Bellona Europa welcomes the opportunity to provide feedback on the draft Delegated Act (EU) 2024/1735, specifying the rules for identifying oil and gas obligated entities required to contribute to the Union-wide target of achieving 50 Mt of CO₂ injection capacity by 2030, as set out in the Net-Zero Industry Act (NZIA).

Enforcing the NZIA’s CO₂ injection capacity target will be critical not only to achieving the EU’s climate goals, but also to safeguarding the long-term competitiveness of industries that are unable to fully decarbonise without Carbon Capture and Storage (CCS) technologies and access to CO₂ storage.

Since the release of the Industrial Carbon Management Strategy and the adoption of the NZIA, momentum behind industrial carbon management deployment has grown significantly. Bellona urges the European Commission to capitalise on this momentum by enabling and enforcing timely implementation of Article 23 of the NZIA. The full list of obligated entities should be finalised as soon as possible to ensure that the plans required under Article 23(4) by 30 June 2025 are sufficiently detailed and to provide entities with time to fulfil their obligations.

Download or view the full consultation response below:

• Consultation Response (pdf)