Event:16 September | Carbon Removal Policy Summit
No Wasted Opportunities: Embedding Carbon Removal in the Management of Wastewater, Concrete, and Mine Waste
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No Wasted Opportunities: Embedding Carbon Removal in the Management of Wastewater, Concrete, and Mine Waste

Co-authored with Deloitte, this report identifies wastewater management, concrete recycling, and mining waste as largely overlooked sectors that could play a critical role in scaling high-quality carbon dioxide removal across Europe.

Carbon Gap|21 April 2026
We worked in partnership with Deloitte North and South Europe,  to identify a largely overlooked opportunity to embed CDR into three existing industrial sectors: wastewater management, concrete recycling, and mining waste management. By integrating CDR into processes that are already happening at scale, these sectors could shift from being emissions sources to becoming part of the climate solution.

Sectors with big potential

The report highlights a largely overlooked opportunity; wastewater management, concrete recycling, and mining waste management could play a critical role in scaling carbon dioxide removal (CDR), a set of approaches that remove CO2 from the atmosphere and store it durably, in Europe. By embedding carbon removal into existing industrial processes, these sectors could shift from being emissions sources to becoming part of the climate solution, at a time when Europe urgently needs to scale high-quality CDR.

Significant potential, but barriers remain

The amount of carbon that could be removed could potentially exceed the amount of greenhouse gas emissions created by these three sectors. Crucially, the economic impact of integrating CDR appears minimal – wastewater management would likely see minimal effects on end-user prices, while concrete recycling would face only marginal cost increases. For mining waste, however, cost implications remain uncertain and require further research.

Despite this potential, deployment remains at an early stage. The report identifies key challenges, including persistent knowledge gaps, incomplete GHG inventories, and a limited number of operational projects. Weak voluntary demand and the absence of clear policy mandates further constrain progress. In addition, the lack of CO2 transport and storage infrastructure adds cost and complexity, slowing down real-world implementation.

To address these barriers, Carbon Gap, drawing on the joint analysis, recommends prioritised research efforts, dedicated public funding, and stronger monitoring and reporting frameworks. Expanding CDR purchasing schemes to include these sectors could also help create early markets and accelerate uptake.

A policy pathway to unlock CDR

The report sets out clear, actionable policy pathways within existing EU frameworks to unlock this potential.

For wastewater, extending the Urban Wastewater Treatment Directive to include GHG emissions or even carbon removal targets would create a clear signal for deployment. In concrete recycling, setting minimum carbonation requirements for recycled concrete aggregates, establishing harmonised EU standards on the maximum content of (carbonated) recycled concrete aggregates in new concrete, and leveraging public procurement can drive adoption at scale. For mining waste, introducing GHG emissions targets in the Extractive Waste Directive and recognising enhanced mineralisation as a best available technique under the Industrial Emissions Directive would support innovation and investment.

Europe’s path to climate neutrality will depend not only on the innovators that are introducing new CDR technologies, but also on rethinking existing policy frameworks to provide the foundation for further scaling up and technological leadership. Embedding CDR into waste streams offers a scalable, cost-effective, and underused solution for meeting the net-zero goals.

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