CO₂ Value Europe’s Recommendations for an Open-Access European CO₂ Transport Infrastructure

CO₂ Value Europe responded to the European Commission’s call for evidence on CO₂ transport infrastructure and markets, strongly advocating for an open-access system that serves all Industrial Carbon Management (ICM) pathways, including Carbon Capture & Utilisation (CCU), Carbon Capture & Storage (CCS), carbon removals, and that is fit for large players as well as SMEs.

As the voice of the Carbon Capture and Utilisation (CCU) community, we welcome the reference to CCU in the consultation. However, we are concerned by the assumption that CO₂ captured in the ramp-up phase will be “nearly exclusively for permanent storage”. This overlooks the growing role of CCU, which the Commission’s own ICM Strategy projects accounts for, stating that ~93 Mt of captured CO₂ by 2040 and ~200 Mt by 2050 (~45%) will go towards usage pathways. With at least 26 CCU projects already expected to be operational in the EEA by 2030, producing 2.3 Mt of CCU products annually, CCU should already be a key part of any ICM-related policy.

Our Key Recommendations:

🔵 Include CCU from the Start: Forecasted CCU volumes justify their integration into infrastructure design. Exclusion would mean higher costs and parallel infrastructures.

🔵 Enable Multi-Purpose Projects: Allow projects with both CCU and CCS outputs access to the same network.

🔵 Guarantee Open-Access: Ensure emitters and offtakers can access CO₂ along the value chain.

🔵 Support SMEs: Secure fair participation of small and medium enterprises in infrastructure access.

🔵 Address Policy Barriers: Remove hurdles such as restrictive permitting rules and eligibility of carbon sources that currently block the growth of a captured CO₂ market.

🔵 Create a Coordination Platform: We support the creation of a system including Guarantees of Origin and a CO₂ marketplace that would connect emitters and offtakers, boosting transparency and accelerating a European CO₂ commodity market.

Europe’s CO₂ transport infrastructure must be open, inclusive, and future-proof – not only to enable CCS, but also to unlock the full potential of CCU in building new industrial value chains, sustainable products, and jobs.

Find our detailed recommendations here.