Positions

Stellungnahme
07-04-2025

Statement on the draft bill to amend the Carbon Dioxide Storage Act

The present draft bill to amend the Carbon Dioxide Storage Act creates the basis for the legally secure application of CCU/S technologies and the development of a CO2 infrastructure for the first time. The German Carbon Management Initiative (DCMI) expressly welcomes this step – but calls for targeted improvements to ensure investment security and to future-proof Germany as an industrial and infrastructure location in the European CO2 market.

Transport von CO2
03-17-2025

Position paper Carbon management – Creating a framework for CCU/S projects in Germany and Europe

The German government’s carbon management strategy is a key step towards reducing emissions that are difficult to avoid and creating negative emissions. It must be dovetailed with the hydrogen and biomass strategy. At the same time, an EU-wide carbon market and global business models are needed to establish a circular carbon economy.

FAQ

What role can carbon management play as a complement to emissions avoidance?

Carbon management complements emissions avoidance where technical or economic limits have been reached. In many industrial processes, unavoidable CO2 emissions are produced even when operating at maximum efficiency and using renewable energy. CCU/S makes it possible to capture, utilise or permanently store these emissions.

Carbon management does not compete with avoidance, but rather complements it in a targeted manner. International analyses show that climate neutrality cannot be achieved without CCU/S. In combination with efficiency, renewable energies and process changes, carbon management is an indispensable component of a realistic and industrially viable climate protection pathway.

How can CCU/S contribute to industrial competitiveness?

CCU/S enables emission-intensive industries to decarbonise their production whilst safeguarding value creation, jobs and investment in Germany. Companies can limit CO2 costs and reduce regulatory risks without relocating production capacity abroad.

The development of a CO2 value chain also creates new business models, technological expertise and export opportunities. At the same time, CCU/S-capable infrastructure ensures connectivity to emerging European CO2 markets. Carbon management is thus an industrial policy instrument for transformation and for securing international competitiveness.

In which industrial sectors can CCU/S technologies be used?

CCU/S is used in particular in industries with unavoidable process-related emissions. These include, above all, the cement and lime industries, the chemical and steel industries, refineries and the waste management sector.

CCU/S also plays a key role in biomethane production and the manufacture of low-carbon hydrogen. These sectors generate emissions for which there are currently no complete alternatives in sight. CCU/S offers a practical and scalable solution for reducing emissions and is a central component in the transition of these industries towards climate neutrality.

What options are there for utilising CO2?

CO2 can be utilised as a raw material, for example in the chemical industry for the production of methanol, synthetic fuels, polymers or hydrogen derivatives. CO2 is also used in the building materials industry, for instance through mineral binding in concrete or cement.

These applications can replace fossil raw materials and contribute to the circular economy. At the same time, it is clear that not all captured CO2 can be utilised; storage remains necessary. For the market ramp-up of CO2 utilisation, clear regulatory frameworks, crediting rules and economic incentives are required.

Why are economies of scale crucial to the cost-effectiveness of CCU/S?

CCU/S is capital-intensive but becomes significantly more cost-effective as the scale increases. Larger capture plants, shared transport pipelines and central storage facilities reduce the cost per tonne of CO2 considerably. Standardisation and operational experience help to reduce both capital and operating costs.

Economies of scale are essential for transitioning CCU/S from pilot projects to industrial application. Shared cluster and infrastructure solutions are therefore key. They avoid inefficient parallel structures, reduce overall economic costs and enable a structured market ramp-up of carbon management technologies.

How can significant quantities of CO2 be captured and transported cost-effectively?

Pooling emissions within industrial clusters is key to cost-effective CO2 transport. Clusters generate sufficient volume for shared transport and storage infrastructure, thereby reducing the cost per tonne of CO2.

At the same time, they reduce investment risks, facilitate approvals and enable a phased expansion of infrastructure. Industrial clusters are also suitable as pilot sites for testing technologies, business models and regulatory processes. They thus form the basis for a scalable and cost-effective roll-out of carbon management infrastructure.

What transport solutions are available for CO2?

CO2 can be transported by pipeline, ship, rail or lorry – depending on the volume, distance and stage of development. For large and continuous volumes, pipelines are the most cost-effective solution in the long term and form the backbone of future CO2 networks.

During the ramp-up phase, multimodal transport solutions play an important role. They also enable smaller or decentralised emitters to access storage and utilisation infrastructure. The combination of different transport options creates flexibility and enables a gradual, market-driven expansion.

What role do port locations play in CO2 exports and international supply chains?

Port locations are key hubs for international CO2 supply chains. They connect industrial emission sources with regions that have large geological storage capacities, such as Norway, the Netherlands or Denmark.

At CO2 terminals, the gas is liquefied, temporarily stored and transported by ship to offshore storage sites. Ports thus enable scalability and flexibility during the ramp-up phase and ensure Germany’s connection to the emerging European CO2 market.

Is transporting CO2 via pipeline safe?

Yes. Transporting CO2 via pipeline is a technically proven and safe method. Internationally, there are decades of operational experience with thousands of kilometres of CO2 pipelines. In Europe, strict legal and technical requirements apply, based in part on the EU CCS Directive.

Modern pipelines are equipped with continuous monitoring, automatic shut-off systems and leak detection. Their construction and operation are subject to comprehensive licensing and inspection requirements. CO2 pipelines are therefore a safe and proven transport solution for large volumes.

What happens in the event of a leak – for example, in a CO2 pipe?

CO2 pipelines may only be operated in accordance with comprehensive safety and emergency response plans. These are regularly reviewed and updated. In the event of an incident, multi-stage safety mechanisms are activated, such as automatic pressure relief, shut-off valves and defined emergency response plans.

In addition, pipelines are continuously monitored to detect anomalies at an early stage. The technologies used are based on decades of experience in pipeline operation. The aim is to minimise risks preventively and to manage incidents safely using technical means.

How is CO2 kept safely stored underground?

CO2 is stored in deep geological formations that are reliably sealed by dense cap rocks. In addition, several natural trapping mechanisms come into play: CO2 remains trapped in the rock’s pore spaces, dissolves in saline water and, over the long term, reacts with the rock to form solid carbonates.

These mechanisms work together and in a staggered manner. Their effectiveness has been scientifically proven and confirmed by international projects with decades of operational experience. Geological storage is therefore permanently safe and controllable.

How is the long-term monitoring of CO2 storage sites ensured?

CO2 storage sites are subject to legally mandated long-term monitoring and post-closure obligations. Even before they are commissioned, storage sites undergo geological testing and assessment. During operation, continuous measurements are taken, for example of pressure, seismic activity and material flows.

Monitoring is also required after decommissioning until long-term stability has been demonstrated. Only then can responsibility be transferred. The requirements are based on the EU CCS Directive and ensure transparency and environmental protection.

What impact does CO2 have on groundwater?

CO2 is stored exclusively in deep geological formations, well below usable aquifers. There are several natural barriers between the storage site and the groundwater, in particular impermeable cap rocks.

Sites are thoroughly assessed in advance and continuously monitored during operation. Under these conditions, the risk of any impact on groundwater is extremely low. The protection of drinking water resources is legally safeguarded by strict European and national regulations.

What role does biogenic CO2 play in achieving climate targets?

Biogenic CO2 originates from the natural carbon cycle. When it is captured and permanently stored, this results in a net removal of CO2 from the atmosphere. Unlike fossil fuel emissions, no additional carbon is released.

Biogenic carbon management thus enables negative emissions, which are necessary to offset unavoidable residual emissions. It is a key component of long-term climate strategies – provided that crediting, regulation and infrastructure are clearly defined.

In which sectors is significant biogenic CO2 currently produced?

Significant quantities of biogenic CO2 are currently generated in sectors such as biogas production, waste-to-energy processes involving biogenic materials, the pulp and paper industry, as well as in sewage treatment plants and biomass power stations.

Many of these sources already provide relatively pure CO2 streams that can be efficiently captured. They offer potential for negative emissions, particularly in rural areas. Technologies such as BECCS are considered necessary in virtually all climate scenarios to offset residual emissions.

Does CCU/S prolong the use of fossil fuels?

No. CCU/S follows the principle of ‘prevention before capture’ and is clearly defined by law. CCS is not a tool for coal-fired power stations and is no substitute for renewable energy or efficiency measures.

CCU/S is used specifically where emissions cannot be avoided, such as in the basic materials industry. Without CCU/S, there is a risk of relocation and carbon leakage. Carbon management accelerates the transition rather than delaying it, and ensures climate protection under realistic conditions.