The ICMS contains separate sections covering which measures are needed to scale CCS, CCU, industrial CDR, and CO₂ transport and storage infrastructure. The measures relevant to CDR include considerations on developing a separate carbon removal trading scheme, introducing Important Projects of Common European Interest (ICPEIs) for CO₂ transport and storage infrastructure, and boosting research, innovation and early-of-a-kind demonstration for novel industrial technologies for carbon removal.

The strategy also provides a dedicated section on public awareness, which appears to signal that the Commission recognises the importance of involving and engaging stakeholders and the public in the scale-up of industrial carbon management technologies.

However, the strategy does not clearly distinguish between CDR, CCS, and CCU, and fails to set dedicated targets for each of these. It narrowly focuses on types of CDR considered ‘industrial CDR’, namely direct air carbon capture and storage (DACCS), bioenergy with carbon capture and storage (BECCS) and biogenic carbon.

For CO₂ transport and storage infrastructure, the strategy mentions that, as of 2024, the Commission:

• should initiate preparatory work in view of a proposal for a possible future CO₂ transport regulatory package, as well as working towards proposing an EU-wide CO₂ transport infrastructure planning mechanism;
• will work with member states on exploring a possible Important Project of Common European Interest (IPCEI) for CO₂ transport and storage infrastructure.

Carbon Gap unveiled its CDR Strategy for Europe in March 2024, and presented key recommendations that are intended to complement the actions foreseen in the ICM strategy to scale CDR.

Scaling up industrial CDR

The ICM strategy acknowledges the key role CDR will play in reaching climate neutrality by indicating that it will be needed to compensate for approximately 400MtCO₂e of residual emissions by 2050. This figure comprises both land-based and industrial CDR (iCDR). The ICM also states that around 280MtCO₂ and 450MtCO₂ would need to be captured by 2040 and 2050, respectively, without clearly specifying which share would be stored and used, and which share would be CDR.

The strategy identifies key policy gaps holding back the scaling up of iCDR, including a lack of incentives, the lack of recognition of iCDR in the current EU legislative framework and the high costs associated with various iCDR methods. The Commission presents three main actions to address these gaps:

• Assess overall objectives for CDR in line with the 2040 targets and the goal of climate neutrality by 2050, and negative emissions thereafter.
• Develop policy options and support mechanisms for industrial carbon removals, including if and how to account for them in the EU ETS.
• In parallel, boost EU RD&I and early-of-a-kind demonstration for novel iCDR under Horizon Europe and the Innovation Fund.

Role of CCS and CCU

The ICMS lacks concrete targets for CCS and CCU beyond the 50MtCO₂ yearly injection capacity target by 2030 set in the Net-Zero Industry Act (NZIA). Some projections are included, but these do not clearly show how much CO₂ would be used for storage, and how much would come from CCS as distinct from CDR. Furthermore, these projections are not presented as actual targets for CO₂ storage.

Regarding CCS, the ICM strategy presents an extensive package of policy actions it plans to undertake, including the development of a platform for demand assessment and aggregation for CO₂ transport and storage services. The strategy also calls on member states to take several measures, such as the inclusion in their national energy and climate plans (NECPs) of an assessment of their CCS needs and identified actions to support the deployment of a CCS value chain.

Regarding CCU, the ICM mentions that over time, biogenic and atmospheric CO₂ will be increasingly used for CCU. It also lays out broad policy actions, such as the creation of a knowledge-sharing platform for industrial CCUS projects.

CO₂ infrastructure as a key enabler

The Commission highlights the need to develop non-discriminatory, open-access, cross-border CO₂ transport and storage infrastructure. The strategy proposes a comprehensive plan, with the ambition to develop a single market for CO₂ in Europe.

From 2024, the Commission will initiate preparatory work in view of a proposal for a possible future CO₂ transport regulatory package. It will also work towards proposing an EU-wide CO₂ transport infrastructure planning mechanism.

Finally, the possibility of creating an Important Project of Common European Interest around CO₂ transport and storage infrastructure will be explored with member states throughout 2024.

Room for improvement of the Industrial Carbon Management strategy

The definition of industrial CDR should be open to all safe and effective high-durability CDR methods. Currently, the ICMS unnecessarily restricts iCDR to solely DACCS, BECCS and biogenic carbon, failing to consider other promising methods, such as enhanced rock weathering.

Clear and quantifiable targets for the role industrial carbon removal should play to reach the EU 2040 target are necessary for at least two reasons. Firstly, to ensure the EU reaches durable net zero by 2050, namely a state where the remaining hard-to-abate fossil emissions are only compensated by high-durability carbon dioxide removal (CDR). Secondly, to provide visibility and predictability to the industry, considering that CDR must be scaled considerably across Europe. Furthermore, the fluidity and ambiguity between CCS, CCU and CDR should be addressed across the board and in future policy texts, clearly distinguishing each different role and climate benefits.

Clear and targeted support measures for scaling up CDR should be introduced. The current measures outlined for iCDR are a good first step, but they are not enough. Deployment incentives are essential in the scaling up of iCDR, bridging the gap between R&D funding and a potential integration into EU compliance markets.

To address these points, the European Commission should produce a strategy solely dedicated to CDR.