Carbon Dioxide Infrastructure and Project Deployment - Policy Summit takeaways
How should the EU build CO2 transport and storage networks? Five Summit recommendations to give carbon removal projects of every size fair access.
The biggest divide in Europe's CO₂ networks may not be carbon removal versus industry, but big suppliers versus small ones. Five recommendations from the Carbon Removal Policy Summit.
A carbon removal project can capture as much CO₂ as it likes, but it only counts as a removal once it is stored safely and permanently. For most engineered removals, that means moving the CO₂, sometimes hundreds of kilometres, to a storage site deep underground.
CO₂ infrastructure is the network of pipelines, ships, trains, trucks, terminals and storage sites that carry carbon dioxide from where it is captured to where it is permanently stored. Without fair, affordable access to it, even the best-designed project cannot deliver.
At last month's Carbon Removal Policy Summit in Brussels, a breakout session led by Carbon Management Europe focused on exactly this. It gathered recommendations for the European Commission as it prepares its legislative proposal on CO₂ markets and infrastructure, expected later this year. The discussion followed the questions in the Commission's recent public consultation, which ran from October 2025 to January 2026.
The big idea: think about scale, not source
Infrastructure debates often split the world into two camps: carbon dioxide removal (CDR) and industrial emitters, such as cement or steel plants capturing their own emissions.
Participants argued this is the wrong lens. The divide that matters is between large-scale and small-scale suppliers of CO₂ into the network. By ‘suppliers’ here, we refer to any facility that captures CO₂ and sends it into the network for storage, whether that is a steel plant or a carbon removal project.
A large industrial plant might capture hundreds of thousands, or even millions, of tonnes of CO₂ a year, often in a coastal cluster near a planned pipeline. Many CDR projects look very different. A biogas plant, a small biomass heating plant or a direct air capture unit may produce a fraction of that volume, and sit inland, far from any pipeline. Networks designed around a few big "anchor" customers can leave these smaller players paying more, waiting longer or locked out altogether.
With this in mind, here are the five areas discussed and what participants recommended.
1. Market design: let quality lead
Carbon removal is extremely diverse. Participants felt that a one-size-fits-all approach to regulating infrastructure would not work. Instead, the quality of the removal (how durable, measurable, and verifiable it is) should be the main driver of the rules.
Recommendation: Implement quality-based regulation of CDR infrastructure as soon as possible.
2. Planning and cross-border access: regulate tariffs
A tariff is the fee a CO₂ supplier pays to use a network, much like a toll on a motorway. When CO₂ must cross borders to reach a storage site, for example from an inland country to a storage site under the North Sea, those shared-infrastructure fees can add up, and smaller suppliers have little bargaining power to negotiate them down.
Recommendation: The EU should regulate tariffs to support the use of cross-border networks, particularly for smaller CO₂ suppliers. The breakout group felt progress could be made quickly on this consideration.
3. Access for CDR projects of all sizes: go beyond pipelines
Pipelines make sense for large, steady volumes. They make much less sense for a small plant in a rural area.
The food and drinks industry has been moving CO₂ by road and rail for decades, for everything from fizzy drinks to food packaging. Projects like the Kalundborg CO₂ Hub in Denmark plan to transport via ship captured biogenic CO₂ to the Northern Lights storage site off Norway, which began injecting CO₂ in 2025.
Recommendation: Diversify CO₂ transport so that small sources can be pooled together and moved by truck, train or ship where a pipeline is not practical. Participants felt progress could be made quickly here as well.
4. Standards and accounting: fix a hidden penalty
Participants remarked that CO₂ from carbon removal risks being indirectly penalised compared to CO₂ captured at industrial point sources.
When a steel or cement plant captures its fossil CO₂, it avoids having to buy allowances under the EU Emissions Trading System (ETS). That savings helps to cover the cost of capture, transport and storage. A plant capturing biogenic CO₂, which comes from recently grown plant material, or a direct air capture facility pulling CO₂ from the air, does not get that same savings. Yet, it faces the same, or higher, operational costs to get its CO₂ into the network and stored.
Recommendation: To level the playing field, CDR should be subsidised more heavily than other sources of CO₂ entering the network and that institutional support start as soon as possible.
5. Financing and de-risking: back the small players
Building infrastructure is expensive and risky, especially when no one is sure how much CO₂ will flow through it. Again, participants rejected framing this as CDR versus carbon capture and storage (CCS). The real question is how to make sure smaller suppliers are not left behind.
Recommendation: Public money should be set aside for public-private partnerships that de-risk infrastructure for smaller CO₂ suppliers, where the public sector/permitting authorities share some of the risk, so private investors are willing to build. The recommended timing by the group for a framework to be put in place was by 2028.
Takeaways for the Commission
Three messages stand out. First, the timelines are short; all point to decisions the Commission needs to take in this proposal, not the next one. Second, the EU already has a legal target, under the Net-Zero Industry Act, to make 50 million tonnes of CO₂ storage capacity available each year by 2030. That capacity will only deliver for climate if suppliers of every size can access the infrastructure network. Third, and most importantly, designing rules around scale rather than source is a practical way to make sure carbon removal is built into Europe's CO₂ networks from the start, rather than bolted on later.
The EU must get the infrastructure right so that carbon removal projects of every size have a route to storage. If it doesn’t, many will never leave the drawing board.