Bioenergia ry – The Bioenergy Association of Finland represents the interests of bioenergy and biochar sectors in Finland. We welcome the Commission’s initiative on developing cross-border CO2 infrastructure in the EU. The rapid scale-up of CO2 infrastructure and well-functioning EU CO2 markets are crucial for the EU to achieve its climate targets, promote the competitive development of carbon management value chains, and enable the swift emergence of new business opportunities. Biogenic CO2 is a strategically important feedstock for achieving the EU’s climate neutrality objectives. When permanently stored, it delivers permanent carbon removals, when used in shorter-lived products, it substitutes fossil carbon. Unlocking this potential requires explicit regulatory recognition, targeted transport infrastructure, and market design that values permanent removals and sustainable CO2 as feedstock.
Industrial carbon management value chains are still underdeveloped, and a common EU regulatory framework is needed to define key principles (including removing barriers to cross-border transport, ensuring a level playing field, and accelerating infrastructure development). Projects and markets face uncertainties, and the regulatory framework should allow sufficient flexibility during the scale-up phase of solutions.
Carbon capture, utilisation and storage (CCUS) technologies can offer multiple sectors opportunities for direct emissions reductions, removal of CO2 from the atmosphere, or the use of sustainable CO2 as a feedstock for various products. The EU regulatory framework for CO2 infrastructure should support the EU emissions reduction pathway in a technology-neutral manner. Decisions on where these technologies are applied should be left to the market.
When planning CO2 infrastructure and markets, the needs for both CO2 storage and utilisation, as well as different CO2 sources, must be considered from the very beginning of the planning process. Regional transport and handling infrastructure ecosystems should also be regarded as part of the EU’s common infrastructure and be eligible for support measures. There should also be a coordinated permitting approach regarding the shared infrastructure and storage hubs.
With regard to CO2 transport, all modes of transport should be treated equally and considered part of the EU’s common CO2 infrastructure. All transport modes will be needed in the coming decades. Any potential EU-wide CO2 infrastructure planning tool should include, in addition to pipelines, other modes of transport. Planning should aim to promote system integration as effectively as possible and leverage synergies with the development of other networks (electricity, gas, hydrogen).
A separate, EU-level harmonised certification scheme for biogenic CO2 for all end uses is not necessary – and could be even counterproductive . Existing certification schemes under the Renewable Energy Directive (RED III) and the Carbon Removal Certification Framework (CRCF) adequately address this need. Regulation of CO2 infrastructure should build on existing legislation, thereby accelerating the implementation of projects and the necessary infrastructure. For mixed CO2 streams, existing traceability methods under current legislation are sufficient.
From the perspectives of social acceptance, safety and risk minimization, all partners in the CO2 value chain should establish a common emissions allowance pool to act as a buffer against the costs of CO2 leaks caused by accidents or service disruptions. For the safe and timely deployment of CO2 infrastructure, it is essential to ensure that leaks do not occur. Under current conditions, the use of PFAS compounds is necessary, as no technically viable alternatives for valves are available within the required timeframe that would provide equivalent performance.
Targeted EU- and Member State-level financial support and non-financial de-risking measures are necessary during the scale-up phase of CO2 infrastructure. For example, state measures to limit operators’ volume risks (such as state guarantees covering volume risks), EU-level operational support for capture projects, and CAPEX support for infrastructure development in CO2 hubs are needed in the market ramp-up phase.
With regard to international agreements, HELCOM restricts the deployment of significant storage capacity in the EU in the Baltic Sea region. As a party to the agreement, the EU should actively promote ongoing developments in legal interpretation to remove these barriers and thus enhance the development of storage capacity in different regions in the EU.
The EU should promote cooperation on carbon management with third countries, especially with the United Kingdom. Alignment is needed between the EU Emissions Trading Directive and the CCS Directive so that projects can be implemented between the EU and the UK without regulatory barriers.
The potential role of an EU-level CO2 Platform should be to increase market transparency and the visibility of current and future supply (captured CO2 volumes) and demand (CO2 storage capacity and utilisation), and to serve as a channel for information sharing between different actors. Actual contracts between value chain actors should be concluded bilaterally between companies.
Contribution CO2 markets and infrastructure Bioenergia ry 2026
Lisätiedot: Erika Laajalahti, +358 44 753 0700, erika.laajalahti(a)bioenergia.fi