Since 2012, CO\u2082 storage in Germany has only been permitted for strictly limited research purposes; CO\u2082 transport across national borders is not permitted. Germany has thus transposed EU Directive 2009\/31\/EC on the geological storage of CO\u2082 into national law.<\/p>\n\n\n\n
The background to the restrictive implementation was the political fears of the Greens that CCS technology could undermine the phase-out of coal-fired power generation. As a result, ongoing research work and demonstration projects on CCS were discontinued (e.g. Vattenfall CCS plant at the Schwarze Pumpe coal-fired power plant; planned CCS plant at the RWE lignite-fired power plant in H\u00fcrth), and only very few small research and pilot projects were continued in Germany (e.g. piloCO2 scrubbing plant at the RWE lignite-fired power plant in Niederaussem).<\/p>\n\n\n\n
While the development of CCS projects continued in other EU countries, the USA, Canada and China, it was not until the end of 2022 that studies were published in Germany (including by research institutions close to the Greens, such as the Wuppertal Institute) pointing to the indispensability of CCS for achieving the climate targets in Germany (and NRW). In 2023, the EU also officially declared that the climate targets could not be achieved without CCS and in 2024 an EU target for CCS of 50 million tons of captured and stored CO\u2082 per year by 2030. In spring 2024, the BMWK presented a key issues paper for a national “Carbon Management Strategy”, which was adopted by the German government in May 2024.<\/p>\n\n\n\n
Despite the end of the traffic light coalition, the draft of the “Carbon Dioxide Management Strategy” Act (KMS) was passed by the cabinet in Nov 2024, but was no longer tabled in the Bundestag due to reservations on the part of the Green and SPD parliamentary groups. (The CDU had signaled its approval and the law could have been passed in Dec\/Jan 2025). By not adopting KMS and the amendment to the “Carbon Dioxide Storage and Transportation Act” (KSpTG), further time was lost. At the same time, the necessary amendment to the KSpTG and ratification of the “Addendum to the London Protocol” (regulating the transportation of CO\u2082 across national borders) were being prepared.<\/p>\n\n\n\n
The EU is also working on further developing its strategy for the capture and storage of CO\u2082 in order to achieve its climate targets, including the adoption of the Industrial Carbon Management Strategy by the European Commission on February 6, 2024.<\/p>\n\n\n\n
In addition to the strategy, the guideline documents on geological CO\u2082 storage were updated in July 2024 in order to optimize approval procedures and support sustainable CO\u2082 storage solutions in the European Economic Area. An EU target of 250 million t\/a for CO\u2082 storage via CCS is envisaged for 2040.<\/p>\n\n\n\n
The KMS assigns CCUS a supplementary role as part of the national pathway to achieving the climate targets (“net zero”), which essentially sees the application of CCUS for “hard-to-abate” sectors (cement, lime, waste incineration, etc.). These represent the priority sector of a five-stage gradation (sector scoring) of possible CCUS applications:<\/p>\n\n\n\n
Politically, CCUS would therefore be “desirable” in cement, lime, waste incineration plants, chemicals and steam crackers. It would be tolerated, but not promoted, in iron production (DRI with natural gas), in the glass industry or for the production of blue hydrogen; politically, it is viewed critically in the paper, aluminum, blast furnace and power generation sectors. In the electricity sector, the expansion of renewable sources should have absolute priority, with CCS being more of an exception in certain areas: Thus, a connection for CHP power plants, industrial power plants, and gas-fired power plants (each without public funding) to the national CO\u2082 core network is possible, but a connection of coal-fired power plants is prohibited. CO\u2082 storage is primarily planned abroad (Norwegian North Sea), as well as offshore in the German North Sea (Germany’s exclusive economic zone); there is also an “opt-in” rule for federal states, which could then also allow CO\u2082 storage onshore.<\/p>\n\n\n\n
The comprehensive draft law leaves a number of questions unanswered, including:<\/p>\n\n\n\n
The adaptation of the KSpTG is necessary for the development of a CO\u2082 transport core network and CO\u2082 storage in Germany. Initial drafts for a CO\u2082 core network as part of a north-west European CO\u2082 core network are available (e.g. from OGE: approx. 4,500 km, costs \u20ac9\u201314 billion). Ideally, the KSpTG would also clarify the issue of financing the CO\u2082 core network (the model could be private financing via the so-called amortization account concept of the hydrogen core network for Germany, which would smooth transport charges over time). If the KSpTG is passed in 2025, including clarification of the financing, the first CO\u2082 core network sections could go into operation > 2032 at the earliest, a NW-European core network around > 2035. However, this would require the classification of the CO\u2082 infrastructure in the “overriding public interest”, which is not yet provided for in the current KMS draft law and is regarded by all stakeholders as essential for rapid approval procedures.<\/p>\n\n\n\n
However, other questions are likely to remain unanswered:<\/p>\n\n\n\n
The London Protocol is an international agreement to protect the marine environment from pollution caused by the dumping of waste and other substances. Originally, Article 6 of the Protocol prohibited the transboundary transportation of waste for dumping at sea. In 2009, however, an amendment was adopted that allows the transboundary transportation of CO\u2082 for geological storage under the seabed. For this amendment to enter into force, it must be ratified by at least two thirds of the Parties.<\/p>\n\n\n\n
However, as of November 2024, only a few states have ratified this amendment, meaning that it has not yet entered into force. In order to nevertheless enable cross-border CO\u2082 transport, contracting parties can provisionally apply the amendment by concluding corresponding bilateral or multilateral agreements and notifying the International Maritime Organization (IMO). Some countries, such as Norway, Denmark and the Netherlands, have already taken this route.<\/p>\n\n\n\n
For Germany, this means that the German government must ratify the amendment to Article 6 of the London Protocol to enable the export of CO\u2082 for geological storage abroad. In November 2024, the Federal Cabinet passed a treaty law that creates the basis for this ratification. However, as the entry into force of the international rule change may still take some time, the German government plans to apply the change provisionally. This requires the adaptation of national laws, such as the aforementioned Carbon Dioxide Storage Act (KSpG), in order to create the legal framework for cross-border CO\u2082 transportation and storage.<\/p>\n\n\n\n
In addition, bilateral agreements with potential recipient countries are required to clearly regulate the responsibilities and licensing responsibilities for CO\u2082 transport and storage. These agreements ensure that both exporting and importing countries comply with the high environmental standards of the London Protocol.<\/p>\n\n\n\n
In summary, Germany must take the following steps to ratify the amendment to the London Protocol and enable cross-border CO\u2082 transport:<\/p>\n\n\n\n
With these measures, Germany can pave the way for cross-border CO\u2082 transportation for geological storage and thus take a further step towards climate neutrality.<\/p>\n\n\n\n
At this discussion event in Berlin, one of the issues discussed was whether it would be better for a new government to adopt the traffic light KMS draft law or to revise it first – particularly with regard to more areas of application. The majority of the stakeholders present advocated the adoption of the traffic light KMS draft law as part of a 100-day program of the new government (instead of a time-consuming amendment, which could then only come into force in 2026), but including a revision.<\/p>\n\n\n\n
Inclusion of “overriding public interest” for CO\u2082 grid & storage.<\/p>\n\n\n\n
The KMS Act adopted in 2025 could then be amended in 2026\/27 following the adoption of any outstanding, possibly more far-reaching EU regulations as part of a revision.<\/p>\n\n\n\n
The adoption of the KSpTG, the ratification of the addendum to the London Protocol and the clarification of the financing of the CO\u2082 core network should also be driven forward in 2025.<\/p>\n\n\n\n
Germany has lost a valuable 15 years from around 2010 to 2025 to further engage in the development and commercialization of CCUS technology and will now need the help of neighboring countries to catch up again. Without the adoption of the 3 key regulatory points (KMS, KSpTG, addendum to the London Protocol), there will be no significant decisions in the economy for conceived CCUS projects. Extended funding opportunities will also play a key role in FID decisions for the first major CCUS projects. The adoption of the three regulatory requirements for CCUS by mid-2025 would also be crucial with regard to the tendering of urgently needed new power plant capacities (15\u201320 GW required by 2030), which is now expected to take place in early 2026. The players in the CCUS value chain at home and abroad will only be able to become active with clear framework conditions, including clarity about possible CCUS application areas:<\/p>\n\n\n\n
From GES’s point of view, a broad application of CCS for larger CO\u2082 point sources in various sectors and the creation of “CCS clusters” would ensure that costs are minimized through economies of scale. For example, the first cross-industry demonstration projects in the UK. Accordingly, the legal framework for CCS must also be created quickly in Germany, ideally as part of a “100-day program” of the new government.<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_acf_changed":true},"autor":[100],"publikationskategorien":[57],"class_list":["post-6297","publikation","type-publikation","status-publish","hentry","autor-thomas-frewer-en","publikationskategorien-background-paper"],"acf":[],"_links":{"self":[{"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/publikation\/6297","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/publikation"}],"about":[{"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/types\/publikation"}],"wp:attachment":[{"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/media?parent=6297"}],"wp:term":[{"taxonomy":"autor","embeddable":true,"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/autor?post=6297"},{"taxonomy":"publikationskategorien","embeddable":true,"href":"https:\/\/global-energy-solutions.org\/en\/wp-json\/wp\/v2\/publikationskategorien?post=6297"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}