Since 2021, the EU has had a legally binding net-neutrality target for 2050 under the European Climate Law (ECL). Since the ECL is a Regulation, those targets are binding at EU level for all EU Member States.

As part of the ECL passed in 2021, a first binding interim target for 2030 has been enshrined, mandating the EU to cut net GHG emissions by at least 55% by 2030 (compared to a 1990 baseline).

The ECL also mandates the Commission to review the ECL and propose a second intermediate target for 2040. To that effect, the Commission formally put forward a proposal for a 2040 target in July 2025, aiming for a 90% net reduction in GHG emissions. As of October 2025, the 2040 target was still being debated among EU Member States and thus not yet enshrined in the European Climate Law.

The EU’s enshrined 2030 and 2050 targets, as well as the proposed 2040 target, are expressed in net terms, i.e. considering the result of accounting for both emissions reductions and removals. At this stage, the EU has not set indicative nor legally-binding separate targets for gross emissions reductions and removals respectively.

However, there is still a form of distinction between gross emissions reductions and removals for the intermediate 2030 target, as the ECL specifies in its article 4 that the contribution of net removals (regardless of their nature) cannot exceed 225 Mt of CO₂ equivalent. This binding rule thus de facto separates emissions reductions from removals objectives for 2030, without setting out legally enshrined figures.

Furthermore, the issue of twin targets is a growing point of political discussions around the establishment of a 2040 target, especially since the European Scientific Advisory Board on Climate Change (ESABCC) released a report on CDR in February 2025 whose first recommendation is to enshrine twin targets.

Through the revised Regulation on GHG emissions from land use, land use change and forestry (LULUCF Regulation), the EU has enshrined a target of 310 Mt CO₂eq per year for the sectors of land use and forestry at Union level, with binding national contributions. This regulation effectively creates a non-durable CDR target under the EU-wide 2030 target (-55% in net emissions compared to 1990). To avoid excessive reliance on non-durable CDR from the LULUCF sector to achieve the 2030 target, a maximum CDR contribution of 225 Mt CO₂eq from this sector has been enshrined in the European Climate Law.

However, there is no dedicated, binding target for more permanent CDR methods enshrined in EU law. The Commission’s 5 Mt CO₂ by 2030 for industrial removals expressed in the 2021 Communication on Sustainable Carbon Cycles is only aspirational.

The EU Climate Law does not set a fixed net-negative emissions target year or volume. However, it explicitly states that after 2050 the EU shall aim to achieve negative emissions. This formulation, while not effectively binding, does commit the EU to continue lowering atmospheric CO₂ beyond the net-neutrality point.

Biomass sustainability

Sustainability criteria for biomass are set out at EU level through the latest iteration of the Renewable Energy Directive (RED III), which proposes a detailed framework for sustainability and greenhouse gas (GHG) emissions savings criteria for any biomass used for energy purposes. As such, those criteria also apply for bio-CSS installations that require biomass feedstock, and condition eligibility to potential support schemes.

This directive also details the “cascading principle” for woody biomass use (i.e. establishing a prioritisation of biomass use based on a hierarchy of best economic and environmental value), pushing Member States to design financial incentives in a way that avoids encouraging the use of high-quality woody biomass for energy if it can be used for higher-value material purposes. Thus, preference is given to using residues, by-products and wastes for bioenergy (and by extension bio-CCS facilities).

Mitigation deterrence

The EU has an important binding legislation to limit mitigation deterrence - under the Climate Law, the contribution of removals to the 2030 net emissions target is limited to 225 MtCO₂e to ensure “sufficient mitigation efforts” are being undertaken towards the -55% net emissions target. This cap is binding regardless of the volumes of CDR achieved in the EU. This separation is especially clear for the LULUCF sink, which has its own, independent target for 2030 of achieving 310 MtCO₂e of removals, enshrined in the LULUCF Regulation, and thus avoids the EU’s “over-reliance” on the LULUCF sink in achieving the 2030 target.

However, there is no clear and automatic mechanism to prevent mitigation deterrence in EU policies directly or indirectly related to CDR, especially for permanent, engineered CDR, which is thus at risk of being conflated with decarbonisation efforts in some instances. As of October 2025, the negotiations on the establishment of an intermediary target for 2040 seemed to develop in the wrong direction, heading towards enshrining only a net target, without separation of removals.

Finally, the EU’s net-neutrality objective by 2050, at the core of the ECL, is also presented as a net target, without separate objectives for removals. The absence of such guardrails for the 2050 and potentially for the 2040 objectives puts a significant risk on the achievement of gross emissions reduction objectives. Indeed, as the EU approaches the point of net-zero, the scaling-up of removals and increasing abatement cost for remaining emissions will increase the pressure to engage in mitigation deterrence practices.

Like-for-like principle

The Carbon Removals and Carbon Farming Regulation (CRCF) sets out an elementary CDR durability taxonomy, by establishing distinct kinds of certified units for permanent carbon removals (storage for several centuries in geological / terrestrial / oceanic reservoirs) and for carbon farming activities (short-term carbon storage in the biosphere). The CRCF also states that these types of units “shall remain distinct from one another”.

However, the CRCF text falls short of establishing clear, differentiated uses for each type of unit, and guardrails to prevent the misuse of units (e.g. the use of a carbon farming unit to compensate for a fossil emission).

The CRCF, an EU-wide certification mechanism intending to become the first public, international and independent certification scheme for emissions reductions, carbon farming and permanent CDR activities, entered into force in November 2024. It intends to develop certification methodologies that guarantee the quality of CDR activities certified, based on accurate quantification, proven additionality, long-term storage and liability, and explicit sustainability criteria.

Certification methodologies for each CDR method are under development by the EU Commission, with the assistance of the Expert Group on Carbon Removals, and will be applicable across EU Member States.

Concerning MRV and liability rules, the CRCF clearly states that certification methodologies must either enforce the storage standards of the CCS Directive (for CDR methods integrating a CCS component), or provide MRV guarantees of similar stringency as those of the CCS Directive (for all other CDR methods).

The EU passed in 2024 the Empowering Consumers for the Green Transition Directive, amending the 2005 Unfair Commercial Practices Directive and the 2011 Consumer Rights Directive. Empowering Consumers creates certain guardrails against some forms of greenwashing and malpractice regarding climate claims in business-to-consumer marketing across the EU. Namely, this directive enshrines a ban on “neutrality” claims based on carbon credits at product level (e.g. purchasing or offering the consumer to purchase carbon credits to compensate for the carbon footprint of a plane trip). The directive also restricts the use of generic vocabulary for environmental and climate claims (e.g. “climate friendly”, “eco-friendly”, etc.) when no proof is given of “recognised excellent environmental performance” relevant to the claim. This Directive must be transposed into the domestic law of EU Member States by March 27 2026, and its rules will apply from September 27 2026.

While the Empowering Consumers Directive establishes guardrails against some of the most misleading forms of climate claims, it doesn’t constitute a comprehensive framework to regulate climate claims at EU level. The However, as of October 2025 the Green Claims Directive proposal had not been voted into law. The proposed directive is now unlikely to ever enter into force, after losing strategic political support in both the European Parliament and the European Council, and wavering support from the European Commission itself.

The EU Climate Law stipulates that only land-based removals from the LULUCF sector can be accounted for in a Member State’s national inventory and be reported in this State’s contribution towards the EU nationally determined contribution (NDC) – as EU Member States do not submit individual NDCs but rather one “aggregated” NDC.

BECCS can be reported under the Effort Sharing Regulation but not accounted for towards national emissions targets set by the Regulation, as per new guidelines by the European Commission.

Furthermore, the CRCF states that all certified units should count towards the EU’s NDC. However, inclusion in the NDC might not take place prior to the publication of the IPCC’s methodology report in 2027, which will provide guidance as to how durable CDR should be accounted for.

The CRCF states that by 31 July 2026, the Commission needs to assess whether the CRCF and Article 6 of the Paris Agreement could be aligned, meaning that Article 6 credits would be eligible to become CRCF units. For now, the EU NDC and its targets do not recognise Article 6 credits.

However, in July 2025, the European Commission published a long-awaited proposal for a revision of the European Climate Law to introduce an intermediary target for 2040, aiming for a 90% reduction in net emissions compared to 1990. This proposal, under negotiation between EU institutions as of October 2025, includes several flexibilities for Member States, including a possible limited contribution (3-5% of 1990 EU emissions) of international carbon credits under Article 6 of the Paris Agreement. If agreed, this flexibility would change the role of Article 6 in the EU’s climate strategy in a post-2030 timeline.

Note: The assessment of this indicator does not take into account the aforementioned ongoing policy debates around the EU 2040 climate target, and may be revised if the agreed 2040 target creates uncertainty on the use of Article 6 credits.

(a) Legal framework covering key aspects

Legality of CO₂ transport and storage

Since 2009, The CCS Directive has established the legal framework for the environmentally safe geological storage of CO₂ across the EU. It covers site selection, permitting, monitoring, closure, and post-closure obligations, including transfer of responsibility to competent authorities.

The ETS Directive recognises captured and stored fossil CO₂ as emissions not released, provided operators comply with monitoring and verification requirements. This stipulation ensures that permanent storage is integrated into the EU-ETS.

The Commission signalled in its Industrial Carbon Management Strategy, adopted in February 2024, its intention to further develop a dedicated legislative package for CO₂ transport infrastructure, including rules on open access, coordination between operators, and common standards for CO₂ quality and purity. Public consultations for this legislative package were held during the summer of 2025, in view of a formal proposal from the Commission.

Additionally, the TEN-E Regulation now explicitly includes CO₂ transport and storage infrastructure as eligible categories for (PCI/PMI), granting them access to EU permitting streamlining and Connecting Europe Facility (CEF) funding.

Liability for CO₂ storage

The CCS Directive requires operators to provide financial security for the entire lifecycle of a storage site, including corrective measures and post-closure responsibilities. After closure and a minimum monitoring period, responsibility for the site is transferred to the Member State authority, but liability provisions ensure long-term safety.

The Environmental Liability Directive establishes an EU-wide liability regime for environmental damage and also applies to damages resulting from geological storage activities. This directive provides a harmonised backstop on remediation and responsibility.

London Protocol

The 2009 amendment to Article 6 of the London Protocol, allowing export of CO₂ streams for sub-seabed storage, has not yet been ratified by some - but not all - EU Member States.

In 2019, Parties adopted a resolution allowing provisional application of the 2009 amendment, enabling bilateral agreements to authorise cross-border CO₂ transport and storage. The Commission has supported this resolution and encourages Member States to use it, while considering that the ETS and CCS Directives conjointly provide a de facto sufficient framework for cross-border CO₂ shipments in the EU-EEA.

(b) Legal framework covering all types of CO₂

The CCS Directive is feedstock-neutral: it covers geological storage of CO₂ regardless of origin, provided the stream meets purity and safety criteria (Article 12(1)), thus enabling storage of fossil, biogenic, and atmospheric CO₂.

The EU ETS Directive, however, currently only accounts for fossil CO₂ emissions avoided through capture and storage, meaning biogenic and atmospheric CO₂ removals (e.g., from BECCS or DACCS) are not yet integrated in the framework.

The TEN-E Regulation includes CO₂ infrastructure as eligible for PCI/PMI status but does not yet provide explicit clarity on whether biogenic and atmospheric CO₂ transport/storage projects can benefit on equal footing with fossil CO₂ projects.

The Industrial Carbon Management Strategy highlighted this gap and announced forthcoming work on the treatment of non-fossil CO₂ streams, with the aim of ensuring that regulatory and infrastructure frameworks support the full range of carbon management technologies, including permanent carbon removals.

Geological storage

Europe possesses significant geological CO₂ storage potential, which is still being formally mapped out and quantified.

The EU’s Joint Research Centre (JRC) has contributed to the first EU CO₂ storage atlas, CO2StoP, elaborated in partnership with European Geological Surveys in 2012-2013. The JRC has since then advocated for an updated and comprehensive European CO₂ storage atlas, and underscored in a 2024 analysis that such an undertaking is necessary to achieve the EU’s CO₂ storage targets.

Independent estimates put Europe’s effective CO₂ storage capacity in the hundreds of gigatonnes (e.g. on the order of 260 Gt in a 2022 study), although a study of global storage capacity estimates published in 2025 offers more prudent figures.

When it comes to offshore geological storage, the North Sea region in particular displays significant potential, through storage in depleted oil and gas reservoirs and saline aquifers. Multiple large-scale storage projects are being developed in this region, starting with the Norwegian Northern Lights project, which has received the label of Project of Common Interest (PCI) from the EU.

Operationalising this storage potential is a key objective at EU level, namely through the Net-Zero Industry Act (NZIA), which has set a binding target of 50 Mt per year of CO₂ injection capacity by 2030, pushing Member States and operators to develop storage sites.

Mineral and product storage

The EU also acknowledges storage of CO₂ in mineralised form or in long-lived products – the latter constitutes a specific category of carbon storage to be certified under the CRCF Regulation. However, these avenues remain at an earlier stage of quantification. CDE methods relying on mineralisation, like CO₂ mineralisation in cement, concrete, or mine tailings and the production of long-lasting carbon-based material, can under some conditions receive funding from EU programmes, specifically under Horizon Europe, with possible additional support from Member State-specific programmes. Mineralisation pilots are underway in the EU but without a comprehensive quantification of their potential as of yet.

(a) Ownership and open-access infrastructure

While practicalities on ownership of infrastructure are handled at the Member State level, EU policy encourages critical CO₂ transport and storage infrastructure to operate as open-access utilities. The CCS Directive obliges Member States to enable third-party access to transport and storage facilities for CO₂ on transparent and fair terms, where there is available capacity. In practice, this detail means a new DACCS or BECCS operator should be able to connect to existing CO₂ pipelines or storage, and incumbents cannot unjustly refuse service. While detailed EU regulations on CO₂ network tariffs and access conditions are forthcoming, the principle is technically enshrined in law. As such, flagship EU-funded CO₂ transportation projects (e.g. the Porthos project in Rotterdam) have been structured as open-access from the start, with multiple companies sharing transport/storage capacity.

Moreover, many strategic CO₂ pipelines and storage hubs have direct government participation (via state-owned energy or development companies) to guarantee third-party access and prevent monopolization. The EU’s Connecting Europe Facility (CEF) funding for CO₂ projects comes with conditions that projects serve broad European interests, effectively discouraging single-user pipelines.

(b) Public support and funding mechanisms

The primary funding vehicle for CO₂ transport infrastructure is the Connecting Europe Facility (CEF), especially for PCI/PMI projects. CEF-Energy funding is available for two main types of activities: studies contributing to the preparation of the implementation of a PMI/PCI (preparatory, mapping, feasibility, evaluation, testing and validation studies); and works contributing to the implementation of a PMI/PCI (purchase, supply and deployment of components, systems and services including software, the development, construction and installation activities relating to the eligible infrastructure items of a PCI/ PMI, the acceptance of installations and the launching of a project).

Additionally, the EU Innovation Fund has already allocated some resources to support carbon capture, transport, and storage projects.

Finally, the EU’s guidelines on State aid for climate, environmental protection and energy (CEEAG) were updated in 2022 to broaden support for CCUS infrastructure, and a comprehensive Clean Industrial State Aid Framework (CISAF), adopted by the Commission in June 2025, provides flexibility for governments to fund CO₂ networks, enabling national state support schemes, resulting in possibilities for CO₂ transport and storage or CDR projects to blend national and EU funding to de-risk their operations.

(c) Cross-border coordination and networks

Under the TEN-E Regulation, cross-border CO₂ pipelines and storage sites can receive Project of Common Interest (PCI) or Project of Mutual Interest (PMI) status, streamlining permits and unlocking funding for multinational projects. The EU’s PCI lists now include several CO₂ network projects connecting hubs in Northwest Europe (e.g. Belgium–Netherlands–Germany pipeline links and North Sea storage with Norway).

(d) Signaling of CO₂ capture and storage volumes

The EU provides several signals on expected CO₂ storage volumes needed in coming decades. The NZIA’s 50 Mt per year storage capacity target by 2030, while encompassing all expected CO₂ storage needs and not only those of CDR, is a significant demand signal to accelerate the constitution fo a market for substantial storage services.

While non-legally binding, several scenarios and indicative targets for CO₂ capture and storage have been put forward in theEuropean Commission’s communication on an Industrial Carbon Management Strategy. It projects, based on the 2040 targets impact assessment scenarios, that approximately 280 Mt CO₂ would have to be captured by 2040, and 450 Mt CO₂ by 2050, with removals (through biogenic CO₂ capture and DAC) representing 40% of the volume captured in 2040 and over 50% by 2050.

Under the revised TEN-E Regulation, cross-border CO₂ network projects designated as Projects of Common Interest benefit from an expedited permitting process – a one-stop shop and binding time limits for decisions by authorities. This accelerated process helps prevent undue delays for important CO₂ pipeline and storage projects. Furthermore, the upcoming CO₂ transport infrastructure legislative proposal is expected to further clarify permitting responsibilities between countries, establish common standards (e.g. for CO₂ purity and measurement), and improve data-sharing about pipeline operations. In the meantime, many Member States coordinate permits domestically (often bundling approvals for complex projects), and the EU monitors the implementation to ensure transparency and public access to information, in line with the Environmental Impact Assessment Directive and Aarhus Regulation.

The CCS Directive mandates detailed site characterisation, risk assessment, and corrective measures as part of any storage permit application. Operators must demonstrate they can monitor and control the site, and they are financially liable for any leakage or environmental harm until a site is sealed and handed over to the state (with a post-closure monitoring period of at least 20 years, unless extended). Permits come with conditions on continuous monitoring, leak detection, and periodic reporting to regulators. National competent authorities, supervised by the Commission, ensure that these conditions are met and can suspend operations if safety is compromised.

In 2025, The European Scientific Advisory Board on Climate Change (ESABCC) released a report on CDR, in which it provides some estimates of deployment potential for various CDR methods, underlining the significant knowledge gaps remaining, thereby preventing a full evaluation of the EU’s CDR potential.

Regarding biomass availability for CDR, the ESABCC emphasises that while the EU has significant biomass resources (forestry residues, agricultural waste, organic municipal waste), current and future demand for those resources already match or exceed supply, leading to competing uses. Imports of biomass (e.g. wood pellets) supplement EU supply but are subject to strict sustainability criteria under the Renewable Energy Directive.

No specific EU-wide assessment of future renewable energy needs for CDR has been officially undertaken.

However, the EU’s renewable energy targets do position it as one of the world leaders in added renewable energy capacity, and the Commission’s new industrial policy, the Clean Industrial Deal, published in February 2025, informs on the future measures to be undertaken by the EU to facilitate renewable energy access for emerging clean technologies, including CDR. In particular, the Deal calls for accelerated permitting of renewable projects, aiming for 100 GW of new renewable energy capacity installed each year in the EU by 2030.

The EU does not have a dedicated RD&I roadmap for CDR. Rather, CDR, and some elements of its value chain often common with CCS, is included in wider RD&I programmes focusing on cleantech and industrial carbon management.

In December 2021, the European Commission published the Sustainable Carbon Cycles communication, outlining the EU’s vision for a future circular economy of carbon, and presenting a phased approach to develop the industrial capture, use and storage or carbon; (1) focus on research, innovation, and establishing initial regulatory frameworks (such as the certification mechanism) in the 2020s; (2) scaling up demonstration projects and start integrating removals into markets in the 2030s; (3)deployment of mature CDR methods at climate-relevant scale by 2050. This communication also outlines the first indicative industrial CDR targets at EU level: 5Mt CO₂ eq by 2030, and up to 200 Mt CO₂eq by 2050.

This communication, which was followed through by the Industrial Carbon Management Strategy in 2024, explicitly calls out the need for R&D to reduce costs and improve the maturity of CCS and CCU technologies, with some calls focused on scaling some industrial CDR methods. To that end, it specifies that the Horizon Europe research programme (2021-2027) contains calls aimed at fostering innovation into CO₂ capture, accelerating the development of CCUS industrial clusters, and other calls covering CO₂ transport and storage, BECCS and DACCS.

Additionally, and while not CDR-specific, the Strategic Energy Technology (SET) Plan also tackles carbon capture and storage as an area of focus, indirectly guiding research agendas.

Regarding the identification of research gaps for CDR, in 2024, the European Commission published a report on R&I for climate neutrality by 2050. Although not CDR-specific nor necessarily comprehensive, this report outlines critical areas in which further research is needed to accelerate CDR scale-up. To facilitate the perception of CDR research gaps by all stakeholders in the CDR sector, Carbon Gap has launched in 2025 a dynamic CDR research gaps database.

While the EU hasn’t established a standalone programme to fund RD&I for CDR, existing programmes often include CDR and offer funding dedicated to specific CDR methods.

Horizon Europe Cluster 5, for example, lists several CDR methods relying on carbon capture and storage, such as DACCS (HORIZON-CL5-2026-02-D3-24) and carbon storage in products as areas of intervention, meaning research proposals in those areas can secure EU grants. Similarly, the LIFE programme, the EU’s funding instrument for the environment and climate action, has funded pilot projects on peatland restoration and agroforestry that, although framed as conservation, also contribute to carbon removal.

In parallel, the Innovation Fund, initially created to support innovative low-carbon technologies, has broadened its scope to include negative emissions. In its 2022 and 2023 calls, the Fund awarded grants to BECCS and DACCS projects – effectively directing some capital for CDR RD&I.

As of 2025, the EU is at the early stages of developing deployment incentives for permanent CDR, Whilst many of these incentives include a fiscal aspect, which makes it the competence of Member States, the EU is considering different options for alternative deployment incentives. As part of the latest revision of the ETS Directive, CCfDs were mentioned as an avenue to support the development of low-carbon technologies, including CCS, through the Innovation Fund.

The release of the Clean Industrial Deal communication by the Commission in 2025 may indicate a renewed impulse to develop EU-level deployment incentives for CDR. Namely, the Commission aims to mobilise up to €100 billion for a new Industrial Decarbonisation Bank, to unlock access to public financing for key projects for the green industrial transition in the EU. While the future IDB’s mandate is not yet established, it could include CDR methods relying on industrial processes.

Furthermore, the Commission is also increasingly considering a purchasing programme for CRCF permanent CDR credits, and in August 2025 has released studies commissioned to Ramboll and Ecologic outlining policy options and recommendations for designing such a purchasing programme to support near-term CDR scale-up. The likely short-term blueprint (2025–2030) is to establish an EU Removals Fund combined with a buyers’ club (both public and private), which could begin procuring durable CDR credits to jump-start the market.

The EU’s Common Agricultural Policy provides the main incentives for land-based carbon sequestration. In the 2023–2027 CAP strategic plans, Member States have included eco-schemes and agri-environmental measures that pay farmers for practices like cover cropping, conservation tillage, agroforestry, and restoring peatlands – all of which increase soil or biomass carbon. While these programmes are usually framed in terms of sustainable farming and ecosystem benefits - rather than being referred to as carbon farming or carbon removal - they effectively subsidise activities that remove CO₂.

The EU also continues to fund afforestation and reforestation through the European Agricultural Fund for Rural Development (part of the CAP), with support for establishing new forests or restoring degraded ones.

In addition, the EU Forest Strategy for 2030 and the Nature Restoration Regulation set targets for enlarging and improving carbon-rich ecosystems (e.g. wetlands) – backed by EU funds such as the LIFE Programme.

Despite these incentives, there is still insufficient coordination and funding across the EU to achieve the 2030 target of the EU LULUCF Regulation of 310 Mt of less durable CDR, underscoring the need for more efficient and comprehensive support mechanisms for these types of activities. The newly established CRCF will soon allow for the certification of carbon farming activities in the EU and provide a framework for additional financial support to these activities. But as things stand, the sole existence of the CRCF framework does not guarantee increased financial flows towards activities delivering less durable CDR and thus falls short of constituting a bespoke deployment incentive.

The EU is considering how CDR might enter EU compliance markets. The Commission is due to publish a report by July 2026 examining options for including permanent CDR either in the EU Emissions Trading System or through a dedicated obligation/separate trading scheme. This assessment will consider technical issues (MRV reliability, permanence guarantees) and market design (whether to create CDR credits fungible with ETS allowances or to establish a parallel quota for removals). It will also determine the relevant timeframe for the potential inclusion of permanent CDR credits in the ETS. The most likely scenario as of 2025 is that such inclusion would happen in the post-2030 period and with strict quality criteria (i.e. restricted to permanent CDR credits under the CRCF).

For sectors outside the EU ETS (e.g. most of transport, buildings until 2027, agriculture, smaller industries), the EU relies on two regulations: the Effort Sharing Regulation (ESR) and the LULUCF Regulation. The former sets binding emissions reduction targets to each Member State for sectors outside of the ETS (transport, buildings, non-CO₂ agriculture emissions, waste), leaving policy decisions to national discretion. The latter covers emissions and removals from the land-use sector (forests, soils, biomass, land use changes).

Despite the EU having not imposed a uniform carbon pricing measure on non-ETS sectors EU-wide, the ESR has incentivised many Member States to implement carbon taxes or levies in these sectors to meet their targets – for example, carbon taxes on heating fuels or a price on emissions from waste incineration.

Upcoming policy developments in EU carbon pricing are expected to transform the carbon pricing framework for many non-ETS sectors. First, the revision of the EU ETS in 2026 may lead to the inclusion of municipal waste within its scope. Second, a separate Emissions Trading System for road transport and buildings, (often called “ETS2”) will commence in 2027. This system will cap and reduce emissions from fuels used in these sectors across all Member States and effectively put a price on those CO₂ emissions at the EU level. Thus, by 2027, a large portion of previously uncapped emissions will face a price signal EU-wide. While ETS2 covers a huge chunk of the “non-ETS” emissions, some will remain outside of this new system – notably, agricultural and land-use emissions are still handled via targets set out under the ESR and LULUCF Regulations, rather than direct pricing.

Besides the sectors covered by the EU-ETS, there is no other sector-wide carbon pricing measure in France.

However, there is a sort of carbon tax for emissions from tourist cars. This system is based on a 'bonus/malus’ system, where well-performing cars are rewarded and bad performing ones are taxed. Such a system is also in place regarding the weight of any private vehicles, where heavier vehicles are more taxed.

All EU laws follow a similar public participation and consultation process, embodied in the Commission’s “Better regulation agenda” for improved EU lawmaking. One of this agenda’s principles is ensuring the contribution of citizens and stakeholders to the lawmaking process through stakeholders’ consultations, online public consultations, implementation dialogues, and feedback mechanisms to Commission calls for evidence and acts. On key technical issues where continued stakeholder input is instrumental for accurate policy design, the EU can establish expert groups, which is notably the case on CDR, where the development of the CRCF was accompanied by the creation of the Expert Group on Carbon Removals, comprised of specialists from various fields involved in drafting the implementing acts to the certification framework.

Beyond formal consultations, the EU has set up forums to involve stakeholders in CDR governance. One important platform is the Industrial Carbon Management Forum (ICM Forum), which meets annually and includes approximately 500 stakeholders – Member State officials, EU institutions, industries, NGOs, and scientists – to discuss CCUS and carbon removal deployment.

When it comes to specific CDR projects (e.g. CO₂ storage sites, pipelines, BECCS plants), the EU’s environmental legislation mandates local public participation. The Environmental Impact Assessment (EIA) Directive requires that projects like large CO₂ transport pipelines or storage facilities undergo an EIA process with disclosure of information and a public comment period before any approval is granted. Additionally, the Aarhus Regulation ensures that environmental NGOs can request an internal review of EU decisions related to the environment, which could include CDR-related authorisations by EU bodies.

The EU’s flagship tool to ensure fairness in the climate transition is the Just Transition Mechanism (JTM), which includes a €17.5 billion Just Transition Fund (JTF) for 2021–2027. While not CDR-specific, this mechanism provides support to regions and communities disproportionately affected by decarbonisation policies, helping to prevent social inequities. For example, regions with declining coal mining or other high-emitting industries can receive funding for projects supporting job creation and industrial development. Therefore, areas transitioning away from high-emitting industries might benefit from JTF money to develop CDR projects (CO₂ storage hubs, DAC facilities, etc) as new economic opportunities.

Beyond the JTM, the EU encourages Member States to use carbon pricing revenues, namely from the EU ETS, to alleviate burdens on vulnerable groups and to fund climate action, but without direct control over the Member States’ choices in that regard.

Additionally, the new Social Climate Fund, funded by ETS2 revenues, will provide over €70 billion to cushion the impact of the fuel price on poorer households, ensuring the carbon price for buildings/transport doesn’t impose undue hardship. While these measures are not targeted at CDR specifically, they represent a framework where the costs of climate measures are partly redistributed to foster equity.

While evidence on significant EU funding towards research into social and ethical dimensions of CDR is limited, there are a few instances of such effort. Under Horizon Europe, several calls for projects explicitly require the examination of the social aspects of CDR. The Commission has also integrated “social sciences and humanities” (SSH) into climate research calls, ensuring that each climate innovation project (including those on CDR) assesses potential societal impacts.