As part of delivering on the aims of the legislation, the TEN-E regulation also outlines the process for selecting projects of common interests (PCIs). PCI are infrastructure projects recognised as essential to meeting the EU’s energy objectives, including greater competitiveness and improved interconnection between national markets. The revision of the regulation in 2022 introduced another category of projects entitled Projects of Mutual Interest (PMIs), which concern projects that involve at least one third country whilst bringing significant benefits to at least two EU member states. The PCI/PMI status is important since it makes projects eligible for funding under the Connecting Europe Facility for Energy (CEF). 

The TEN-E Regulation is significant for carbon removal since it identifies cross-border CO₂ networks as a priority thematic area. This type of infrastructure involving CO₂ transport and storage is needed for some CDR methods, such as direct air carbon capture and storage (DACCS) and bioenergy with carbon capture and storage (BECCS). By enabling the construction of CO₂ networks, the TEN-E Regulation and the CEF are therefore key to building a CO₂ value chain for some CDR methods.  

Projects of Common and Mutual Interest  

The main feature of the TEN-E Regulation is the designation of trans-border energy projects as “Projects of Common/Mutual Interest” (PCI/PMI). Projects granted such status by the European Commission benefit from a streamlined permit-granting procedure, with their development facilitated by member states. While the absolute number of PCIs has been declining over time, especially when it comes to natural gas, the number of CO2 infrastructure projects granted PCI/PMI status has been steeply increasing. While this surge of CO₂ network projects is promising, most PCIs are concentrated around the North Sea region. Some countries, mostly in Central and Eastern Europe, are not involved in any PCIs related to CO₂ networks, including Estonia, Romania, Austria, Malta, Slovakia, the Czech Republic, and Portugal. Moreover, several large emitting countries like France, Italy, Poland and Spain are underrepresented in the PCI list compared to their relative and absolute emissions. For a truly European-wide CO₂ network to be developed, these member states could better incentivise the development of national and cross-border CO₂ infrastructure. 

To date, two CO₂ storage projects have been granted PMI status, the 6th PCI list being the first one to officially grant projects the status as PMI since the revised TEN-E Regulation entered into force. The two projects are located in the North Sea area, with Norway being the final storage destination. 

The Connecting Europe Facility 

The Connecting Europe Facility (CEF) Regulation reserved a budget of EUR 5.84 billion for TEN-E projects for the period 2021-2027, focusing on projects with the PCI or PMI designation. The EU has allocated funding that can be provided for various project stages, including feasibility studies and construction; more than 640 million has been awarded for CO₂ infrastructure projects between 2022 and 2023.  

What to improve 

Through the TEN-E Regulation, the EU is addressing a key issue for the scaling up of EU-wide CDR capacities: the need for sufficient trans-border CO₂ networks. When combined with the Net Zero Industry Act’s CO₂ storage target of 50 Mt by 2030 and the measures that will follow the Industrial Carbon Management Communication, it is clear that the EU is taking steps to address the need for a significant scale-up in the availability and capacity of CO₂ networks in Europe.

Future revisions of the TEN-E Regulation should consider several points. Firstly, the scope of the regulation should be made tech-neutral. Currently, CO₂ networks are defined as infrastructure for CO2 “captured from industrial installations for the purpose of geological storage as well as carbon dioxide utilisation for synthetic fuel gases leading to the permanent neutralisation of carbon dioxide”. Depending on the interpretation of this definition, infrastructure moving atmospherically and biogenically-sourced CO₂ would not be eligible for the PCI status. This ambiguity should be addressed to make it possible for all types of removed carbon to have free and equal access to CO₂ infrastructure. Moreover, the regulation should clearly acknowledge the role of industrial CDR as part of industrial carbon management. Such recognition would be aligned with the target for carbon removal introduced in the 2040 target communication, and with the role foreseen for industrial CDR in the Industrial Carbon Management communication. Finally, the TEN-E Regulation and other EU laws related to CO₂ transport and storage, namely the ETS Directive, the Industrial Emissions Directive and the CCS Directive, should be better integrated. Issues such as CO₂ transport by other means than pipelines and CO₂ quality standards should be harmonised within these laws.