Market Design Options for CCS in Europe: CO2 Transport and Storage Regulation

In CERRE’s latest Issue Paper, Prof. Catherine Banet reviews the key tenets of the EU regulatory regime for CO₂  transport and storage infrastructures. The paper highlights the necessity of reflecting on the evolving scope and the diversity of transportation modes in CCUS activities. It underscores the importance of a full value chain approach and a flexible, multi-modal approach to CO₂ transportation and storage.

Key Findings

The author identifies six building blocks for a future CCS market design: 1) transport network planning; 2) permitting of CO₂ transport and storage; 3) ownership and unbundling; 4) system operatorship; 5) access to transport and storage capacities; 6) regulatory oversight & dispute settlement.

Key policy recommendations include:

• Establishing legal definitions of key infrastructure types, such as for “CO₂ network” or ” CO₂ terminal”;
• Addressing the lack of alignment and coordination in the planning of different segments of the CO₂ value chain;

Determining the appropriate level of regulatory intervention for different transport modes at the EU level, ensuring a level playing field among EU and market actors;

• Facilitating the development of a flexible and multi-modal transportation system between the industrial clusters, the export infrastructures and the storage sites to ensure cost-effective and timely development of CCS value chains and risk mitigation;
• Clearly defining the role of the system operator, and adapting to the types of transport and storage infrastructure;
• Adopting a phased regulatory approach to the application of the full regulatory regime;
• Considering bundled transport and storage capacity offerings in the early stages of market development;
• Foreseeing the establishment of a legal basis for future network codes and guidelines for CO₂ transport and storage;
• Providing clarity on regulatory oversight, as well as dispute settlement mechanisms.

The Issue Paper was presented and debated on 20 March 2025, during the CERRE public webinar “Market Design Options for CO2 in Europe“.

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