Carbon management is an emerging future market. Within the EU, there is a clear regulatory framework through the Emissions Trading System (ETS). CO₂ is priced, and by 2039 at the latest, no more emissions certificates will be allocated to companies in Europe.
The price of CO₂ will increase. More and more companies are therefore investing in CCX solutions to secure their market position in this growing field and gain early access to relevant technologies and projects.
As part of due diligence in lending, the question of how companies reduce or avoid CO₂ emissions plays a key role – partly due to ESG requirements. A comprehensive carbon management approach offers future-proof solutions to strengthen competitiveness.
To create investment security, funding impulses from federal and state governments are also needed. The EU already provides funds through the Innovation Fund, and with the planned Bank for Industrial Decarbonisation, public financing will be further strengthened. A coordinated funding strategy is needed that provides companies with uncomplicated access to public financial facilities. A market-oriented funding approach is required to reduce financing risks in the early market ramp-up phase. Currently, it is unpredictable what the CO₂ price will be in 2030 or 2040, which creates uncertainty for investors. At the national level, climate protection contracts must also be opened to CCX technologies. In particular, projects that integrate hydrogen and CO₂ could be quickly incorporated into the existing funding structure.
Rising CO₂ prices due to the EU Emissions Trading System, EU taxonomy, and the Net-Zero Industry Act (NZIA).
CCX solutions address emissions at all levels (Scopes 1–3).
The NZIA stipulates that by 2030, the production capacity of strategic net-zero technologies must cover at least 40% of the EU’s annual demand. This opens up new market opportunities.
Sustainability is becoming a condition for investment. Companies with a robust climate strategy use the regulatory framework to secure a strong market position now.
The German government should also cover investment risks for CCX technologies through climate protection contracts (Carbon Contracts for Difference, CCfD). These risks arise from fluctuations in the CO₂ price within the EU Emissions Trading System (ETS). CCfDs help ensure that industrial CO₂ reduction projects can implement climate protection measures at competitive prices. Projects awarded a contract receive guaranteed payments to bridge the gap between their base offer price (cost of CO₂ reduction per ton) and the ETS carbon price. If the ETS CO₂ price rises above a certain threshold, companies are obligated to repay part of the surplus to the state. This enables a market-based ramp-up of the CO₂ market.
Furthermore, close coordination with funding instruments at EU and national levels is needed. Unbureaucratic solutions are required to keep cost premiums low in private sector financing models.
Carbon Management includes all measures that avoid, reduce or permanently neutralize CO₂ emissions. Two key approaches are:
With CCU, CO₂ is captured from industrial processes or directly from the air and used as a valuable raw material – for example, in the production of synthetic fuels, plastics or construction materials. This returns CO₂ to the cycle, conserves resources, and reduces emissions.
CCS refers to the capture of CO₂ and its safe, permanent storage in geological formations such as depleted gas and oil fields. This technology is indispensable for neutralizing hard-to-avoid or unavoidable emissions and achieving climate targets.
CO₂ capture has a history of nearly 100 years. In addition to capturing CO₂ from energy production and industrial processes, “greenhouse gas-neutral” CO₂ can also be obtained from the combustion of biomass. The goal must be to establish a CO₂ circular economy.
The establishment of a transport infrastructure for CO₂ is an infrastructural task that needs to be financed. This cannot be achieved solely with public funds. To enable private actors to participate in the demand-driven construction of the infrastructure, some fundamental decisions need to be made early on.
It is unclear who will be responsible for the establishment (and operation) of the infrastructure in the future. We advocate for legal structures in the sense of a regulatory framework that allow various market participants in the energy sector to operate privately in construction and operation.
This also means developing conceptual considerations for the overall transport network and its components in order to enable implementation by different participants in coordinated steps.
Private investments in infrastructure work when supply and demand exist. In this regard, comparable to the project of the "hydrogen core network," it must be considered that substantial preliminary investments by private companies can only occur if later amortization of the investments is possible. This requires sufficiently concrete revenue prospects which – presumably combined with initial CAPEX subsidies – are enough to refinance the investments. Questions such as pricing (both in the ramp-up phase and after market establishment) play a decisive role in revenue expectations. It should be urgently reviewed whether the instruments chosen for financing the hydrogen core network are suitable to build a CO₂ transport infrastructure.
It is understandable that currently no fee mechanism for network usage is specified. However, from the private sector's perspective, reliable statements are needed about the direction in which the infrastructure is to be developed.
Germany must realign its industrial policy and strategically invest in CO₂ capture, utilization, and storage (CCX) to secure climate goals and competitiveness.
Reliable regulation that reduces bureaucracy and integrates CCU into the EU Emissions Trading System is crucial for investment and technological leadership.
As free CO₂ certificates are gradually phased out, CCX becomes the key solution for ensuring that industrial production remains climate-friendly and competitive.
Germany must undergo an economic policy realignment. The focus must return to strengthening the competitiveness of industry in Germany and Europe. A key lever for this is CCX – Carbon Capture, Utilisation and Storage. Without these technologies, neither the climate targets nor the strengthening of industrial locations can be achieved. For companies to invest in carbon management technologies, reliable regulatory frameworks are needed.
On the demand side, there is already a growing need for CO₂ transport, utilization, and storage services – especially from hard-to-decarbonize sectors such as industry, waste management, and air and maritime transport.
On the supply side, companies in Germany and Europe are among the global technology leaders in CO₂ management. To strengthen this position, clear regulatory requirements are needed. These must also include reducing bureaucracy, accelerating approval processes, and supporting market ramp-up. A central lever is the integration of CCU (Carbon Capture and Utilisation) into the EU Emissions Trading System (EU ETS).
So far, industrial companies have received free CO₂ certificates from the EU ETS under certain conditions to cushion competitive disadvantages in the global market. However, by 2030 the number of free certificates will drop significantly, and from 2034 the free allocation will cease entirely for all sectors. As compensation, companies can access funds from the significantly expanded EU Innovation Fund. However, they must apply, and whether they receive funding is uncertain.
From around 2039, the EU ETS certificate budget will likely be exhausted. CCX creates the conditions to implement these regulatory requirements while maintaining industrial competitiveness.
Additionally, CO₂ capture and utilization form the basis for a CO₂ circular economy – especially in the chemical industry. Carbon-based products remain essential even in a climate-neutral economy, such as in chemicals, industry, or synthetic fuels.
The scope of the EU ETS 1 is being expanded to include the maritime sector. It will cover all emissions from journeys within the European Economic Area (EEA – EU) as well as port emissions. Emissions from voyages arriving from outside the EEA or departing from the EEA to outside are 50% covered. The inclusion of maritime transport will be phased in starting in 2024. In the first reporting year, maritime shipping companies will only have to surrender allowances for 40% of verified emissions. This share will increase to 70% in 2025 and then to 100% from 2026 onward. For the years 2024 and 2025, a corresponding amount from the auction volume will be cancelled for the emissions not covered by allowances.
Ports will play a key role in intra-European trade (EU, EEA, and the UK) for the handling of CO₂ for CCU. They are strategically important in the operational setup of CCU/CCS value chains. At the same time, they serve as infrastructure hubs for storing CO₂ beneath the seabed. Thus, ports make a significant contribution to industrial decarbonization and climate protection.
Carbon management is the lever for the market ramp-up of green hydrogen. The captured CO₂ is transported to facilities that convert the CO₂ together with green hydrogen into synthetic fuels. The energy required for this usually comes from renewable sources. The CO₂ produced in this process is captured again in the industrial sector, thus closing the cycle.
Synthetic fuels are already used today in the transport sector, especially in maritime and aviation sectors. The CO₂ is used multiple times before it reaches the atmosphere. Carbon capture is a bridging technology that already enables a massive reduction in greenhouse gas emissions. In the long term, CO₂ from natural sources such as biomass should be made available to achieve full climate neutrality.
Public perception reveals a differentiated picture regarding acceptance, especially of CCU and CCS technologies and the associated transport infrastructure. This is quite different for projects such as forest reforestation, which enjoy broad support.
With the introduction of CCS legislation, Denmark also focused on strengthening social acceptance and actively engaged in dialogue with its citizens. Today, the vast majority of the Danish population supports CCS technology. Carbon management, alongside the expansion of renewable energies, is a key factor in achieving climate goals. Technologies like CCU and CCS enable the management of unavoidable emissions. At the same time, industrial value creation, economic growth, and climate protection are advanced together.
Partner, Watson Farley Williams
Senior Business Development Manager Everllence SE
Head of Industry and Associations, BVCMS
Head of Industry and Associations, BVCMS
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The Federal Association Carbon Management Solutions (BVCMS) welcomes the new coalition's immediate program. The Carbon Storage and Transport Act (KSPtG) is to be initiated within the next hundred days – this is a first step in the right direction.
The "if" has been decided. Now the "how" of implementing the carbon management strategy is the focus,” says Markus Rosenthal, Managing Director of BVCMS. Effective climate protection requires the capture, use, or storage of CO₂. From 2039, companies must produce climate-neutrally since from that date the EU greenhouse gas certificate budget will be exhausted. Germany’s industry must then achieve negative emissions on a broad front.
This requires investments. To strengthen investment security, it is now important to advance technology openness, clear regulations, accelerated approval processes, and the strengthening of social acceptance. Furthermore, national incentives for private investments in capture and infrastructure projects are needed. This also includes integrating carbon management into the structure of CO₂ difference contracts.
The London Protocol must be ratified. “This is a prerequisite for Germany to trade CO₂ with its neighboring countries Belgium, Denmark, the Netherlands, Norway, Austria, and the United Kingdom and thus strengthen cooperation,” says Markus Rosenthal. These countries are far ahead of Germany with their national carbon management strategies.
At the EU level, the federal government should advocate for an opening clause in emissions trading to recognize CCU as negative emissions. An industrial decarbonization bank under the European Investment Bank’s umbrella is also needed. Germany must initiate the necessary legislative process to establish this financial institution in Brussels. Europe is still leading compared to China and the USA in carbon management technologies. This position must be strengthened.
The Federal Association Carbon Management Solutions (BVCMS) welcomes the new coalition's immediate program. The Carbon Storage and Transport Act (KSPtG) is to be initiated within the next hundred days – this is a first step in the right direction.
Statement of the Federal Association Carbon Management Solutions e.V. (BVCMS) on the draft law amending the Carbon Dioxide Storage Act, Federal Ministry for Economic Affairs and Energy
Industrial Decarbonisation Accelerator Act – speeding up decarbonisation
In spring 2025, the Carbon Dioxide Storage and Transport Act (KSpTG) was passed, allowing commercial CCS/CCU projects, legally securing CO₂ pipelines, and promoting offshore storage. Additionally, the EU established a Delegated Regulation on the CCS infrastructure quota for energy companies.
Starting in 2033, the free allocation of CO₂ certificates under the EU Emissions Trading System for energy-intensive sectors such as cement, steel, and chemicals will end. By 2036, this free allocation will be fully abolished. Companies will then have to offset their emissions either through reductions or by purchasing certificates. For unavoidable emissions, technologies like CCS (Carbon Capture and Storage) and CCU (Carbon Capture and Utilization) are being discussed as solutions.
June 17, 2025, digital
EU Innovation Fund
Financing low-carbon technologies
Stefanie Hiesinger, European Commission
Industrial Decarbonisation Bank
Promoting industrial emissions reduction
Aymeric Amand, ZEP
May 22, 2025, 11:00–12:30 (English)
Dan Allason
Head of Research and Innovation, DNV
CO₂ Research: History & large-scale equipment testing
Andy Cummings
Senior Principal Consultant, DNV
Jeremiah Dutton
Business Developer, Green Hydrogen, InnoEnergy
CarbFlex: Creating the European CO₂ Value Chain
May 7, 2025, 10:00–11:30
Gesine Ruetz
Head of Unit, Climate-Neutral Economic Transformation, Hydrogen/PtX, Carbon Management
Ministry for Economy, Industry, Climate Protection and Energy, NRW
Carbon Management Strategy Implementation in NRW – Support from Federal Government?
Dr.-Ing. Marcel Loewert
Senior Sustainability Manager
Infraserv GmbH & Co. Höchst KG
CCUS in Chemical Parks – Needs, Best Practices & Challenges at Industriepark Höchst
Feb 12, 2025, Webex, 10:00–11:30
Dr. Jörg Rothermel
Head of Industry and Policy
Speaker
Dec 12, 2024, Webex, 10:00–11:00
Eadbhard Pernot
Managing Director, Zero Emission Platform (ZEP)
Topic: Carbon Management under the next EU Commission: What to expect? (in English)
Nov 26, 2024, Webex, 10:00–14:30 CET
Topic: Carbon Management
Dr. Christian Bauer
Partner, Watson Farley & Williams
"Current considerations on financing CO₂ capture, transport, and storage"
Dr. Niklas Niemann
Partner, SMP Strategy Consulting
"Carbon Capture, Transport and Storage: Advances in point-source capture at industrial facilities – the need for transport infrastructure – perspectives on storage and utilization"