Response to Commission Public Consultation on CO2 Transport

Author(s): Andrei Marcu, Chiara Cavallera, Marino Varricchio

Key points

•⁠ ⁠EU framework: A harmonised EU framework with clear, simple and predictable regulatory principles is essential to remove cross-border barriers, ensure a level playing field, prevent market fragmentation and provide long-term investment certainty. Regulation should remain strictly technology-neutral and market-driven, avoiding preferential treatment of specific carbon capture technologies, sectors or applications. Decisions on decarbonisation options should be left to the market.
While core principles such as non-discriminatory access, transparent tariffs, clear liability must be established now to provide certainty, temporary derogations/exemptions may be needed during the ramp-up phase so that early projects are not blocked or distorted by premature detailed rules. Flexibility must expire automatically when the market matures.
•⁠ ⁠Cross border CO2 transport: International treaties, particularly broad marine dumping prohibitions, currently restrict cross-border CO₂ transport and create legal uncertainty for CCS deployment; ratification of the London Protocol amendment and addressing HELCOM restrictions in the Baltic are critical.
•⁠ ⁠Financing: Temporary Financial and non-financial de-risking measures are needed to kick-start the market, but in the long run, the CO₂ value chain must be self-financing.