IOGP Europe recommendations to address the implementation challenges of the Net-Zero Industry Act’s (NZIA) 2030 CO2 injection capacity objective

We welcome the European Commission’s recognition of carbon capture and storage (CCS) as a critical tool for industrial decarbonization. While the NZIA goal reflects the urgency of emission reductions, it introduces an obligation to reach at least 50 Million Tonnes Per Annum (Mtpa) of operational CO₂ injection capacity by 2030 to be achieved by oil and gas producers as designated by Commission Decision.

The scale and timeline of this unprecedented investment obligation under EU law ignores key technical, regulatory, and logistical barriers. It does not take into account the practical and legal constraints associated with its implementation and de facto imposes challenging expectations.

As it is currently, this injection capacity objective and the Delegated Regulation (DR) on identifying authorized oil and gas producers, risk undermining both the goals they seek to achieve and investor confidence, thus weakening decarbonisation efforts.

We call on EU institutions to ensure a pragmatic, market-driven approach to establish an attractive business case for the entire CCS value chain (capture, transportation, and storage), including all the flexibility needed for implementation. 

This paper proposes targets and implementable solutions to make the NZIA CO₂ storage obligation achievable, without weakening the objective to develop the CCS value chain in Europe. This is necessary in light of some major challenges faced by obligated entities:

1. The obligation is imposed retroactively on oil and gas producers based on past production, regardless of their access to storage licences or proximity to viable storage sites. This creates legal and investment uncertainty, undermining investor confidence and deterring future oil and gas investments in the EU, which are needed to support security of supply.
2. The Commission Decision identifying the companies subject to a NZIA investment obligation was adopted at the end of May 2025, entering into force following only the minimum two-month legislative scrutiny period. At the same time, Article 23(4) of the NZIA requires these companies to submit to the Commission, by the end of June 2025, “a plan specifying in detail how they intend to meet their contribution to Union CO₂ injection capacity objective by 2030.” In many cases, short deadlines make compliance difficult.
3. Experience demonstrates that completing a CO₂ storage project typically require over 10 years to progress from conception to first CO₂ storage injection. Setting, in 2025, an obligation on companies to bring storage operational by 2030 ignores the realities of operations on the grounds and is therefore very challenging to achieve.
4. The legal framework for the EU CO₂ transport is expected to be tabled by the European Commission in 2026; therefore, it is highly unlikely to be transposed into national law in time for 2030. This makes investing in the networks needed to transport CO₂ to storage sites problematic and risky on a timescale commensurate with the 2030 storage obligation.
5. There is currently very little incentive for EU industry to invest in CO₂ capture equipment and to contract for transportation and storage. The Emission Trading Scheme (ETS) price is not at the level needed to enable this, and whether it will be high enough by 2030 is, at best, uncertain. Whilst the European Commission has identified important potential de-risking support mechanisms in the Industrial Carbon Management Strategy (ICM) and in the Clean Industrial Deal (CID), it is unclear when and at what scale they will become effectively available.

To make the obligation practical, cost-effective, and implementable, this paper calls in particular to:

1. Provide flexibility and implement derogation through foreseen secondary legislation under NZIA Article 23 (12).
2. Enable access to CO₂ storage outside the EU.
3. Recognize CO₂ storage sites having taken Final Investment Decisions (FID) by 2030 as compliant.
4. Establish effective de-risking mechanisms for the entire CCS value chain.
5. Ensure cross-border interoperability in CO₂

These recommendations also focus on ensuring that the storage obligation is achieved in a cost-effective manner, reflecting the competitiveness objective introduced by the CID. Without the proactive adjustments and flexibilities regarding the storage target obligation, the target is unlikely to be achieved and will necessarily increase the cost of decarbonization for industry.