IOGP response to the roadmap on the modification of the General Block Exemption Regulation (GBER)
This document provides IOGP’s response to the roadmap on the modification of the General Block Exemption Regulation (GBER) for the Green Deal and the Industrial and Digital Strategies.
Context
National governments usually require EU approval for subsidies to domestic businesses, to avoid giving them an unfair advantage over other EU competitors. Under the GBER, certain subsidies can be exempt.
IOGP believes that the State aid framework, including the GBER, should facilitate investments in promising, innovative and scalable technologies that facilitate large-scale carbon emission reduction and management projects while maintaining the functioning of the internal energy market.
Regulations and exemptions should be aimed at allowing for European industries to deliver the scale of projects required to meet the EU’s climate objectives, while, as a priority, maintaining competitiveness and a level playing field, and at the same time retaining key skills within the employment pool and attracting new talent.
Key Points
- The GBER should reflect new developments in CCS business models and related technologies
- Renewable and low-carbon gases, including hydrogen, should be incorporated in the GBER in a technology neutral manner
- The role of natural gas to support the transition should be recognized
- Assess notification thresholds and aid intensities in consideration of the significant investments required, including research and innovation
- Defining positive environmental benefits
- Modification of the definition of “energy infrastructure” in relation to gaseous fuels
- Modification of the Regulation as regards incentive effect
Overview
- Summary of recommendations
- Reflecting new developments in CCS business models and related technologies
- Incorporating renewable and low-carbon gases, including hydrogen, in a technology neutral manner
- Recognizing the role of natural gas to support the transition
- Assessing notification thresholds and aid intensities for environmental protection and research and innovation
- Defining positive environmental benefits
- Modification of the Regulation in terms of incentive effect
- IOGP’s preliminary proposals for modifications of the GBER
- Publications
- News
- Events
Delivering on the Omnibus I simplification mandate: IOGP Europe position on the draft Sector-Agnostic European Sustainability Reporting Standards (ESRS)
Upstream Oil & Gas and CCS operations in Europe: Perspective on a proposed EU Universal-PFAS Restriction
IOGP Europe’s response to CO₂ markets and infrastructure public consultation
IOGP Europe calls for simplification of the hydrogen regulatory framework through the Omnibus Package
IOGP Europe response to the EU Taxonomy – review of Climate and Environmental Delegated Acts consultation
Recommendations on the proposed new EU funding architecture under the MFF (2028-2034)
Joint industry letter ahead of the plenary vote on the First Omnibus Simplification Package
IOGP Europe’s response to the call for evidence on the General Block Exemption Regulation (GBER)
Amended ESRS Exposure Draft July 2025 Public Consultation Survey
Ten action points for a Hydrogen Grids Strategy
IOGP Europe’s response to Draft T&Cs for the H2 Bank third auction
IOGP Europe input to the Public Consultation on the methodologies for certifying permanent carbon removals
IOGP Europe recommendations to address the implementation challenges of the Net-Zero Industry Act’s (NZIA) 2030 CO2 injection capacity objective
IOGP Europe feedback on the Call for Evidence: Simplification of administrative burden in environmental legislation
IOGP Europe input to the Call for Evidence on CO2 market and infrastructure
The Mediterranean: an energy and decarbonization opportunity for Europe
Joint Letter on EU-UK ETS Linkage
IOGP Europe views on the Grids Package
Updated European CO₂ Storage Projects Map
IOGP Europe response to consultation on the Industrial Decarbonisation Accelerator Act (IDAA) and call for evidence
Joint statement: Urgent need for European Commission to correct course on the draft Delegated Regulation on Low Carbon Fuels
IOGP Europe response to ESMA Consultation on the draft technical standards under the ESG Ratings Regulation
The upcoming Grids Package: a critical opportunity not to be missed for the deployment of a European hydrogen infrastructure
Omnibus Simplification Package: Open Letter with Eurogas and FuelsEurope
Unlocking the Black Sea’s Strategic Energy Potential
EU Hydrogen Strategy needs a fundamental reset
Simplification Omnibus Package: towards a proportionate, coherent and efficient sustainability framework for European competitiveness
Joint Letter: Accelerating investments in CO2 infrastructure
Response to the European Commission’s consultation on the draft Clean Industrial Deal State Aid Framework (CISAF)
Response to the Draft Delegated Regulation on CO₂ Injection Capacity Obligations
Omnibus Simplification Package EU Taxonomy Consultation
Public consultation on inter-temporal cost allocation mechanisms (ICA) for financing hydrogen infrastructure
Joint Position Paper – Extending the ‘Stop-the-Clock’ Initiative to Wave 1 Companies
Joint Statement: Call for action- Urgent need to recognise third country exports of gaseous fuels under the Union Database
Feedback to the public consultation on the Net-Zero Industry Act Delegated Act on primarily used components
Advancing a Competitive, Resilient, and Integrated Energy Market
IOGP Europe Response to the Consultation on the Review of the Taxonomy Climate Delegated Act
Joint Statement: Reality Check for European Hydrogen Policy to Adjust the Course
IOGP Europe recommendations for the Omnibus proposal
The Case for a European CCS Bank
Joint Trade Association Statement: Towards EU due diligence that works for all
The Joint Statement on the Low-Carbon Fuels certification draft Delegated Act
IOGP response to the public consultation on the draft Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels
IOGP Europe key principles on a future regulatory framework for CO2 transport infrastructure
Joint Letter- Harnessing the IPCEI mechanism for CCS in Europe
Joint Statement on the Low-Carbon Fuels certification Delegated Act
GasNaturally Letter to Competitiveness Council 23 May 2024
IOGP Europe key principles on a future regulatory framework for CO2 transport infrastructure
IOGP Europe recommendations on the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen
EU Taxonomy Stakeholder Request Mechanism
IOGP consultation response to draft EFRAG Value Chain Implementation Guidance (VCIG)
Download
IOGP consultation response: Rationalisation of reporting requirements
Creating a sustainable business case for CCS value chains
IOGP Europe statement on the ECHA proposed PFAS restriction proposal related to the Carbon Capture, Transport and Storage (CCS) Technology
IOGP Europe position on the EU Industrial Carbon Management
IOGP position paper on the European Commission’s public consultation on the EU climate target for 2040
IOGP Europe feedback on Net Zero Industry Act proposal
Joint industry statement on the EU Taxonomy
IOGP Europe views on the EU corporate sustainability reporting framework
IOGP input on the EU Commission’s public consultation on the EU Taxonomy Delegated Acts
IOGP position on capital requirements
IOGP response on Competitive Bidding schemes for hydrogen under the Innovation Fund
IOGP response on revamping the Strategic Energy Technology (SET) Plan
IOGP position on the Corporate Sustainability Due Diligence Directive (CSDDD)
IOGP response to the public consultation on the Hydrogen and Decarbonized Gas Market package
IOGP comments to R. W. Howarth and M. Z. Jacobson (2021): How Green is Blue Hydrogen?
Re-Stream – Study on the reuse of oil and gas infrastructure for hydrogen and CCS in Europe
IOGP response to the public consultation on the Renewable Energy Directive (RED) proposal
IOGP feedback on the Platform on Sustainable Finance’s draft report on preliminary recommendations for technical screening criteria for the EU taxonomy
IOGP feedback on the Platform on Sustainable Finance’s draft report on social taxonomy
IOGP feedback on the Platform on Sustainable Finance’s draft proposal for an extended taxonomy to support economic transition
IOGP response to public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)
IOGP Paper on metric to use for 2030 targets
IOGP input to the consultation on the Hydrogen and Gas Market Decarbonization Package
Response to consultation on costs of implementing MRV regulation based on OGMP
IOGP position on the European Commission proposal on the update of the Corporate Sustainability Reporting Directive
FuelsEurope and IOGP position on the Draft Delegated Regulation on taxonomy related disclosures by undertakings reporting non-financial information
IOGP response to the roadmap and inception impact assessment concerning revision of the 3rd Gas Package
Response to consultation on proposal for an Initiative on Sustainable Corporate Governance
Response form for the Consultation Paper on the Draft advice to European Commission under Article 8 of the Taxonomy Regulation
IOGP input to the Commission’s Delegated Regulation establishing the technical screening criteria for economic activities contributing substantially to climate change mitigation or climate change adaptation
IOGP written input to the consultation “Maritime sector – a green post-COVID future”
What’s Right? What’s Wrong? IOGP comments on the ‘EU Strategy for Energy System Integration’ and ‘A hydrogen strategy for a climate neutral Europe’
IOGP response to the inception impact assessment concerning the revision of the 2018 Renewable Energy Directive (REDII)
IOGP input to the IIA on the EC’s Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information
IOGP response to the consultation on ESG disclosures under Regulation (EU) 2019/2088
IOGP response to consultation on the renewed Sustainable Finance strategy
Funding CCS in Europe: key investments for the recovery
IOGP response to the public consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation
IOGP response to targeted consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation
IOGP input to the Roadmap on the EU Smart System Integration
IOGP input to the Roadmap on the EU strategy on hydrogen in Europe
IOGP feedback to the Combined Evaluation Roadmap/Inception Impact Assessment on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E
IOGP response to the public consultation on the revision of the NFRD
Sustainability reporting guidance for the oil and gas industry
IOGP input to the forthcoming EU Strategy for Energy System Integration
IOGP Initial Feedback to the Taxonomy: Final report of the Technical Expert Group on Sustainable Finance
Response to the inception impact assessment “Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy”
IOGP input to the Impact Inception Assessment on the Revision of the NFRD
New and old CCS projects in Europe: What’s different this time?
IOGP assessment of National Energy and Climate Plans
Scaling up Hydrogen in Europe
Hydrogen for Europe Pre-study – Key findings
IOGP assessment of draft National Energy and Climate Plans
Call for feedback on TEG report on EU Taxonomy
Hydrogen for Europe
The potential for CCS and CCU in Europe Report to the thirty second meeting of the European Gas Regulatory Forum 5-6 June 2019
IOGP response to the European Commission’s package on sustainable finance Call for a “Talanoa Platform” to guarantee a smart, inclusive and technology-neutral taxonomy
CCS: the Innovation Fund and beyond
OGP contribution to the CCS Directive evaluation
Press Release: European Parliament backs meaningful simplification of sustainability rules
New Pact for the Mediterranean: an opportunity to foster the region’s energy integration
Updated European CO₂ Storage Projects Map
EU Low-Carbon Hydrogen production rules are not the signal investors were waiting for
Press release: 2040 Climate trajectory requires urgent action on policy enablers
Press release: State Aid Framework for Clean Industrial Deal marks a turn towards pragmatic decarbonization
Press release: Low-carbon fuels methodology envisaged by the Commission will block key hydrogen production pathways
Updated European CO₂ Storage Projects Map
Joint Letter: Accelerating investments in CO₂ infrastructure
Press Release: Roadmap to end Russian energy imports will require policy signals and regulatory adjustments to succeed.
MEP Jeannette Baljeu on the Crucial Role of CCS in Europe’s Industrial Transition
Draghi Report: a pragmatic pathway to Competitiveness, Sustainability, and Resilience
Press release: Recognition of CCS on path to 2050 marks a step change, but approach to low-carbon solutions remains too narrow.
Letter: IOGP Europe recommendations on the Hydrogen and Decarbonized Gas Market Package
Letter: The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) – IOGP Europe and FuelsEurope recommendations in view of the trialogue negotiations
Letter: Strong support for an implementable and pragmatic Net Zero Industry Act Article 18 – solutions to make CCS work
Net-Zero Industry Act marks a step change in industrial and climate policy – EU paves way for carbon capture and storage scale-up
Letter: Open, inclusive, and pragmatic Green Deal Industrial Plan for Europe
Europe needs a CO2 storage ambition for 2050
Inclusion of gas in the Taxonomy Regulation supports EU ambition to reach climate neutrality by 2050
Gas market reform marks a step change in EU approach to the transition
New Re-Stream study assesses the feasibility of transport of hydrogen and CO2 in European gas and oil infrastructure
Letter: Call for a technology-inclusive revision of the TEN-E Regulation
“Hydrogen for Europe” study launch
Towards greater hydrogen production capacity in Europe
Letter: IOGP input on the European Commission’s consultation on the priority list for the development of gas network codes and guidelines for 2021 (and beyond)
Council’s inclusive approach to hydrogen sends strong signal ahead of key legislative year
Letter: 57 industry leaders call for enhancing gas contribution to decarbonisation
Sustainable Finance Webinars
Carbon Management Webinars
EU’s hydrogen and energy system vision can only succeed with a more balanced, inclusive approach
Wide industry coalition call for a Hydrogen Strategy inclusive of all clean hydrogen pathways
IOGP Statement on the EU Recovery Plan
Joint letter: CCS and CCU for the EU’s Industrial Transition
Hydrogen for Europe: 1st Working Group Meeting
The Europe CCUS & Hydrogen Decarbonisation Summit
Re-Stream Study Launch Event
Hydrogen4EU Launch Event
Sustainable finance: investor, oil and gas sector and global perspectives
Carbon Management Webinars
Sustainable finance: non-financial disclosure for the oil and gas sector and EU taxonomy in practice
