The 4th annual Industrial Carbon Management Forum (ICM Forum), formerly known as the CCUS Forum, took place last week (10–11 October) in Pau, France—a region renowned for its industrial heritage and currently engaged in the PYCASSO project[i]. This year’s event was the largest to date, with 570 in-person participants and over 2500 joining online. Organised by the European Commission (EC) in collaboration with the French Ministry of Energy, the Forum brought together a diverse range of stakeholders, including representatives from industry, EU Member States, EU institutions, NGOs, and academia.

While the speaker lineup was relatively balanced, reflecting the broader Carbon Capture and Storage (CCS) stakeholder landscape, the audience was largely dominated by industry and oil and gas representatives. However, this year saw a small but welcome increase in civil society participation, both in the audience and on panels. Bellona, as in previous years, was represented as we believe that civil society’s presence is crucial to ensure that the core objective of CCS deployment—rapid emissions reductions in hard-to-abate sectors—is not overshadowed by varying commercial interests. We also want to ensure that critical concerns are well represented in the discussions.

The establishment of the ICM Forum Working Groups (WGs)—tasked with providing input for ICM legislation to the Commission—occurred quite late this year. This delay limited the progress they were able to make in the lead-up to the Forum compared to previous years. Additionally, NGO involvement in these WGs has remained limited, partly due to the lack of public visibility and relative inaccessibility of the process. Improving this could involve greater efforts to publicise the opportunity to join, clearly outlining the deadlines and procedures for participation, and enhancing transparency by making the list of active organisations publicly available. Such steps would encourage broader civil society engagement, ensuring that the legislative process reflects a wider range of perspectives and maintains the climate and environmental integrity of CCS deployment.

2024 has proven to be a decisive year for CCS, with its momentum reaching so far unprecedented levels. Earlier this year in its Industrial Carbon Management Strategy (ICMS), the EC once again officially recognised CCS as a decarbonisation solution, (CCU, and permanent carbon removals (from biogenic or atmospheric sources) —collectively termed Industrial Carbon Management (ICM))— and recognised it as essential to the net-zero puzzle. This Strategy outlines plans to massively scale up ICM technologies by 2050, offering a large array of initiatives to support this aim.[ii] Meanwhile the co-legislatures passed a binding target for oil and gas producers to develop 50Mt of geological CO₂ storage capacity across the EU in the Net-Zero Industry Act (NZIA).[iii]

Urgent need for a CO₂ transport regulation to accelerate infrastructure deployment

Among the most urgent and highly anticipated developments is the CO₂ transport regulatory package, aiming to address critical issues such as “market and cost structure, cross-border integration and planning, technical harmonisation and investment incentives for new infrastructure, third-party access, competent regulatory authorities, tariff regulation and ownership models”[iv].

Despite widespread interest, previous Commissioner for Energy, Kadri Simson, did not provide a concrete timeline for the Regulation, noting only that it remains ‘in the works’ and will be carried over to the next legislative cycle. The slow progress of the CO₂ transport Regulation, partly due to the election year, is shaping up to become a significant roadblock to network planning and therefore the rapid deployment of CO₂ infrastructure across Europe. To express concern and avoid this becoming a serious bottleneck, six Member States (Denmark, Germany, France, the Netherlands, Sweden, and Finland) signed a Joint Statement urging the Commission to “present a  CO₂ transport regulatory package early in its mandate and no later than 2025 to support a rapid development of CC(U)S in Europe”[v].

This is a much-needed initiative, and we hope it will prompt the Commission to fast-track the publication of the proposed Regulation. For the operators of  CO₂ transport infrastructure aiming to offer  CO₂ transport as a service, regulation that sets at least minimum standards is crucial – not only ensuring interoperability but also providing much-needed market confidence for those working to deploy other parts of the value chain, while this EU-level harmonisation of standards can also play a significant role in de-risking investments.

The lack of regulatory certainty surrounding CO₂ transport—and its necessity for ensuring interoperability—was a recurring concern, regardless of the specific panel topic. Types, concentrations and combinations of impurities in the captured CO₂ depend both on the flue gas and on the capture technology used. The picture broadens even more when CO₂ streams from several capture facilities are mixed. Possible impurity combinations and their effects must be completely mapped and understood. A standard needs, therefore, to strike a delicate balance between current knowledge, safety and the risk of inflating costs to the point where it undermines the viability of CO₂ capture installations.

Building a viable business case through funding and financing mechanisms

Another prominent issue was the question of funding and financing to create a viable business case for CCS deployment. Opportunities for debt financing are becoming increasingly available, with more private banks, such as BNP Paribas and ING, entering the picture. This could potentially make these projects more attractive to private investors, highlighting the growing need to significantly boost private investment as well.

While the Commission’s financial backing—supporting first-of-their-kind projects through the Innovation Fund and subsequent ones via the Connecting Europe Facility—is valuable, the absence of a solid business case for these projects without external support remains a challenge. As a result, attention is now shifting towards Carbon Contracts for Difference (CCfDs) as a key tool for de-risking CO₂ capture projects.[vi] CCfDs would not only help de-risk CO₂ capture projects thereby making them more attractive for private investors, but also provide much-needed market confidence to transport and storage developers, ensuring demand for their services as emitters work to capture their process emissions—finally breaking the ‘chicken and egg’ dilemma [vii].

As for demand, the creation of lead markets for low-carbon products was emphasised several times as a crucial driver for boosting investments in decarbonizing industry. ‘You cannot run a project on subsidies; someone needs to pick up the bill—it’ll have to be consumers,’ said a representative from Yara, fertiliser company. Indeed, a self-sustaining business requires a solid business case, and for that, there must be clear demand-side measures for low-carbon products, such as green public procurement, whole-life carbon maximum thresholds, low-carbon product quotas. This needs to be reflected in upcoming legislation, and Member States have a crucial role to play in the implementation of such measures. Utilising public purchasing power to absorb a potential initial green premium and create the business case to de-risk investments will enable lead market creation.

Growing Member State-level engagement in Industrial Carbon Management

Member States are entering the ICM conversation as well in larger numbers, especially with the introduction of the NZIA and the Commission’s recommendations to include ICM technologies in their National Energy and Climate Plans (NECPs). “This growing engagement was reflected in the conference attendance, with new national authority representatives from Croatia, Denmark, Germany, Greece, Hungary, the Netherlands, Norway, Romania, and Italy present on the Forum panels, and many more attending as participants, including France, as the co-organiser and host, alongside Belgium, Lithuania, Poland, and Sweden. They tended to emphasise the importance of retaining their national industrial base, with the ‘reindustrialisation’ of Europe being highlighted as both a strategic goal for achieving net-zero and a crucial aspect of ensuring security through increased autonomy.

In some countries, even where CCS projects have been underway for years, they have yet to reach a final investment decision (FID). Greece, however, is expecting several FIDs by next year, largely thanks to four major emitters joining forces to advocate for public support for their decarbonisation projects. France is also anticipating an FID for the D’Artagnan project in Dunkirk[viii], while Italy is hinting at a staggering 500 Mt of CO₂ storage potential in the long term[ix], through a ramp-up of the Ravenna CCS project which became operational in September this year[x]. All of this supports the notion that, once momentum builds, market confidence will grow, accelerating the rollout and rapid implementation of CCS projects.

So, what can we expect from 2025?

• The Clean Industrial Deal will be introduced within the first 100 days of the new Commission, with possible implications for CCS deployment.
• The regulatory package on CO₂ transport is highly anticipated and may be rolled out towards the end of 2025.
• The Commission is expected to publish, or at least make significant progress on, the CO₂ Investment Atlas, the CO₂ demand aggregation and the knowledge sharing platforms, all of which will be important to create enhanced collaboration among private and public stakeholders along the value chain.
• Northern Lights (Norway) will begin operations, storing CO₂ from a cement plant (in Brevik), officially marking the introduction of low-carbon cement.
• Several FIDs are expected in Greece and France.
• Germany is set to implement Carbon Contracts for Difference (CCfD) and allocate public funding to CCS projects in accordance with the criteria laid out in its yet-to-be-released comprehensive Carbon Management Strategy.
• Poland is developing a CCS action plan, with hopes of releasing it next year.
• Further CO₂ exploration licenses will be granted across the EU, following the Delegated Act (DA) specifying contributions and small producer thresholds.
• The process related to the Low-carbon Hydrogen Delegated Act should be finalised next year and, if done right, will encourage CCS application on H2 production.
• The JRC updated report on CO₂ transport network planning is expected to be released early in 2025.

Momentum for CCS is expected to grow rapidly in 2025, with the potential to cover significantly more ground than before. However, this progress will also bring certain bottlenecks to the forefront, such as long permitting times, regulatory gaps (especially regarding CO₂ transport), technical and operational issues, and insufficient demand for low-carbon products. These challenges will need to be addressed swiftly.

Given that speed is not one of the EU’s strong suits, private players and Member States will likely need to enhance collaboration by strengthening peer-to-peer discussions, improving information sharing, and building trust across the value chain through a robust system of verification. This system would ensure that all actors—capture facilities, transport operators, and storage providers—adhere to uniform technical standards, for instance concerning CO₂ purity levels. Such consistency would reduce technical, operational, and liability risks, create clarity around responsibilities, and help avoid operational errors. By providing transparency on performance and compliance, it would foster accountability and build trust, making participants more willing to commit long-term investments and scale up CCS deployment.

Additionally, engaging local communities early, in the planning stage of CCS projects, will be crucial. This can begin with mapping local sentiments and conducting impact assessments to ensure that projects obtain social license. Success in these areas will be vital to overcoming the hurdles and driving forward CCS deployment in Europe.

To accelerate CCS deployment for tackling hard-to-abate emissions, Bellona Europa recommends to:

• Extend and strengthen public support from the EU as well as Member State governments. This support can take different shapes (grants, tax credits, debt financing, state-owned enterprises, carbon pricing, green public procurement, Carbon Contracts for Difference, insurance schemes) based on what works best in the economic, social and political context of each country, but in every case it is necessary to create a business case for CCS deployment until a functioning market is ready to take off and to de-risk private investments into the technology to get CCS projects off the ground.
• Establish the legal frameworks necessary in the case of CO₂ transport infrastructure deployment, to provide clarity to the market as to the frameworks within which it must operate. We urge the European Commission to expedite the publication of its proposal for the CO₂ Transport Regulation to 2025.
  • CO₂ purity standards need to strike the balance between safety, technological realities and cost-efficiency. The Commission should therefore prioritise a comprehensive study and mapping of possible CO₂ impurity combinations and their effects for the update of early standards.
• Accelerate CO2 storage; it is crucial to incorporate both existingand new datasets to enhance our understanding of the subsurface and thereby enable faster permitting. This will help reduce uncertainty, lower associated risks and significantly shorten the lead time for storage development.
• Accelerate the implementation of the CO₂ Investment Atlas, the CO₂ demand aggregation and the knowledge sharing platforms to address the insufficient coordination along the CCS value chain.
• Integrate strong demand-side measures for low-carbon products in the Clean Industrial Deal. This should include mandatory green public procurement in the upcoming revision of the Public Procurement Directive, strong maximum embodied carbon thresholds in the national whole-life carbon roadmaps within the EPBD, and low-carbon product quotas in public projects. Member States should utilise public purchasing power to absorb the initial green premium, creating a solid business case and de-risking investments.
• Encourage Member States to publish their final NECPs as soon as possible, ensuring they adequately reflect their strategies for CCS technologies.
• Implement measures that reduce lead times such as capacity building on all levels of government to meet the needs for public engagement and processing permits.
• Establish widespread collaboration between companies and Member States to enhance peer-to-peer discussions and information sharing, which can help address potential bottlenecks in CCS deployment.
• Increase transparency and accessibility of the ICM Forum Working Groups by publicising participation opportunities, clearly and publicly communicating deadlines and procedures, and publishing the list organisations active in ICM WGs.

Engage local communities early in the planning process by mapping local sentiments and conducting impact assessments and ensure that local communities receive tangible benefits from CCS projects, aligning with the principles of a just transition

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[i] PYCASSO project, https://www.pycasso-project.eu/en/home/

[ii] European Commission, 2024, Communication on the Industrial Carbon Management Strategy, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2024:62:FIN

[iii] European Commission, 2024, REGULATION (EU) 2024/1735 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 June 2024 on establishing a framework of measures for strengthening Europe’s net zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401735

[iv] European Commission, 2024, Communication on the Industrial Carbon Management Strategy, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2024:62:FIN, (pp. 10)

[v] Joint Statement on Establishing an Appropriate European Framework for Cross-Border CO₂ Transport Infrastructure, 2024, https://www.kefm.dk/Media/638644879489987071/ONDERTEKEND%20-%2020241010_Joint%20statement%20DK_signed.pdf.dk

[vi] Bellona Europa, 2021, Contract Incentives for Industrial Carbon Capture: A review of design options, https://network.bellona.org/content/uploads/sites/3/2021/06/2021-Contract-incentives-for-industrial-carbon-capture-1.pdf

[vii] Bellona Europa, 2023, Carbon Capture and Storage: A Crucial Piece of the Puzzle in Industry’s Path to Net-Zero, https://bellona.org/news/eu/2023-06-carbon-capture-and-storage-a-crucial-piece-of-the-puzzle-in-industrys-path-to-net-zero

[viii] The 3D Project (DMX™ Demonstration in Dunkirk), https://corporate.arcelormittal.com/climate-action/decarbonisation-technologies/the-3d-project-dmx-demonstration-in-dunkirk

[ix] Draft National Energy and Climate Plan, Italy, 2023  https://commission.europa.eu/document/download/75b8162c-3d62-4627-8706-c62997b324da_en?filename=ITALY%20-%20DRAFT%20UPDATED%20NECP%202021%202030%20%281%29.pdf

[x] Ravenna CCS project, https://ccushub.ogci.com/focus_hubs/ravenna/