CEMBUREAU Input To Part A – CO₂ Injection Capacity

1. Is it justified to have a specific Chapter on CO₂ injection capacity, even if CCS is already included as a net-zero strategic technology? If so, are the provisions likely to be effective enough in the entire EU to reach the 2030 capacity storage target in geographically balanced way beyond the North Sea region, given the limitations imposed by several MS to CCS?

CEMBUREAU considers that a specific chapter on CO₂ injection capacity is absolutely critical.

Carbon Capture, Utilisation and Storage (CCUS) is a key technology to decarbonise our sector, as cement production faces unavoidable process emissions which cannot be reduced to zero without carbon capture. A significant number of CCUS projects are currently being developed by the EU industry, with a number of them reaching commercial deployment before 2030. CEMBUREAU estimates that by 2030, about 12-15 million tons of annual CO₂ injection capacity will be required by the EU cement industry. It is critical for these projects to have sufficient guarantees that enough storage capacity will be available by then.

CEMBUREAU agrees that a geographical balance of CO₂ storage sites is an important element. There are about 200 cement kilns in Europe and these are evenly spread on the EU territory. In this respect, CEMBUREAU would suggest that:

• As part of article 16, a provision should be added to ask the European Commission regulatory report on the progress achieved towards the EU annual injection capacity target,  looking in particular at the geographical balance of storage sites across the EU.
• As part of article 17, a new provision should require Member States to report about the CO₂ capture and transport projects on their territory, in addition to storage. Furthermore, Member States should report on bilateral agreements made to facilitate cross-border transportation of CO₂ .
• As part of article 17, if Member States do not report no CO₂ storage projects are in progress on their territory, they should then report on plans to facilitate the decarbonisation of industrial sectors faced with unavoidable CO₂ process emissions. These plans should include cross-border transport of CO₂ to storage sites located in other Member States, as well as CO₂ utilisation projects.

Last but not least, CEMBUREAU strongly believes that the Net Zero Industry Act should also contain provisions requiring the European Commission to establish further CO₂ injection capacity targets at a 2040 horizon, as part of its 2040 climate change target plan.

2. Noting that the NZIA does not regulate which type of CO₂ will be captured and stored in the relevant storage sites and that the Commission is currently consulting the public on an Industrial Carbon Management Strategy , would Member States see merit in limiting the promotion of CCS to hard-to-abate sectors and energy production routes where there are no other alternatives, in order to avoid further consumption of fossil fuels, or should CCS be promoted for all sectors that economically can capture CO₂ considering the great challenge of achieving climate neutrality by 2050?

As expressed above, CCUS is indispensable to reach carbon neutrality in cement, as the sector is faced with unavoidable process emissions. CEMBUREAU considers that industrial sectors facing process emissions should be prioritised over other sectors where alternative technologies are available. 

3. Do you consider that the annual injection capacity target of 50 million tons by 2030 can be reached in geographically balanced way beyond the North Sea region without imposing obligations to oil and gas producers? If so, would you be in favour of deleting these obligations from the text?

CEMBUREAU is opposed to the deletion of the obligations put on oil and gas producers as part of article 18. Furthermore, CEMBUREAU considers that requirements should be added to ensure that the CO₂ infrastructure projects should respect the principles of third-party access, ownership unbundling, non-discriminatory tariffs and transparency, as defined in Directive 2009/73/EC. As projects are being deployed, it is vital to have a clear regulatory framework with fair market access conditions for future users of CO₂ storage sites.