August 31, 2023

Industrial Carbon Management Strategy

Carbon Gap's comments on the ICMS

Key Takeaways

1. The EU must chart a path to net negative emissions through ambitious and dedicated carbon removal targets for 2040.

2. The EU must use the Industrial Carbon Management Strategy to identify and address policy gaps in the EU legislative framework for carbon removal.

3. Europe should introduce ambitious deployment incentives to scale up carbon removal technologies and create a European carbon removal ecosystem.

4. The EU must promote non-discriminatory, open-access, cross-border CO2 transport and storage infrastructure in Europe.

5. The Industrial Carbon Management Strategy must introduce guardrails and clear rules of the road for carbon removal.

Carbon Gap EU policy consultation feedback

The consultation on Industrial Carbon Management provides an opportunity to make carbon removal an integral part of EU climate policy. Addressing the immediate threat posed by climate change requires using a broad range of tools. The 2023 IPCC (Intergovernmental Panel on Climate Change) Report recognises that carbon removal must be included in efforts to achieve global climate goals. However, carbon dioxide removal must not detract from the urgent task of cutting emissions. Reaching the European Climate Laws commitment to climate neutrality by 2050, and net negative emissions thereafter, will require significant emissions reductions alongside net removals of CO2 already released into the atmosphere. This commitment will require the gradual deployment of Carbon Dioxide Removal (CDR).

The EU is currently failing to realise the potential of carbon removal. Ongoing efforts to deploy and scale up industrial carbon removal are stymied by lacking incentives and an incomplete EU regulatory framework. EU policy proposals and funding instruments were not designed with carbon removal technologies in mind. To make good on the EUs climate commitments, the EU needs an ambitious strategy dedicated to promoting and regulating carbon removal technologies. The European Commission consultation on Industrial Carbon Management provides an opportunity to develop an EU strategy that can guide policymaking and lay the groundwork for achieving net zero by 2050 and negative emissions thereafter.

As the leading independent non-profit organisation focused on mainstreaming carbon dioxide removal in Europe, Carbon Gap calls for the development of a dedicated Industrial Carbon Management Strategy (ICMS) to deploy critical CO2 infrastructure for industrial decarbonisation at scale whilst promoting permanent carbon removal. The European Commission should adopt the Strategy before the end of the year to enable the deployment of carbon removal technologies and CO2 infrastructure in time to adequately contribute to broader climate mitigation efforts. It is essential that the EU give carbon removal sufficient consideration in all relevant policy files, including those focused on land use, agriculture, forestry, industrial infrastructure, and financing of research and innovation projects. Carbon Gap has already started mapping and tracking EU, national and international legislation and policy proposals related to CDR.

Carbon Gap welcomes further discussion of carbon removal as part of a forthcoming Industrial Carbon Management Strategy. The Commissions public consultation provides an opportunity to develop a dedicated EU strategy for carbon removal and chart a path to net negative emissions. The Strategy should make carbon removal an integral part of EU climate policy and introduce clear rules of the road for durable carbon removal. A key policy deliverable is the scaling up of carbon removal technologies as part of a European carbon removal ecosystem that relies on non-discriminatory, open-access and cross-border CO2 transport and storage infrastructure.