The Dutch Climate Act / Klimaatwet, originally passed in 2019, established legally binding targets for 2050 (-95% reduction compared to the 1990 baseline) and 2030 (-49% compared to the 1990 baseline). However, the Act was amended in 2023 to reflect the increased ambition expressed in 2021 in the European Climate Law, mandating that the Dutch government achieve net neutrality by 2050, and a -55% reduction in net emissions by 2030.

Note: While the Netherlands are legally bound by their climate targets, a 2024 report by the Netherlands Environmental Assessment Agency (PBL) warns that current policies are largely insufficient to reach the objectives set out for 2030 and 2050. Despite the announcement of new measures to accelerate the energy transition on April 25, 2025, further recent setbacks in Dutch climate policy increase the risk for Netherlands to miss its 2030 climate target.

The latest NECP update for 2021-2030 provided in 2024 by the Netherlands confirms the country’s intention to reach the European target of -55% net emissions reductions by 2030 and climate neutrality by 2050, while announcing it will consider intermediate targets for 2035 and 2040 in line with the EU Commission’s early recommendation of a -90% net reduction target by 2040.

The current Dutch Climate Act gives no separation between a gross emissions reduction target and a removals target, both for the net-neutrality objective (by 2050) nor for the intermediate 2030 target.

However, as mentioned above, the CDR roadmap lays out the possibility of introducing separate governance structures, coupled with separate targets, for emissions reduction and removals, within the revision of the EU Climate Law.

The Netherlands has a target for land-use sector removals through EU legislation, but no separate permanent CDR target in national law. Under the EU LULUCF Regulation, the Netherlands is committed to enhancing its land carbon sink as part of the EU-wide goal of achieving a –310 Mt LULUCF net sink by 2030, effectively giving the Netherlands a binding LULUCF contribution. According to this regulation, as the Dutch LULUCF sink is currently a net-emitter of CO₂ (around 4.95Mt/yr), the government aims to reduce emissions in the LULUCF sector by a volume of ~450kt CO₂ eq/yr for 2030.

In contrast, there is no official volume target yet for permanent CDR methods from the Netherlands. However, the CDR Roadmap gives an estimation of 20–25 Mt of CDR by 2040 to be achieved by scaling up various methods . It also signals intent to establish a permanent removal goal; for example, the Netherlands states its intention to advocate for the EU Climate Law to set separate targets for permanent and LULUCF removals.

The Dutch Climate Act, in its Article 2, paragraph 1, states the obligation for the Netherlands to comply with the objectives of the EU Climate Law and clearly states that the Netherlands “aims for negative greenhouse gas emissions after 2050”. Even though it is only a domestic transposition of the EU Climate Law, it is worth noting that not all EU Member States have explicitly mentioned negative emissions in their domestic climate objectives yet. However, the formulation in “aim[ing] to” reach this objective is not as legally binding as the 2030 or 2050 net emissions reductions target.

Biomass sustainability

The Netherlands outlined its vision for biomass sustainability in a letter to the Dutch Parliament in April 2022. Biomass is expected to play a significant role in reaching climate neutrality and achieving a circular economy in the Netherlands by 2050. To achieve this vision, the letter outlines key principles that guide the Netherlands’ approach towards biomass use. It plans to implement a cascading use of biomass, prioritising high-value purposes (bio-chemicals, plastics, materials replacing fossil feedstocks), applications with no credible renewable alternative (advanced biofuels for marine, aviation, heavy road transport, generation of high temperature heat (>100°C), and applications by which carbon is stored in products (construction materials)). In contrast, subsidies to low-value purposes are to be phased out (e.g. biopower, low temperature heat).

Those priorities have been applied to current requirements for the Netherlands’ SDE++ scheme, the primary subsidy scheme supporting renewable energy and climate change mitigation technologies. To qualify for subsidies under this scheme, projects must meet the criteria for sustainable use of biomass laid out in the EU Renewable Energy Directive (RED III).

Mitigation deterrence

The CDR Roadmap sets out five guiding principles for the Netherlands’ CDR action, one of which is the “prioritisation of emissions reductions” - i.e. CDR should complement, not replace, efforts to reduce greenhouse gas emissions. The roadmap emphasises that emissions reductions must remain the primary strategy for climate mitigation, with CDR serving as a supplementary measure to address residual emissions.

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

Like-for-like principle

The importance of following the like-for-like principle is explicitly mentioned in the CDR Roadmap, which acknowledges that “the nature and durability of carbon removal must correspond to that of the emissions being offset”. The Roadmap thus advocates that “permanent” emissions, namely from fossil fuels, require permanent removal methods (DACCS and BECCS are presented as examples), while temporary removal methods, including reforestation and soil carbon sequestration, are appropriate for offsetting temporary or short-lived emissions.

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 and will be applicable across EU Member States.

In terms of mechanisms at the national level, the Netherlands, while planning for comprehensive MRV rules for a wide range of methods to be in place in its Roadmap by the 2030s, currently requires some certifications in restricted cases. For instance, under the SDE++ subsidy scheme, pilot projects (i.e. DACCS) must measure and verify the CO₂ removed to receive payments, using methodologies approved by the government. Moreover, any geological CO₂ storage (including biogenic CO₂) is monitored under EU regulations (the Monitoring and Reporting Regulation and CCS Directive). For carbon stored in forests and soils, the national inventory follows IPCC guidelines to quantify CO₂ removals in the LULUCF sector, but there is no activity-scale public certification mechanism in place.

No specific national regulations govern corporate use of CDR or offset claims in the Netherlands yet, but there is growing scrutiny on those practices. The Dutch Authority for Consumers & Markets (ACM) has issued guidelines against misleading sustainability claims – for example, it warns that terms like “carbon neutral”, “CO₂-neutral” or “climate neutral” should only be used if they are truthful and substantiated (companies must transparently disclose the use of offsets).

At the EU level, the Green Claims Directive was supposed to provide a comprehensive framework for climate-related claims, combined with the Directive on Empowering Consumers for the Green Transition, could 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 the Dutch national inventory and be reported in the Netherlands’ contribution towards the EU nationally determined contribution (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’s NDC and its targets set in the European Climate Law are to be achieved only through domestic measures.

As preliminary discussions on the revision of the European Climate Law are underway, in view of establishing targets for 2040, the Netherlands has expressed its “scepticism” towards the potential use of Article 6 credits to meet a share of the 2040 target, arguing that any legally binding target should be met by domestic efforts only.

(a) Legal frameworks covering key aspects

Legality of CO₂ transport and storage

The Mining Act (Mijnbouwwet) consists of the transposition in Dutch law of the EU CCS Directive (2009/31/EC), establishing a legal framework for safe geological CO₂

The ETS Directive imposes that entities undertaking capture, transport and storage of fossil CO₂ register under the ETS must have their operations recognised as emissions avoided (no purchase of allowances required).

Finally, the Dutch Climate Act confirms the ban in the Netherlands of onshore CO₂ storage, limiting possible storage sites to offshore depleted gas fields under the North Sea. This disposition results from local opposition to an onshore CCS project in Barendrecht which was cancelled in 2010. Since then, all current CO₂ storage projects (including Porthos and Aramis) are offshore.

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, 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.

The Netherlands has ensured the transposition of this Directive in domestic law through amendments to the Mining Act, as well as through the Environment Management Act (Wet milieubeheer) and the Environment and Planning Act of the Netherlands (Omgevingswet).

The Environment and Planning Act entered into force in 2024, merging the environmental requirements outlined in previous legislation. Together with the Environmental Permitting Act (Wabo), they complement the Mining Act by covering environmental safety and remediation obligations for storage operators in line with EU standards.

London Protocol

The Netherlands is among the few countries to ratify the 2009 amendment to Article 6 of the London Protocol, which enables cross-border CO₂ transport for sub-seabed storage.

In 2019 the Dutch and Norwegian governments led a resolution allowing countries that ratified this amendment to provisionally begin CO₂ export/import for storage.

signed a bilateral Memorandum of Understanding with Norway in April 2024 to mutually recognise permitting and oversight for CO₂ shipments between the two countries, ensuring that liability and regulatory responsibilities are clearly allocated for cross-border CO₂ projects. In parallel, the Netherlands signed a multilateral agreement with Denmark and the province of Flanders (Belgium) in 2022, enabling cross-border CO₂ transport and storage cooperation. Discussions are also ongoing with other Nordic countries such as Denmark and Sweden, and the Netherlands actively participates in the North Seas Energy Cooperation platform to promote transboundary CO₂ infrastructure development.

(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 those emissions. Furthermore, 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.

Dutch law (through the Mining Act, aligned with the EU CCS Directive) does not distinguish CO₂ by origin – atmospheric, biogenic, and fossil CO₂ are equally eligible for transport and storage.

Furthermore, the SDE++ subsidy scheme in the Netherlands supports carbon capture and storage projects, allowing for an increasingly wide spectrum of CO₂ origins. Projects capturing CO₂ from industrial processes, from biomass through BECCS projects (since 2024), or directly from the atmosphere through DAC projects for CCU purposes (starting 2025) are eligible, provided they meet the technical and environmental criteria set by the scheme.

Geological storage

The Dutch offshore geology provides significant CO₂ storage potential. Estimates indicate approximately 1.6 gigatonnes of CO₂ capacity in depleted gas reservoirs under the North Sea. Specific projects confirm significant capacities: the Porthos project plans a total capacity of 37 Mt CO₂ (2.5 Mt/yr for 15 years), and the Aramis network could store up to 22 Mt CO₂ per year by 2030 with over 400 Mt total capacity in its depleted gas fields. These assessments stem from detailed geological surveys by entities like TNO (the Netherlands Organisation for Applied Scientific Research) and EBN (a state-owned Dutch natural gas company).

Mineral and product storage

Netherlands-based projects and companies are currently exploring mineralisation and product-based CO₂ storage pathways, with support from the DEI+ subsidy scheme, though these remain at earlier stages. For example, CO₂ utilisation in building materials (cement and concrete curing) or long-lived products like carbonated aggregates is being researched, but their potential volumes are comparatively modest and not yet fully quantified in policy. The CDR Roadmap notes the need to further evaluate capacities for mineralisation and storage in products, while acknowledging that geological storage (namely offshore) has greater theoretical potential in the Netherlands than biological sinks, given limited land area.

Ownership of infrastructure

The Dutch government has decided that critical CO₂ transport pipelines and storage facilities will operate as open-access networks. State-owned entities Gasunie and EBN have taken equity stakes in projects like Porthos and Aramis, ensuring public oversight and making infrastructure available to multiple users. The Minister of Climate has indicated that, if needed, further rules will mandate third-party access to prevent any single company from monopolising CO₂ pipelines and other transport infrastructure.

State support

The Netherlands de-risks CO₂ transport and storage through substantial public support. The SDE++ subsidy scheme was extended to CCS in 2020, covering the part of the operating cost of CCS operations which isn’t covered by savings on ETS allowances. Through SDE++, the Porthos project secured a 15-year subsidy (up to a maximum of approx. EUR 2.1 billion) to guarantee a price per tonne stored.

The EU has also recognised Porthos and Aramis as Projects of Common Interest, awarding Porthos EUR 102 million from the Connecting Europe Facility. This blend of national and EU funding reduces financial risk for infrastructure developers.

Finally, the Dutch government has offered ad-hoc support for flagship projects - in April 2025 the Dutch state committed EUR 639 million to finance the CO₂ pipeline of the Aramis project after two private investors pulled back.

Cross-border cooperation

The Netherlands actively pursues the development of cross-border CO₂ infrastructure. The 2024 Netherlands–Norway memorandum under the London Protocol not only allows export of CO₂ for storage but also signals intent to import CO₂ from other EU countries into Dutch storage sites.

The Dutch government also cooperates with Benelux countries, as well as with those part of theNorth Sea Basin Taskforce for CO₂ pipelines. Domestically, provisions exist for third-party access to transport and storage – for example, investments and usage rights to the Porthos pipeline were open to multiple companies (Shell, Air Liquide). By placing CO₂ networks in the national Energy and Climate infrastructure plan (MIEK), authorities are treating them as critical infrastructure, and in so doing, Projects like the (linking Rotterdam’s CO₂ network towards Germany’s industrial Ruhr area) and Carbon Connect Delta (in Zeeland) have been designated Projects of National Importance under the MIEK. These initiatives align with EU Projects of Common Interest, laying the groundwork for cross-border CO₂ flows with Belgium and Germany in the future.

Indication of capture and storage volumes

As part of risk reduction for investors, the government has signalled expected CO₂ throughput volumes. The Climate Plan projects that 5–10 Mt CO₂ per year will be captured and stored by 2030 through CCS. To allow CCS capacities to reach those volumes by 2030, the government removed in 2023 the limitations on SDE++ subsidies for CCS projects. This policy shift guarantees that viable CO₂ storage projects will not be turned away due to subsidy caps. The Climate Agreement initially envisaged approximately 7.2 Mt/yr of industrial CCS by 2030, and current subsidy allocations appear on track to achieve that.

The Netherlands has implemented a coordinated permitting regime for CO₂ transport and storage projects to improve efficiency. Major projects like Porthos are handled under the National Coordination Scheme (Rijkscoördinatieregeling) to bundle approvals and set clear timelines. CO₂ storage permits require a detailed storage development plan and environmental impact assessment. and environmental impact assessment. The Ministry of Economic Affairs involves the State Supervision of Mines and independent experts (e.g. Mijnraad advisory council) to vet site integrity and monitoring plans. Conditions on monitoring, leakage prevention and remediation are attached to permits to uphold the high safety standards mandated by the EU CCS Directive. Notably, the Dutch regulator and courts also ensure alignment with broader environmental law (see the example of the Porthos project below).

The Netherlands is also considering specifying regulations to guarantee third-party access to CO₂ transport infrastructure, so that new CDR projects can plug into pipelines – a measure being developed in anticipation of future EU CO₂ network legislation. So far, third-party access is mentioned under Article 32 of the Mining Act (Mijnbouwwet), which requires transport network or storage permit holders to grant access on reasonable, transparent, and non-discriminatory terms. Taking Porthos as an example, the draft storage permit and associated approvals were published in December 2021, with a public consultation period open from 17 December 2021 to 27 February 2022. Notifications appeared in the official gazette and local newspapers to guarantee transparency and public input. This one-stop process allowed Porthos to reach a final investment decision in 2023. Yet when it came to ensuring alignment with broader environmental law beyond rules strictly related to CO₂ transport and storage, Porthos faced a delay when a 2022 Council of State ruling required accounting for construction-phase NOx emissions, temporarily pausing Porthos until compliance was addressed

The Dutch government has explicitly evaluated how much carbon dioxide removal is needed alongside emissions reduction. In its Climate Plan 2025–2035, the government set an indicative goal of 20–25 Mt CO₂ per year of removals by 2040–2050 for the Netherlands. This number corresponds to approximately 10% of 1990 emissions and reflects expected residual emissions (especially from sectors like aviation, agriculture and industry) that must be neutralised. The 2025 CDR Roadmap discusses scenarios with a lower bound of 10–15 Mt and an upper bound up to 30–40 Mt by 2050, examining the range of potential national CDR contributions.

Biomass availability

The Netherlands recognises that sustainable biomass feedstock is a limiting factor for BECCS. Domestic biomass (agricultural residues, organic waste, some forestry by-products) is finite and much is already used for materials or energy. The Dutch Climate Plan notes that the country is highly land-constrained and currently imports significant biomass for energy. Assessments in the National Energy and Climate Plan (NECP) and other studies quantify how different biomass streams could contribute to negative emissions. One promising route is BECCS at bio-refineries – e.g. ethanol plants or biomass power units – which the Roadmap highlights as a way to leverage biogenic CO₂ already being emitted. However, domestic biomass alone cannot fuel very large-scale CDR due to competing uses and sustainability limits.

The government’s stance is to prioritise residual and waste biomass for BECCS and avoid purpose-grown energy crops that compete with food or nature. There is also attention to imported biomass (wood pellets, etc.), but any use for CDR will adhere to strict sustainability criteria. In summary, studies indicate biomass supply could support on the order of 5–8 Mt CO₂ of removals per year in the Netherlands by 2050 if optimised.

Renewable energy supply

The Netherlands’ climate and energy strategy – which targets approximately 70 GW of offshore wind by 2050 – aims to factor in future electricity demand for carbon removal technologies. Overall, the Netherlands’ expanding renewable energy capacity should be sufficient to support the envisioned CDR scale-up, provided that grid planning anticipates these new electricity demands and that, as per the 2025 CDR Roadmap, the country further explores the development of adding CCS to previously existing bioenergy streams (biomass-fired plants or waste facilities), to generate negative emissions with only a marginal increase in energy demand.

To limit the strain on current renewable energy capacity in the Netherlands, early pilot DAC projects (such as those by Dutch firm Carbyon) are already being integrated at sites with surplus renewable energy or waste heat to test viability.

Infrastructure availability

With its extensive North Sea continental shelf and experience in the gas sector, the country has identified enough storage capacity (approximately 1.7 Gt in offshore formations) to handle many decades of removals, as expressed in reports by TNO, and in the CDR Roadmap. Infrastructure development is underway; the Porthos project will inaugurate an open-access CO₂ pipeline and storage site by 2026, and the planned Aramis network aims for up to 22 Mt CO₂/year capacity by 2030, linking multiple capture sites to North Sea storage. These transport & storage projects that if capture facilities (DAC plants, bio-CCS installations, or others) come online, transport and storage should not be a bottleneck.

Land use

Land scarcity in the Netherlands limits the potential of land-based CDR such as afforestation and soil carbon sequestration. The country’s Forest Strategy aims for a 10% increase in forest area by 2030 (approximately +37,000 ha) to enhance carbon sinks, but even if achieved, the net removals impact is relatively small; estimates place the added uptake at only 0.1–0.4 Mt CO₂/year by 2030. Likewise, the government is actively re-wetting carbon-rich peatlands to halt emissions from peat oxidation, yet this activity relates more to emissions reductions than CDR. The CDR Roadmap emphasises that significant scaling of engineered and hybrid CDR methods will be required to satisfy the future CDR needs of the Netherlands, as the limitations of Dutch geography implies that no massive growth of nature-based CDR should be expected. Nevertheless, modest contributions from nature-based solutions are counted in the country’s CDR potential: e.g. continued sustainable forest management could maintain a small net sink, urban tree planting and blue carbon (coastal wetlands restoration) may offer limited gains.

The CDR Roadmap the government published at Parliament’s request in 2025 lays out a phased development plan for CDR, with an initial start-up phase (up to approximately 2030) that focuses on innovation and research. The government is thus initiating a national stimulation programme for CDR innovation and early deployment. The aim is to leverage existing instruments (national research grants, EU Horizon programmes, Mission Innovation funds, etc.) and fill any gaps with dedicated support for carbon removal technologies.

To that end, the Dutch Research Council (NWO) has issued calls related to investigating the social and technical aspects of negative emissions, and the Topsector Energie’s innovation scheme’s grant programme includes CCS and carbon removal. As a comprehensive strategy document for CDR scale-up, the Roadmap mentions plans to adapt existing R&D support mechanisms for CDR methods that need it. Indeed, the government acknowledges in the Roadmap that significant public investment in R&D and demonstration will be needed this decade to bring down costs. Already, a public-private R&D consortium on CO₂ utilisation/conversion (TKI Nieuw Gas) is receiving €35 million in subsidy, which, while focused on CCU, builds knowledge relevant to removals (e.g. direct air capture sorbents, carbon mineralisation processes).

Competitive grant schemes have started to earmark funding for CDR-related projects. The Netherlands Enterprise Agency (RVO) has included carbon removal topics in programmes like DEI+ (Energy and Climate Innovations), encouraging pilot projects for BECCS, DACCS, and carbon capture in novel applications.

Additionally, the government has leveraged European R&D support - Dutch institutes and companies are active in EU Horizon Europe projects on direct air capture, biochar, and carbon sequestration monitoring. One clear example is the government-funded 2025 TNO study “Carbon removal in a sustainable Dutch energy system”, which identified research gaps in MRV (monitoring, reporting, verification of removals) and in scaling up technologies. This study, commissioned by the Ministry of Economic Affairs and Climate, will guide future research calls. The Netherlands is now focusing on a number of identified gaps, including developing reliable carbon accounting methods for soil and biomass-based removals (to integrate them into climate targets), improving the cost-efficiency of DAC through materials science, understanding storage permanence (especially for novel techniques like mineralisation), and the socio-economic aspects of CDR deployment.

A notable initiative is the establishment of Invest-NL (the Dutch state investment bank) and other funding vehicles to support cleantech startups in carbon removal. For instance, the Dutch startup Carbyon, which is developing an innovative DAC technology, received both research grants and a €6 million investment from Invest-NL to help scale up its R&D towards a field pilot. Moreover, the CDR Roadmap opens the door to using some ETS auction revenues to fund an innovation mission for carbon removals.

At the pilot scale, the DEI+ (Energy and Climate Innovations) subsidy scheme is already providing a few million euros to fund pilot BECCS and DACCS projects. The DEI+ scheme is also open to subsidising biochar projects.

The Netherlands’ landmark subsidy scheme for renewable energy and CO₂ emissions reductions, the SDE++, was initially restricted, in the case of carbon capture, to CCS operations for fossil point sources. Following a letter from the Minister of Energy and Climate to the Dutch parliament, SDE++ is now open to BECCS projects and may soon become accessible to DACCS projects, once the proper accounting mechanisms are in place.

Topsector Energie’s innovation budgets also include lines for CCUS innovation, some of which overlap with CDR (such as R&D on direct air capture sorbents). Although limited in volume, those funding streams explicitly mention CDR methods as eligible topics.

The SDE++, the Netherlands’ core funding mechanism, currently acts as a Carbon Contract for Difference (CCfD) for CCS/CCU and BECCS projects, and will potentially soon expand to DACCS projects (see the section “Dedicated funding earmarked for relevant CDR methods”). Indeed, the SDE++ subsidy enables project developers to receive the difference between an “application price” (maximum 400 EUR/t CO₂ in 2024), chosen by the developer, and a “correction price” set each year by the Netherlands Environmental Assessment Agency (PBL). In the case of CCS/CCU/BECCS projects, the correction price incorporates the ETS price. Thus, the SDE++ covers the difference between the removal price per tonne and the ETS price, effectively covering the “unprofitable” portion of the cost of CDR. This subsidy constitutes a deployment incentive for permanent CDR, which will be reinforced when the SDE++ is open to DACCS projects.

In terms of tax incentives, project developers can also benefit from the Energy Investment Allowance, which can lead to up to a 40% deduction of investment costs from the taxable profit when investing in a list of specific technologies, including CCS, thus reducing the upfront costs of permanent removal projects.

The CDR Roadmap released in 2025 mentions several deployment incentives the country could launch, including negative emissions auctions using ETS auction revenues, but only in the medium term (post-2030).

Deployment incentives for less durable CDR methods in the Netherlands are limited in scope, in part due to the Netherlands’ constrained land availability. The Dutch government’s climate strategy does include support for land-based carbon sequestration (which encompasses afforestation, reforestation, soil carbon improvements, and peatland restoration), but these measures are not always explicitly framed as CDR incentives.

The 2020 National Forest Strategy (Bossenstrategie) highlights several relevant initiatives, such as funds to plant new forests and improve forest management, supported by a global envelope of EUR 51 million allocated by the government. This funding includes subsidies for planting on private lands and urban forestry initiatives. These efforts are backed by climate targets. For example, the Netherlands’ LULUCF plan aims to enhance the forest CO₂ sink, and communities can get co-funding for tree-planting projects. One of the main tools to scale up less durable CDR methods is the adaptation of the SNL (Subsidiestelsel Natuur en Landschap) subsidy to favour carbon storage in trees and promote small-scale climate-resilient forestry.

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.

In the CDR Roadmap, the Netherlands sees the EU ETS as a potential lever to make a compliance market emerge for permanent CDR, although only after 2040.

The Netherlands has advocated for CDR inclusion in the EU ETS, and has supported the development of EU incentive mechanisms for CDR alongside Denmark, Norway and Sweden to contribute to the EU climate neutrality target emphasising that achieving climate neutrality will require additional EU support to permanent CDR beyond the integration in the ETS (i.e. by mobilising additional funding for public procurement of CDR).

The Netherlands is at the very early stages of incorporating CDR into general legislation and sectoral policies, with measures that could pave the way to greater inclusion of CDR products or practices, but without explicitly mentioning carbon removal. For instance, public procurement rules are currently under reconsideration, and some criteria could reward a CDR component in the life cycle analysis of the procured good.

Furthermore, the Netherlands has integrated CO₂ utilisation (mainly CCU so far) into certain sectoral policies: the horticulture sector uses concentrated CO₂ (from industry, but also starting in 2025, from DAC operations supported through the SDE++) in greenhouses to enhance yields, which is governed by greenhouse climate regulations. Looking forward, as CO₂-based products such as carbonated concrete or recycled carbon fibres emerge, Dutch product standards and building codes are expected to adapt to ensure these are allowed and maybe encouraged. At this stage, the government is funding pilots to gather experience for future standards.

Additionally, following the 2024 amendments to the Algemene Groepsvrijstellingsverordening (AGVV), specifically its provisions on CO₂ capture (article 25), transport (art. 36), and utilisation (art. 47), certain captured CO₂ streams (specifically, permanently bound fossil CO₂) are eligible to be classified as a raw material rather than waste when used in approved building-material applications. This classification facilitates compliance under Dutch waste law and is eligible under the EU ETS delegated act on permanently bound fossil CO₂. However, this categorisation applies only to specified CO₂ streams and certified processes and is not yet uniformly applied across all CO₂ types or material use cases.

As of 2025, the Netherlands has implemented a CO₂ levy for greenhouse horticulture. Large greenhouse companies (which burn gas for heat/CO₂) will face a carbon tax designed to ensure the sector meets a 4.3 Mt cap by 2030. However, given the upcoming inclusion of the horticulture sector in the ETS 2, starting in 2027, the Dutch government has stated that ETS 2 inclusion would replace the current CO₂ levy.

It is also worth noting that the country introduced an additional carbon levy in 2021 on ETS-subject industries to accelerate their decarbonisation efforts in line with the Netherlands’ emissions reduction objectives. This year-on-year increasing levy (74.2 EUR/t CO₂ in 2024) was imposed on an entity’s emissions over a sector-specific threshold. Said threshold decreased linearly year-on-year, thus creating an added incentive on top of the EU ETS to accelerate decarbonisation. Although mostly imposed on ETS-subject entities, the levy also covered waste treatment plants, currently outside of the ETS. This levy constituted one of the key policies put forward by the Dutch government to reach its Fit for 55 obligations. Nevertheless, it was abolished by a vote of the Dutch Parliament in June 2025, to “restore a level playing field” with the rest of the EU.

Public and stakeholder participation in CDR decision-making has emerged as a “reactive” participatory route: concerned stakeholders push for a strategy, and policymakers respond. For instance, the Scientific Climate Council (WKR) held dialogues when formulating its 2022 advice on CDR governance, and included civil society perspectives. The government’s CDR roadmap itself was partly a response to Parliament’s request, which followed input from academics and environmental groups highlighting the need for a removal strategy.

Following the Netherlands’ long-standing culture of building consensus among stakeholders (“polder model”), the government has announced its intention, namely in the CDR Roadmap, to form working groups on CDR implementation that include public interest representatives. NGOs will be consulted on topics like biomass sustainability for BECCS. However, CDR-specific broader public engagement (e.g. citizen forums) has been limited so far.

At the project level, public participation mechanisms are in place through legal requirements. Large CO₂ storage projects such as Porthos had to undergo an Environmental Impact Assessment (EIA), during which the public and local stakeholders could review plans and submit comments. Indeed, in the early planning of Porthos, informational meetings were held for the Rotterdam community, and formal objections could be filed – a process that was tested by environmental groups’ legal challenge on nitrogen grounds.

The Netherlands stands out for its use of dedicated tax revenues for climate transition support. The Dutch industrial CO₂ levy, for instance, is designed not just as a ‘punitive’ incentive to reduce emissions but also as a source of funds for industry decarbonisation programmes. Similarly, the Netherlands has a coal phase-out compensation scheme for workers and regions affected by coal plant closures.

The EU Just Transition Mechanism offers funding for Member States to support the green transition in territories most at risk of losing jobs due to the transition. The Netherlands secured about EUR 623 million under this programme to support territories that face socio-economic challenges in the shift to climate neutrality. Regions like Groningen (with the end of natural gas extraction) and parts of South Limburg (with heavy industry) are earmarked for projects funded by the JTF. These funds will develop new low-carbon industries (potentially including CO₂ storage services in the North Sea, hydrogen, etc.) and retrain workers.

The Scientific Climate Council (WKR), in its 2024 report “Clearing the air? Advice on principles and policy for governing CDR,” delves into key ethical issues for CDR governance: avoiding mitigation deterrence, defining the fair use of permanent versus temporary removals, and the just accounting of CDR. This report has directly informed the Dutch CDR Roadmap released in 2025, including the inclusion of the like-for-like principle.

The Dutch research council NWO has funded projects on the public perception of carbon removal and the ethics of negative emissions technologies. Additionally, the Netherlands Environmental Assessment Agency (PBL) included societal acceptance scenarios for CDR in some of its modelling analysis for the Climate Plan, conducting interdisciplinary research on how different CDR levels might be perceived or what governance challenges they raise.