Joint letter – ICC reform and expansion risks diverting ETS Revenues from real climate action
In light of the European Commission’s ongoing considerations to amend the ETS State Aid Guidelines, revising the rules for Indirec...
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Publish date: July 29, 2025
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The survey targets industrial emitters but is also designed to invite responses from prospective CO₂ transport and storage operators. It covers a range of topics essential to the creation of a well-functioning CO₂ market in service of climate objectives. Included are questions on transport & storage infrastructure, the functioning of the market and cross-chain risks, as well as cross-border issues and international cooperation.
The survey coincides with upcoming efforts by EU policy makers to set in place an official consultation process on the upcoming proposal, and Bellona Europa hopes that the analysis and results from the survey can contribute positively to these efforts. It also aligns with the official adoption of the delegated act establishing CO₂ storage obligations for major oil and gas producers, on July 24, under the NZIA. This obligation marks a crucial moment in the fight against climate change, the progress of which Bellona is consistently tracking through the Article 23 project together with CATF and CBI. The survey therefore places particular focus on how best to ensure a level playing field amongst market participants across the value chain. As more CCS projects across the EU are moving forward, the establishment of clear, effective and fair regulatory frameworks for capturing, transporting and storing CO₂ are becoming ever more urgent.
Bellona Europa looks forward to learning more about the different views, knowledge, concerns and positions of the various organisations participating on the range of issues tackled in the survey. The results will be shared widely and feed into Bellona’s recommendations for the scope and function of the EU’s upcoming EU proposal on CO₂ market and infrastructure function. Of course, respondents will be anonymized.
The survey will remain open until end of September, 2025.
We strongly encourage you to share with other relevant stakeholders for whom this survey is of interest.
For any questions or further information, please contact Behnam Lot (behnam@bellona.org).
Your perspective matters. Help us ensure the regulatory framework works for those who will bring CO₂ management into operation.
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