The Federal Climate Protection Act enshrines a target for net greenhouse gas (GHG) neutrality in 2045, i.e. the creation of a balance between anthropogenic GHG emissions and removals, and negative GHG emissions after 2050, i.e. more removals than emissions. As such, Germany has committed to using CDR. The Act does not provide a clear definition of removals, however, the key points document on the long-term negative emissions strategy highlights the definition of the IPCC AR6 Working Group III report, which states that “CDR refers to anthropogenic activities that remove CO₂ from the atmosphere and store it durably in geological, terrestrial, or ocean reservoirs, or in products”.

The Federal Climate Protection Act establishes GHG reduction targets of 65% by 2030 and 88% by 2040, compared with a 1990 baseline.

Furthermore, the long-term negative emissions strategy proposes the development of specific negative emissions targets for technical carbon sinks for 2035, 2040 and 2045.

Flowing from requirements set out in the EU Effort Sharing Regulation (ESR) and LULUCF Regulation, Germany also has national targets for 2030 for those sectors that are covered by the two regulations. However, studies and reporting in 2024 found that Germany risks falling short of its 2030 ESR target due to inadequate progress in the buildings and transport sectors.

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.

German climate law does not enshrine specific targets for gross emissions and gross removals. However, under its long-term negative emissions strategy, Germany is expected to introduce separate targets for technical sinks for 2035, 2040 and 2045. These separate targets would complement the already-existing binding targets for LULUCF sinks under the Federal Climate Protection Act.

The evaluation report on the Carbon Dioxide Storage Act that reviewed studies on the German net zero transition estimated that Germany’s CDR needs equal 45-80 Mt/year (including technical and LULUCF removals) if the country is to achieve GHG neutrality by 2045.

Germany has a legally binding LULUCF target for 2030 through the EU LULUCF Regulation to deliver an additional net removal capacity of 3.7 MtCO₂ by 2030. Achieving this target would bring Germany’s total LULUCF CDR target for 2030 to 30.1 Mt/year.

The Federal Climate Protection Act sets binding targets for CDR from land use, land use change and forestry (LULUCF) of at least 35 MtCO₂e by 2040 and at least 40 MtCO₂e by 2045. These targets are echoed in the key points of the upcoming negative emissions strategy.

Specific targets for “technical sinks” are mentioned in the Federal Climate Protection Act and are proposed as one of the key points in the upcoming negative emissions strategy. Technical removals are also part of Germany’s long-term strategy to offset unavoidable residual emissions and subsequently remove more greenhouse gases from the atmosphere than it emits. The long-term strategy emphasises the need for investment in CDR technologies as a prerequisite for Germany’s climate neutrality in 2045.

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.

The Federal Climate Protection Act states that negative GHG emissions will be achieved after 2050, i.e. a state where Germany removes more carbon from the atmosphere than it emits. The long-term negative emissions strategy also plans to establish the expected role of negative emissions (namely from technical sinks) up to 2060.

Biomass sustainability

Germany is developing a National Biomass Strategy to address key topics related to sustainable biomass, nature protection, climate action and food security. In 2022, a document outlining the key points of the strategy was published. The strategy will operate at the political, strategic, and operational levels – including identifying areas and sectors where biomass can be used, taking into account the use in technical CDR, as well as setting out clear incentives, disincentives and regulations for biomass use.

Mitigation deterrence

Regarding mitigation deterrence, the key points of the long-term negative emissions strategy emphasise the need for deep and rapid reductions in Germany’s emissions, which remains the ultimate priority for the country’s climate strategy. The strategy highlights that the appropriate development of “needs-based” CDR must happen alongside a robust framework for emissions reduction.

In addition, the document outlining key points for the carbon management strategy states that funding for the development of carbon capture and storage or utilisation (CCS/U) will focus only on hard-to-abate industrial and waste management-related emissions and power generation from bioenergy. Public funding will not be granted to CCS/U projects for power plants that run on fossil fuel combustion and access to CO₂ pipelines will not be enabled for fossil power plants.

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

Like-for-like principle

Regarding the like-for-like principle, the negative emissions strategy key points document defines negative emissions as involving storage that is as permanent as possible, noting geological, terrestrial, or oceanic reservoirs or products. However, no specific rules for fully upholding the like-for-like principle have been found.

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 Removal and Carbon Farming Framework (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 national level, the key points of the long-term negative emissions strategy indicate that Germany will consider proposals for monitoring and certification of CDRs. Monitoring and certification will likely focus on addressing discrepancies between the EU CRCF process and the rules for CDR accounting at the national inventory level.

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. 

In Germany, rules on corporate climate claims have been disputed in the courts. A June 2024 ruling in the Federal Supreme Court found a firm’s claim of “climate neutrality” misleading due to differing interpretations of the claim. The court ruled that usage of such terms must be accompanied by an explanation of the specific meaning of “climate neutrality” in the given context. In this case, the plaintiff was confused by the term and expected the production process itself to be climate-neutral.

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

BECCS can be reported under the 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.

Section 3 of the Federal Climate Protection Act notes that the achievement of national climate targets shall apply “without prejudice to the possibility of achieving national climate targets by using intergovernmental mechanisms to achieve part of the reduction in greenhouse gas emissions”, leaving the door open for the potential use of Article 6 within national law, without contributing to the EU NDC.

(a) Legal framework covering key aspects

Legality of CO₂ transport and storage

The Carbon Dioxide Storage Act governs CO₂ transport and storage in Germany, transposing the EU CCS Directive. Several elements of the Act were restrictive to the development of transport and storage, such as a limitation of storage to testing and demonstration purposes, a cap on overall CO₂ storage levels in Germany and a clause allowing states to prohibit storage on their territories, which was effectively adopted by five federal states (“Länder”). As a consequence, no storage facility has been in operation in Germany since 2016.

The recently-published key points of the upcoming Carbon Management Strategy signalled changes to Germany’s legal framework regarding carbon capture and storage, where transport and offshore storage are to be explicitly regulated. The Strategy is also described as the foundation for regulating CDRs that use capture and storage infrastructure.

A draft law to amend the Carbon Dioxide Storage Act has been published alongside the Carbon Management Strategy by the German government. The draft law proposes to allow offshore underground geological storage outside of marine protected areas and to maintain the prohibition of onshore geological storage (except in the case of research). The draft law also establishes a regulatory framework for CO₂ pipelines. Individual Länder will be able to “opt-in” to onshore storage by passing state legislation.

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

Through the Industrial Carbon Management Strategy, the EU signalled the upcoming development of a dedicated regulatory package for CO₂ transport 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.

Liability for CO₂ storage

Requirements for monitoring of CO₂ storage are set out in Subsection 5, Clause 22 of the Carbon Dioxide Storage Act, while Clause 23 sets out measures in the case of CO₂ leakage.

The provisions on decommissioning and aftercare of CO₂ set out in Clause 17 and 18 require that the operator continues to take measures to prevent leakage at their own expense, with the requirements on monitoring and leakage measures continuing to apply after closure. Responsibility for the site can transfer to the competent authority forty years after site decommissioning is completed.

An aftercare contribution must be paid by the operator, as set out in Clauses 30 and 31 of the Act. The contribution must cover the costs of monitoring for 30 years after the transfer of responsibility.

After responsibility has been transferred, monitoring frequency can be reduced whilst still ensuring that any leaks would be detected.

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 German law through the Environment Damage Act 2007 (Umweltschadensgesetz). The Carbon Dioxide Storage Act amends the Environment Damage Act to include the operation of CO₂ storage facilities within its scope, meaning such facilities are subject to environmental liability provisions such as reporting potential risks, identifying appropriate remedial measures to address damage, and covering the costs of such measures.

The Carbon Dioxide Storage Act sets out rules on safety management. Clause 5 details assessments which must be undertaken by federal institutions to assess the potential for permanent storage. This includes an assessment by the Federal Environment Agency to assess environmental impacts and measures for environmental protection. Under the draft amendment to the Act, the Federal Agency for Nature Conservation will also need to prepare principles for nature conservation for the site.

Per the draft amendment of Clause 7, exploration permits for offshore storage will only be issued where the marine environment will not be endangered.

Under Clause 19, a safety "proof” must be submitted to the competent authority, which must include measures to prevent and eliminate leaks. The document must be regularly updated, to assess long-term safety risks to humans and the environment, including as a result of leakage.

The monitoring requirements detailed in Clause 22 and 23 include assessment of potential human or environmental impacts, assessing the effectiveness of any remedial measures and the reporting of these to the competent authority.

Clause 29 of the Act also sets out the operator’s liability for damage to human health.

Under the draft amendment to the Carbon Dioxide Storage Act, marine protected areas are to be excluded from offshore storage permitting.

London Protocol

In the key points document, the German government signalled its willingness to ratify the amendment to Article 6 of the London Protocol, which would allow Germany to export CO₂ to other countries for geological storage under the seabed.

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.

(a) Physical storage capacities

Geological storage

The Federal Institute for Geosciences and Natural Resources has estimated Germany’s offshore and onshore CO₂ storage potential to equal 6.3-12.8 GtCO₂ in saline aquifers, 2.75 GtCO₂ in depleted natural gas fields and 130 MtCO₂ in depleted oil wells. The Institute has also assessed the storage capacity beneath the North Sea, estimated to be 150-190 GtCO₂. CDRmare has estimated a storage capacity of 1-6 GtCO₂ in the German Exclusive Economic Zone within the North Sea. They focus their attention on storage in red sandstone.

Mineral and product storage

Nothing found.

(b) Estimation of CO₂ storage needs

The evaluation report on the Carbon Dioxide Storage Act summarises the findings of five studies of Germany’s net zero transition and the associated contributions from CCS, finding the need for annual capture volumes in Germany to be between 34-73 Mt of CDR by 2045.

Ownership of infrastructure

Nothing found.

State support

The upcoming carbon management strategy is expected to set out state support for carbon capture and storage, with the aim to ramp up the technology and complement the carbon price incentive, focusing on hard-to-abate industrial and waste management-related emissions.

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.

In January 2023, a joint statement by the German and Norwegian governments announced a feasibility study for pipeline CO₂ transport between the countries.

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.

The planning, construction and operation of CO₂ storage and transport infrastructure are already regulated under the Carbon Dioxide Storage Act, which transposes the EU CCS Directive. Under the Act, no facilities for pipeline transport or geological storage of CO₂ onshore or offshore were developed, as the federal regulation banned activities outside of research-scale projects. Many Länder have also introduced their own specific bans.

The recently published key points of its upcoming Carbon Management Strategy and its accompanying draft amendment to the Carbon Dioxide Storage Act set out a streamlined approval process for CO₂ pipelines, bringing the procedure in line with the Energy Industry Act (EnWG) and shortening the process for approval. The amendment addresses the lack of alignment with the EnWG, as well as fragmentation in the legal framework (where different activities were regulated under different instruments), which have to date created uncertainty in the planning process and stymied project development.

The document outlining the key points of the upcoming negative emissions strategy calls for a stocktake of the current performance and long-term potentials of CDR methods under different scenarios.

The Federal Ministry of Education and Research published the Future Research and Innovation Strategy in February 2023, setting out six central missions for the current government, including the advancement of climate protection. A document detailing the specific actions and goals within the missions was published in 2024. Under Mission 2 on climate protection, the development of the evidence base surrounding CDR is mentioned as a key goal, as well as the creation of an integrated monitoring, reporting and verification (MRV) system for all GHGs.

The key points of the long term strategy for negative emissions highlights the need to strengthen Germany as a hub of research and technology development for CDR. Key questions for Germany to address include the LCA performance of CDR methods, co-benefits, public acceptability, economic incentives and other sustainability issues for CDR.

In addition to the federal approach, individual Länder have their own incentives for research, innovation and deployment. The legislation for storage in the 16 German Länder differs, consequently, so will research and innovation. For example, in Niedersachsen, terrestrial storage is so far prohibited but there is some momentum for marine storage. In North Rhine-Westphalia, a call for proposals has been opened to support CDR projects. Federal states will be central to the implementation of Germany’s Carbon Management Strategy. While some Länder are pioneering their own sub-management strategies, such as North Rhine-Westphalia, the level of support differs amongst the regional governments.

The German government has been funding CDR research programmes for some years. The CDRTerra and CDRMare programmes explore a variety of CDR methods and their possible applications on land and at sea. The Ariadne project deals with the role of CDR in Germany’s net zero GHG emissions target. The government has also put in place funding measures to explore the inclusion of CDR in regional and European CO₂ transport networks, and European cooperation in the storage of CO₂ in the North Sea.

There are several funding opportunities for CDR application in land use. The German Strategic Plans for the Common Agricultural Policy (CAP) includes several eco-schemes for the increased storage of CO₂ through, for instance, crop diversification with legumes and more extensive grassland management. The CAP rural development programmes also provide support for measures such as peatland rewetting and wetland farming (so-called paludiculture), long-term conversion of arable land into grassland and agroforestry. However, the availability of such programmes differs among the Länder.

The Climate Protection Programme 2030 promotes measures to build up humus in arable land, the sustainable management of forests and the use of wood. The 2021 Immediate Climate Protection Programme builds on these measures to provide support for increasing the carbon sink capacity of forests as well as the carbon storage in durable wood products.

The upcoming long-term strategy on negative emissions is expected to assess options for economic incentives for CDR to support economic viability, whilst also considering corresponding EU policies. Specific state funding for CDR is one option being considered as part of the long-term negative emissions strategy. The market framework will take into account the marginal costs of different CDR options with a view to ensuring the economically efficient delivery of CDR.

The federal government launched the ‘Climate Protection Agreements’, which are carbon contracts for difference applicable to carbon-intensive sectors. This instrument, which compensates for potential differences between market prices of CO₂ and the cost of deploying technologies aimed at reducing GHG emissions, could also be used to incentivise CDR.

In August 2024, Germany set aside EUR 3 billion up until 2030 for industrial decarbonisation projects. The funding programme has two main tracks, one on decarbonisation and one on CCUS, where CDR might be applicable.

In addition to the federal approach, individual Länder are able to establish their own deployment incentives. In North Rhine-Westphalia, a call for proposals has been opened to support carbon capture and utilisation projects involving industrial, biogenic, and atmospheric CO₂ capture, which is relevant for parts of the CDR value chain. Proposals have been opened to support carbon capture and utilisation projects involving industrial, biogenic, and atmospheric CO₂ capture, thus having relevance for parts of the CDR value chain.

At the domestic (federal) level, Germany has developed a Federal Action Plan on Nature-based Solutions for Climate and Biodiversity, published in March 2023. The Plan allocated EUR 4 billion from the Climate and Transformation Fund for nature-based climate action, including the promotion of soil carbon stocks, restoration of peatlands and coastal habitats, forestation and urban tree planting.

Additional schemes are available at the state (Länder) level and the cross-cutting level. One noteworthy initiative is the Federation-Länder target agreement on climate change mitigation through peat soil conservation, which focuses on large-scale peatland rewetting across the country.

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.

Note: Germany’s Climate and Transformation Fund, adopted in 2022, was initially established as a EUR 212 billion fund for climate and energy projects between 2024 and 2027, but has been subject to cuts under changing economic and political circumstances in the country.

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. Germany has indicated it will specifically review proposals for integration of CDR into the EU ETS in its upcoming long-term strategy on negative emissions. The strategy will also review other state funding options for CDR, as well as longer-term options beyond the EU ETS lifespan. The assessment will take into account the marginal costs of different CDR options with a view on economically efficient delivery of CDR.

Nothing found.

Though Germany is already subject to the EU ETS, Germany set up a national Emissions Trading System for heating and transport fuels in 2021. The system is currently in its first phase, involving a fixed allowance price, and will move to full auctioning with a minimum and maximum allowance price in 2026. In 2024, the allowance price is fixed at EUR 45/tCO₂. Revenues from the scheme are directed to the Climate and Transformation Fund, to be spent on climate action programmes.

The preamble to the Federal Climate Protection Act states that public consultation procedures will take place with local authorities, civil society groups and businesses, as part of the development of climate focused policies.

The key points of the long term strategy for negative emissions further highlights the importance of civil society involvement in the development of the strategy at appropriate points. The BMWK will develop the strategy through workshops with key stakeholders themed around each pillar of the strategy – targets, evaluation of methods, governance and legal framework, and R&D.

Beyond CDR, Germany has involved the public throughout its climate policy development. The Climate Action Plan 2050 involved a citizen dialogue process from 2015 to 2017, a tool the Federal Environment Ministry plans to use going forward. The Federal Ministry for Economic Affairs and Climate Action also recognises the role of public dialogue, adopting this tool as part of electricity grid expansion plans – plans that have involved the use of local “citizens offices” in relevant places, providing information, listening to citizens’ concerns and harnessing local knowledge.

The EU Just Transition Mechanism makes funding available for member states to support the green transition in territories most at risk of losing jobs due to the transition. In this context, EUR 2.5 billion has been made available for Germany, targeting four regions most impacted by the transition away from coal power. The funding will focus on renewables, circular economy, resource efficiency, alternative materials and land rehabilitation, by supporting start-ups, creating new jobs, and providing training.

The long-term strategy for negative emissions is expected to examine issues of public acceptability for CDR in Germany.

Social and ethical dimensions of CDR are being investigated across publicly-funded German CDR research projects including CDRterra and CDRmare.