At the end of April, CO₂ Value Europe submitted its response to the European Commission’s consultation on the Clean Industrial State Aid Framework (CISAF), a crucial initiative to accelerate renewable energy deployment, support industrial decarbonisation, and strengthen clean tech manufacturing capacity in Europe by enabling State Aid support to be granted under certain conditions. Moving away from fossil fuels comes at a cost: State Aid support for CCU projects is dramatically needed to help fossil-free alternatives become competitive.
As the EU association representing the entire Carbon Capture and Utilisation (CCU) value chain, we welcomed the opportunity to contribute and highlighted several key recommendations to ensure the CISAF truly enables innovative technologies like CCU to scale.
OUR MAIN RECOMMENDATIONS TO THE COMMISSION:
State Aid support for CCU technologies is essential
While the draft CISAF includes important provisions for CCU fuels and CO₂ mineralisation, which is promising, it also strikingly overlooks critical parts of the value chain—such as CCU chemicals, recycled carbon fuels (RCFs), low carbon fuels (LCFs), and carbon monoxide (CO) conversion technologies. We emphasised the need for a broader and more consistent scope to include all innovative CCU solutions; otherwise, technologies left behind will continue to struggle.
Support across the entire CCU value chain
Funding must cover more than just the capture part. CCU projects typically involve capture, transport, and conversion stages. Supporting only one part undermines their viability. We called on the Commission to adopt a holistic approach to value chains, including provisions for infrastructures such as CO₂ and hydrogen transport.
Ensure inclusiveness and clarity on CCU products
Terminology across the CISAF must be consistent- terms like RFNBOs, low-carbon fuels, and derivatives should be used systematically. We also urged the Commission to clarify eligibility conditions and avoid creating vague or hard-to-understand criteria that could lead to legal uncertainty or hinder project deployment.
Reflect real project timelines and challenges
We raised concerns over the 36-month implementation deadline and the 10% renewable hydrogen threshold for aid eligibility—both risk excluding promising projects due to overly complex criteria. We called a more pragmatic and science-based approach.
Aid for manufacturing clean tech
We strongly support the inclusion of CCU technologies in the clean tech manufacturing aid section. We recommend aligning the scope of eligible technologies with the Net Zero Industry Act (NZIA) categories to ensure consistency and address identifiable market failures.
NEXT STEPS
CO₂ Value Europe looks forward to further dialogue with the European Commission and calls for the final CISAF to be designed to truly empower Europe’s clean industrial transition, supporting innovation, simplifying access to aid, and enabling a resilient and competitive net-zero economy.
Find our full response to the consultation here.
