Feedback to the European Commission Call for Evidence on the EU Ocean and Water R&I Strategy

Earlier this summer, Carbon Gap responded to the European Commission’s Call for Evidence on the upcoming European Ocean and Water Research and Innovation Strategy.

Marine CDR (mCDR) could become an important part of Europe’s carbon removal portfolio, but most approaches are still at an early stage. Questions remain around storage potential, monitoring and verification, environmental and social risks, and how methods perform beyond the laboratory.

The EU therefore needs to navigate two risks: inaction, if these questions are not actively researched, and rushing ahead, if methods progress without sufficient evidence and safeguards. The key is in the balance.

In our response, we highlight the following priorities to ensure the Strategy supports the development of robust, safe and effective marine carbon dioxide removal methods.

According to the IPCC, achieving climate goals will require 4000–8000 MtCO₂ of removals annually by 2050. Marine CDR (mCDR) is a good complement to land-based methods because it can help reduce land-use conflicts and lessen dependence on limited geological CO₂ storage. This means large-scale mCDR could be decisive for keeping 1.5 °C within reach and a critical pillar of the EU's carbon removal strategy. 

Although many mCDR techniques show promise, most are still very new. Scientists agree that we need more research into their storage potential, monitoring best practices, and environmental and social risks, and into bringing the technologies out of the lab and into open-ocean field trials to test real-world conditions. Europe is well placed to lead, but this will require a coordinated research effort to address the open questions, close the policy gaps, build robust monitoring, and drive innovation. 

The EU faces two risks: inaction, if outstanding scientific and policy questions are not actively researched; and rushing ahead, if methods progress without sufficient evidence, safeguards or public acceptance. Europe's challenge is to balance these risks by advancing knowledge and determining which mCDR approaches have the most potential to contribute to climate goals while maintaining high environmental standards. 

The Strategy must prioritise two areas: 

1. Adopt a clear mCDR R&I agenda that identifies the most pressing knowledge gaps for each method, directs sufficient funding towards answering them, aligns priorities across the wider research ecosystem, and supports the transition from laboratory research to controlled field trials and demonstration. Carbon Gap estimates that approximately €2.6 billion in R&I support will be needed across the wider CDR portfolio in the next seven years, with a meaningful share dedicated to mCDR required through FP10 and the ECF.  

This would help determine whether—and under what conditions—mCDR's potential can be realised. This is particularly relevant in the context of the Carbon Removal and Carbon Farming Regulation (CRCF). In 2025, the Commission started evaluating the possibility of developing methodologies for methods such as Ocean Alkalinity Enhancement (OAE) and Direct Ocean Carbon Capture and Storage (DOCCS). A research agenda would generate the evidence base and MRV approaches needed to unlock these methodologies. 

Attached is a list of R&I priorities focused on OAE and DOCCS, given the Commission's ongoing CRCF process; the majority of these questions are cross-cutting to other mCDR methods. They are informed by Carbon Gap's analysis and input from the European Marine CDR Working Group, chaired by Carbon Gap and composed of 32 organisations from civil society, companies, academia and the scientific community. 

2. Ensure coordination with broader ocean governance. Marine CDR sits across climate, biodiversity and marine legislation, and innovation policy cannot work in isolation from wider initiatives such as the Ocean Act and the OceanEye. The Strategy and the Ocean Act should therefore be designed in tandem. The Strategy should generate the evidence base needed to advance and assess mCDR methods, while the Ocean Act should provide greater legal clarity on governance principles, permitting pathways and safeguards. Ocean observation initiatives should in turn deliver the data and monitoring capacities needed for research, assessment and future CRCF methodologies. 

The Strategy represents a timely opportunity to establish a coherent framework for advancing mCDR research in Europe. A precautionary approach should not mean inaction. Through sustained investment in research, monitoring and governance, the EU can reduce scientific uncertainty, uphold high environmental standards, and position Europe to lead the responsible development of marine carbon dioxide removal where it proves safe, effective and societally beneficial.