France has a climate neutrality target by 2050 set in law through Law 2019-1147 on Energy and Climate.

Note: climate neutrality is referred to as “carbon neutrality” in the law, even though the scope includes all GHG emissions.

In France, national intermediate targets are set through national carbon budgets, which are defined every five years through the National Low Carbon Strategy (Stratégie National Bas Carbone): 2014-2018, 2019-2023, 2024-2028, 2029-2030, 2034-2038, etc

Stemming from the EU Effort Sharing and LULUCF Regulation, France also has national targets for 2030 for sectors covered by the two regulations.

Under the European Climate Law, the EU as a whole must reduce its emissions by 55% by 2030. This commitment is reflected in the EU’s Nationally Determined Contribution to the Paris Agreement.

Note: France is expected to reach its 2030 ESR target only by a tiny margin. It is, however, at an increasing risk of not meeting the target due to an underperforming LULUCF sink.

The National Low Carbon Strategy sets the goal of achieving net zero emissions by 2050 and refers to the role of several CDR methods in doing so, including BECCS and land-based CDR methods. The strategy proposes greenhouse gas (GHG) emissions and removal projections for 2050 based on the expectation that France will emit roughly 80 million tonnes (Mt) of CO₂e, with GHG sinks taking up just over 80 Mt CO₂e each year (including general CCS in its sink consideration). The carbon budgets are directly based on this projection; therefore, even though it is not a target per se, it directly informs legally binding targets at the national level.

At EU level, France has a legally binding LULUCF target for 2030 through the EU LULUCF Regulation to deliver an additional net removal capacity of 6.7 MtCO₂ by 2030. Achieving this target would bring France’s total LULUCF CDR target for 2030 to 34.0 Mt/year.

There is only a legally binding LULUCF target for 2030 through the EU LULUCF Regulation, corresponding to a total of 34MtCO₂ of net removals per year in 2030.

The final updated NECP indicates that up to 1.2Mt of biogenic CO₂ might be captured and stored in 2030.

At the EU-level, the latest version of the European Climate Law states that the EU as a whole shall reach climate neutrality by 2050 and shall aim for net negative emissions thereafter, establishing the legal basis to introduce a quantified net negative target in the future. France does not have a net negative target in its domestic law, nor are there discussions around such a target.

Biomass sustainability

In its final updated NECP, France signals a big increase in biomass, primarily to produce bioenergy. In the long-term, it also plans to produce all the biomass it needs. While it recognises that biomass use could enter in conflict with food production, carbon sinks and use in products, it does not set clear measures to minimise these conflicts, other than referring to the sustainability criteria laid out in the EU Renewable Energy Directive. It does, however, acknowledge the need for more modelling to understand the trade-offs between biomass use and a decrease in the carbon sink capacities of forests.

Mitigation deterrence

Nothing found.

Note: Mitigation deterrence is explained in a separate report by Carbon Gap.

Like-for-like principle

Currently in France, most types of carbon credits can be used to compensate for some domestic fossil emissions. For example, emissions reduction and non-durable credits can be used by airlines to compensate for domestic flights in the country (as per Law 2021-1104), as well as coal combustion for energy production. This requirement means that, as it stands, the like-for-like principle is not met.

Note: The like-for-like principle is a precondition to reach a state of durable net-zero, in which all fossil GHG emissions are compensated by durable removals.

At the EU level, the Carbon Removals and Carbon Farming Regulation (CRCF), an EU-wide certification mechanism, entered into force in November 2024. Methodologies for each CDR method will be developed by the EU Commission, which will be applicable across EU member states.

At the domestic level, France already has a voluntary certification scheme through the Label Bas-Carbone, which only covers land-based removals and timber buildings. Furthermore, carbon removal is only one part of the scope of the Label Bas-Carbone, as it includes a broad range of practices. The methodologies recognised by the label need to be approved by the French Ecological Transition Ministry. Once methodologies are approved, individual projects apply and are certified by the French Government. Projects can then issue units, which are validated by the Government and verified by a third party. Certified units are then tracked on an official registry to prevent double-counting and cannot be further traded.

At the domestic level, climate claims are regulated both through the Label Bas-Carbone and Decree 2022-539.

The Label Bas-Carbone provides clear guidelines for external communication, including communication requirements for (i) different project phases; (ii) direct and indirect emissions reductions; and (iii) emissions reductions and carbon removal.

Decree 2022-539 from April 2022 relates to carbon offsetting and claims of carbon neutrality in advertising. It expands on these measures but does not address the issues of non-fungibility between emissions reductions and removals, the long-term and short-term carbon cycle, and the lack of clarity on what constitutes ‘residual emissions’. 

At the EU-level, the Green Claims Directive, combined with the Directive on Empowering Consumers for the Green Transition, is expected provide a comprehensive framework for climate-related claims, including what is defined as a compensation claim. 

Stemming from the EU Climate Law, only land-based removals from the LULUCF sector can be accounted for in France’s national inventory and be reported in France’s contribution towards the EU nationally determined contribution (NDC).

BECCS can be reported under ESR, 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. This would mean that Article 6 credits would be eligible to become CRCF units. For now, the EU’s NDC and its targets set in the European Climate Law are to be achieved only through domestic measures.

Domestically, France does not consider using Article 6 of the Paris Agreement.

(a) Legal framework covering key aspects

Legality of CO₂ transport and storage

The French legal framework for CO₂ transport and storage is a combination of national and EU legislation. It can be summarised as follows:

Liability for CO₂ storage

The EU CCS Directive has been transposed in French Law directly in the French Environmental Code in articles L.229-27 to L229-54 and R.229-57 to R.229-102. It covers several key aspects, including the permitting process for geological storage of CO₂ and the liability mechanisms in case of reversal. It covers the entire lifetime of the storage site. It also allows geological storage of CO₂.

The EU TEN-E Regulation sets out guidelines for cross-border energy infrastructure within the EU, including trans-border CO₂ infrastructure projects.

Finally, through the Industrial Carbon Management Strategy, the EU signalled the upcoming development of a dedicated regulatory package for CO₂ transport underway to cover remaining gaps in the CO₂ transport legal framework, including coordination between the many actors in the CCS value chain and standards for CO₂ purity.

France signalled in its CCUS Strategy that it will move ahead without waiting for the EU’s regulatory package on transport. France plans to develop a regulation on access to the capture and transport network to provide clarity and predictability on costs and conditions to access the network. A report is due at the end of 2024, which could lay the groundwork for this new legislation.

Environmental safety and remediation

The EU Environmental Liability Directive provides an EU-wide liability framework for environmental damages, including those induced by geological storage sites of CO₂. It was transposed into French law through the 2008-757 Act and the 2011-1411 Decree.

London Protocol

France should ratify the amendment to Article 6 of the London Protocol sometime in 2024, which allows countries to avoid the prohibition on transboundary transport of CO₂ for the purposes of sub-seabed geological storage.

In parallel, France has engaged on the issue of CO₂ transport and storage with several countries, including:

• Letter of intent with Denmark on CCUS and bilateral agreement on CO₂ export with Denmark
• Letter of intent with Norway on CCUS and high-level dialogue with Norway to facilitate strategic partnerships related to CCS
• France joined the North Sea Basin Task Force related to CCS in the North Sea region
• France, Italy and Greece cooperate on regional transborder CO₂ transport infrastructure development. This is part of a Mediterranean Carbon Capture and Storage Plan between the three countries.

In 2022, the EU Commission released guidance on how to understand the amendment to Article 6 of the London Protocol. It concluded that the EU CCS Directive and the EU ETS Directive acted as a sufficient arrangement between countries in the European Economic Area (EEA). Therefore, according to the Commission, there is no need for bilateral agreements to implement the amendment to Article 6 of the Protocol. Bilateral agreements could be concluded only on issues that are not covered by the two directives.

(b) Legal framework covering all types of CO₂

The EU ETS Directive only recognises fossil CO₂ under its scope, as it only puts a price on emissions of fossil CO₂.

The EU TEN-E Regulation does not explicitly recognise all types of CO₂, causing confusion regarding whether projects transporting and storing biogenic and atmospheric CO₂ can be labelled as Projects of Common Interest or not.

The French CCUS strategy defines the roles of fossil, atmospheric and biogenic CO₂.

Note: In the context of carbon management, there are three main types of CO2, depending on their sources: atmospheric, biogenic and fossil CO2. Atmospheric CO2 is generally sourced from direct air capture, biogenic CO2 from bio-energy with carbon capture and fossil CO2 by point-source carbon capture in industrial facilities burning fossil fuels. Legal frameworks must cover all types of CO2 to ensure equal access to CO2 transport and storage infrastructure.

(a) Physical storage capacities

Geological storage

Studies to assess geological storage capacities in France were launched in early 2024. EUR 25- 30 million under the funding programme ‘France 2030’ could also be dedicated to further studies, such as seismic campaigns and injection tests. A call for expressions of interest was also held in summer 2024 to identify stakeholders interested in being part of the CCUS value chain.

Mineral and product storage

There is an old study from 2004 which explored the potential for mineralisation in France. Since then, there have been no further plans to explore mineral storage capacity, nor storage in long-lived products

(b) Estimation of CO₂ storage needs

The national CCUS Strategy states that CCUS could reach 4 to 8.5MtCO₂/year by 2030 and between 30 and 50MtCO₂/year in 2050, including biogenic CO₂. The provisional National Low-carbon Strategy 3 projects 6.6MtCO₂ captured per year in 2030, 1.2Mt being biogenic and 5.4Mt fossil, with 10% used to produce e-fuels.

Ownership of infrastructure

France indicated in its CCUS strategy that public interventions might be needed to ensure an adequate repartition of costs and benefits throughout the whole CCS value chain. It also indicated that it would assess whether to regulate CO₂ transport further to avoid monopolistic market actors emerging, as well as to make access to CO₂ transport infrastructure a regulated model.

Cross-border cooperation

The framework for cross-border cooperation is set under the EU TEN-E Regulation through the Project of Common Interest (PCI) label. Cross-border projects that have been labelled as PCIs can apply for funding under the Connecting Europe Facility for Energy. Earning the PCI label can help projects reach a final investment decision, as the label adds a seal of assurance that the project is robust.

State support

Through the France 2030 plan, 'Industrial Low-Carbon Zones’ were created. As of now, four are operational while six new ones will be created soon. These zones were created to leverage economies of scale. They also receive public support to run strategic studies for new CCUS projects.

However, France does not plan to provide further support for CO₂ transport projects, beyond what is already provided by the French government and the EU.

Indication of capture and storage volumes

The EU Net Zero Industry Act (NZIA) set a mandatory injection capacity target of at least 50MtCO₂/year by 2030 in the EU.

In France, the search for storage sites needs a special exploration permit and the injection of CO₂ in a storage site needs a storage permit. Storage permits are delivered after a thorough process to ensure environmental and health safety.

Furthermore, CO₂ storage for climate mitigation purposes follows a special permitting process through section 2970 of the nomenclature of installations classified for environmental protection (ICPE in French).

Regarding injection trial projects, following decree n°2024-529, trials follow a case-by-case permitting process.

The permitting process is thoroughly detailed in articles L.229-27 to L229-54 of the French Environmental Code.

However, there are no clear approval timelines nor a platform dedicated to data sharing yet.

Carbon Gap led the creation of a country assessment report which showed what France could deploy for each relevant CDR methods. Yet this report is the only study to date that fully tackles the issue.

A study made by INRAE in 2020 explored the potential of soil carbon sequestration in France.

There is a very limited description of research gaps for CCUS in general in the French CCUS Strategy; despite some light research overlaps, there is no mention of CDR. There is no long-term plan for RD&I funding for CDR. The national alliance for the coordination of energy research (ANCRE in French) published a report on carbon sinks in October 2022, which identified the gaps various CDR methods were facing. It recommended to fund RD&I for CDR and develop demonstration projects.

CDR, especially higher-durability methods, is absent from the France 2030 funding programme, which aims to catalyse EUR 54 billion for investment by 2030.

The Priority Research Program and Equipment (PEPR) ‘Supporting innovation to develop new, largely decarbonized industrial processes’ (SPLEEN) has four tracks and supports 10 projects, 6 of which are related to CCS (EUR 70 million over six years). One of the six pertains to geological CO₂ storage, project Sesame.

EUR 50 million were attributed to research projects aiming to 1) ensure the resilience of forests 2) align supply and demand of wood products and 3) develop a shared governance of forests.

Besides forest management-related CDR methods, no funding has been allocated to CDR methods themselves so far.

Carbon contracts for difference (CCfDs) for CCS are going to be put in place. A public consultation to gather inputs on the CCfD structure started on 26 June 2024. The scheme should provide funding to projects over 15 years.

For now, the priority of this scheme will be on industrial residual emissions and traditional CCS (cement, chemical industry, steel, aluminium). There are signals that biogenic carbon capture might be supported by the scheme at a later stage.

Additionally, the Plan Relance attributed EUR 94 million in direct payments for farmers planting hedges around their fields.

Through France 2030, EUR 100-150 million per year have been allocated for reforestation until 2030.

The Forest Investment Tax Incentive Scheme provides a tax credit to incentivise good forest management practices and enhance the resilience of forests.

The EU Common Agricultural Policy sets up direct payments through ecoschemes aiming to support environmentally friendly practices. Some activities enhancing soil carbon sequestration are among the recognised practices.

The European Commission is due to publish a report by July 2026 examining the possible inclusion of CDR into the EU Emissions Trading System or another compliance regime.

France has not yet expressed its view on the matter.

Nationally, airlines need to compensate for the emissions released by domestic flights through emissions reductions or CDR projects.

Note: compensation of national flights should be changed to only allow for permanent CDR, in light of the like-for-like principle.

Nothing found.

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.

Some public consultations and calls for inputs around CCUS topics have been conducted/are being conducted, which is a good sign for what could happen with CDR projects. These consultations included:

• The CCUS strategy
• Future large projects for industrial decarbonisation
• Call for interest to develop geological storage capacities

Furthermore, the French government implemented the framework to hold 'regional COPs'. Through this process, local governments and communities in every French region are involved in creating regional roadmaps to reach France’s 2030 objectives.

The EU Just Transition Mechanism makes funding available for member states to support the green transition in territories most at risk from losing jobs due to the transition. In this context, six territories have been selected in France, which will get a total of EUR 1 billion. There are a few projects relevant for CDR. For example, in the north of France, a first round of requests for projects focused on seven areas of interest has been launched, including one on ‘CO₂: a new resource for new uses’. Most plans for the six regions mention CCUS as one of the new avenues for job creation and one mentions CDR as well (Régions Pays de la Loire – Pacte Cordemais).

Project Sesame, which was part of the Priority Research Program and Equipment (PEPR) ‘Supporting innovation to develop new, largely decarbonized industrial processes (SPLEEN)’, explores societal issues around CO₂ storage.