The European Commission’s Industrial Carbon Management Strategy only delays the inevitable, as the discussion on where and under what conditions carbon capture is deemed (politically) acceptable will have to be picked up by the next Commission.
The EU is getting serious about carbon management
As Europe fully decarbonises its economy it will be necessary to permanently store some CO2 emissions as a complement to other mitigation efforts including waning off fossil fuels. Carbon capture, storage (CCS) or utilisation (CCU) however remain concepts more than a reality in Europe, despite previous unsuccessful attempts.
The industrial carbon management strategy (ICMS) marks a new stage for carbon management in Europe.
The strategy acknowledges some of the challenges of CCS deployment and provides some genuine answers to the decades-old chicken and egg problem, i.e. the intricacies of coordinating investments where those seeking to capture emissions will not do so until access to transport and storage infrastructure is certain, while potential infrastructure developers hold off investments until they know what volumes of CO2 to expect.
Doubling down on the CO2 storage targets of the Net-zero Industry Act (NZIA) and the regulatory foundation of the CCS Directive, the strategy has mainly provided a way forward for the ‘transport and storage parts of the value chain.
One of the main novelties is the focus on creating open-access transport infrastructure, the call for coordinated planning with electricity and hydrogen infrastructure development, as well as the introduction of CO2 standards to facilitate cross-border interoperability.
A technocratic rather than political strategy
The Commission seems to have avoided, however, the tough political decisions on the first part of the value chain, namely where CO2 will be captured.
The strategy shies away from specifying what the high-value carbon capture applications are and where public support should be targeted. Rather, it merely provides broad estimations of forecasted quantities of captured, used, and stored CO2 from ‘process emissions’, ‘fossil fuels’, ‘biogenic emissions’, and ‘air’ based on unclear assumptions and without differentiating the most climate-positive use cases.
Without more granularity and transparency, the strategy risks painting carbon capture as a catch-all solution.
This technical approach stands in contrast with the fierce political debates raging in Europe as to where capturing emissions is deemed acceptable, including in the context of COP28 where the Council signalled that carbon management should mainly be targeted to “hard-to-abate” sectors; or in the context of the NZIA where several lawmakers in the European Parliament urged for targeting CCS only for so-called “unavoidable emissions”.
The strategy does not speak clearly enough to these political dynamics. This may be due to it coming at the end of the Commission’s mandate; a lack of sufficiently clear political guidance; or might signal a potentially ‘less political’ next Commission. In any case, most of the burden of devising sectoral plans, managing public acceptance, and introducing incentives for economic operators are left with the Member States.
The timid approach to these political questions leaves many unsatisfied, if not concerned, especially those seeing the strategy not as a technical modelling exercise, but rather as a political signal for a potential over-reliance on CCS, CCU, and carbon removals to the detriment of other mitigation options.
What needs to come next?
The strategy should be seen as the starting point of what will likely be a messy and iterative political process. With this opening gambit, the Commission has now put the ball in the court of the Member States.
The development and implementation of the ICMS will have to continuously reconcile and conform to further political signalling, including from:
- Member States’ emerging carbon management strategies and updated National Energy and Climate Plans, which now request governments do be more explicit about CCS;
- Ongoing international conversations about fossil fuels phaseout and the role of carbon management;
- Possible political guidance from the European Council in the context of pending discussions on the 2040 ambition level and the enabling conditions to deliver it.
Ultimately, the publication of the ICMS has demonstrated the need for an EU-level political debate on its development and implementation. This will need to happen sooner rather than later for carbon management solutions to scale up in time to meaningfully contribute to reducing emissions where few alternatives exist. The next Commission will need to be ready to facilitate that debate.