Industry welcomes the European Commission’s work on the development of a
regulatory framework for CO₂ transport infrastructure, which will be critical to
achieving the EU’s climate objectives and enabling the scale-up of Carbon Capture,
Utilisation and Storage (CCUS) as part of an integrated value chain, including emitters,
transport, storage operators, and CO2 offtakes for use in products.

However, the European CO₂ transportation market remains at an early stage of
development, with limited infrastructure in operation and many projects still facing
significant regulatory, financial, and coordination challenges. At this stage, the priority
should be to enable deployment and support the de-risking of investments for
current and future projects, rather than focus only on regulatory frameworks.

A strong Industrial Carbon Management framework should also ensure that adequate
incentives are in place across the value chain, recognising the high costs of CCUS
projects and the need for effective de-risking and support mechanisms to enable
large-scale deployment.

While regulatory clarity is important, there is a need to ensure that policy design
remains proportionate and aligned with the current maturity of the market,
avoiding the introduction of strict regulatory approaches in a nascent market, and
ensuring that any future regulation intervention is justified by clear market needs.
The framework should also preserve investor confidence by safeguarding first-mover
projects and avoiding retroactive changes that could undermine bankability.

Key messages to policymakers include:
🔹 Prioritise deployment and investment certainty in this early-stage market
🔹 Remove regulatory and cross-border barriers to CO₂ transport
🔹 Support industrial clusters and regional transport corridors
🔹 Ensure proportionate and flexible regulation as the market evolves
🔹 Protect investor confidence and avoid premature regulatory burdens

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