The Bioenergy Association of Finland strongly supports the Commission’s legislative initiative regarding CO2 transportation infrastructure and markets and appreciates the opportunity to contribute.
The swift emergence of CO2 infrastructure and a well-functioning EU market for CO2 are crucial to enable the EU to reach its climate targets and to foster competitive development of carbon management value chains. Removing barriers to cross-border CO2 transportation, ensuring competitive market outcomes and improving investor confidence are needed to develop a well-integrated and efficient EU market. This will lower costs, reduce CCUS project lead times, and support the build-up of value chains needed for permanent carbon removals, sustainable CO2 as feedstock and the decarbonization of hard-to-abate sectors.
Biogenic CO2 represents a strategically important feedstock for the EU’s climate neutrality goals. When permanently stored it provides permanent carbon removals, when used in more short-term products it substitutes fossil carbon. Recognising and supporting biogenic CO2 in the EU CO2 market and transport infrastructure is therefore crucial. Unlocking its’ potential requires explicit regulatory recognition, targeted transport infrastructure, and market design that values permanent removals and sustainable CO2 as feedstock. Without these measures, Europe risks missing an opportunity to mobilise existing sustainable CO2 streams into the emerging CO2 market.
At present, CO2 infrastructure development for CCUS projects is largely uncoordinated and built on project-by-project basis leading to higher costs. To reduce investment risks and unlock private capital, tailored and smart support mechanisms are critical. EU-level funding will be vital for deploying CO2 infrastructure at scale. Funding models that prioritise early connection of biogenic CO2 sources or hubs should be developed.
Given the geographic dispersion of CO2 sources and storage or utilization sites in the EU, a mix of local pipelines, interim storage facilities, terminals, ship transport from coastal hubs and repurposed gas infrastructure will be needed. Investment in local hubs will be essential to aggregate streams into volumes suitable for pipeline or shipping and also to foster large-scale utilization projects. Separate and regional infrastructures should be recognised as parts of the European market.
Regarding the safety and timely implementation of CO2 infrastructure, it is essential to ensure that no leakages occur. Under current conditions, the use of PFAS remains indispensable, as no technically viable alternatives for valves are available within the required ramp-up timeframe that can deliver the same level of performance.
Biogenic CO2 sources can provide meaningful, near-term permanent removals and feed sustainable product value chains — but only if the EU creates predictable market recognition and invests early in CO2 infrastructure that connects biogenic sources to storage or utilization hubs. Policy clarity, targeted infrastructure support for biogenic sources, and cross-border legal alignment will be critical to unlocking this potential and accelerating timely delivery of permanent removals and sustainable CO2 as feedstock for the EU’s climate neutrality objectives.