Institute of Building Materials Research / RWTH Aachen University
•  Interconnector Limited
•  IOM Law
•  Istanbul Technical University
35

•  Italcementi
•  Izmir Institute of Technology
•  Izmir Katip Celebi University
•  Johnson Matthey
•  European Commission’s Joint Research Centre (JRC)
•  KBR
•  Klaipėdos nafta
•  Klimarepublik
•  Konya Technical University
•  Korean Embassy
•  MCi Carbon
•  Middle East Technical University
•  Ministry of Climate and Environment of Poland
•  Dutch Ministry of Economic Affairs and Climate Policy
•  Dutch Ministry of Economic Affairs and Climate Policy
•  Ministry of Environment and Spatial Planning of Slovenia
•  Ministry of Transport of Baden-Württemberg
•  Mission of Norway to the EU
•  Mitsubishi Heavy Industries EMEA
•  nabu
•  NABU NRW
•  Negative Emissions Platform
•  Neptune Energy Germany
•  Nippon Gases
•  Norsk e-Fuel AS
•  Norsk Hydro
•  North Denmark EU Office
•  Northern Lights
•  Norwegian Energy Partners
•  Norwegian Ministry of Petroleum and Energy
•  OGE
•  OMV Petrom
•  Open Grid Europe
•  PGS
•  PNO
•  Port of Aalborg
•  Port of Gothenburg
•  Porthos
•  Prime marine
•  Renova
•  Repsol
•  Return Carbon
•  RHI Magnesita
36

•  RITE
•  Romanian National Agency for Mineral Resources
•  romgaz
•  Ruhr University Bochum
•  RWE
•  RWE Generation SE
•  Sandbag Climate Campaign
•  Shell
•  Sia Partners
•  Silesian University of Technology
•  SINTEF
•  Sivas Cumhuriyet University
•  Snam Spa
•  South Scania Waste Company
•  Stockholm Exergi
•  Svante
•  Swiss Federal Office for the Environment
•  Swiss Federal Office of Energy
•  TANECS Engineering Consultancy Inc
•  Teréga
•  TES-H2
•  Danish Ministry of Climate, Energy and Utilities
•  The Energy House
•  The Norwegian Ministry of Petroleum and Energy
•  TNO
•  TotalEnergies
•  Tree Energy Solutions
•  Tübitak Mam
•  Uniper SE
•  University of Belgrade - Institute of Chemistry, Technology and Metallurgy
•  University of Manchester
•  University of Stavanger
•  University of Western Macedonia
•  VDZ
•  VDZ Technology
•  Wien Energie
•  Wintershall Dea
•  Wintershall Dea Norge
•  Wintershall Noordzee
•  WiseEuropa
•  WWF EPO
•  Yara
•  Yıldız Technical University - Economics Department
37