Green Transition Denmark insists that emission reductions should have the highest priority in the EU's climate policy, but acknowledges that the technologies may be necessary for CO2 reduction in certain areas. But it will require tougher EU requirements and the right incentives in order not to compromise with the green transition.
Therefore, we recommend:
Focus on emission reductions
RGO believes that one should prioritize here-and-now reductions and a further focus on reducing the 'hard-to-abate' emissions, as this will reduce the future need for CO2 capture and storage. Otherwise, you risk building oversized CCS infrastructure, which can create a technological lock-in in products and production processes with high emissions of greenhouse gases.
RGO believes that the use of CO2 capture and storage should only be considered in the sectors that have the most difficulty in reducing their emissions, such as the steel and cement industries, as well as for reducing the CO2 concentration in the atmosphere.
Tightened and expanded legislation
RGO believes that the focus should be on overall regulatory frameworks that best ensure a cost-effective and climate-friendly combination of emission reductions, CO2 capture and negative emissions. Here, it is absolutely crucial to expand the EU's emissions trading system (ETS) to also include the agricultural sector and the remaining emissions outside the existing system. In addition, a robust certification scheme for negative emissions based on BECCS and DACCS must be established.
RGO believes that the quotas for natural carbon storage should be strictly regulated and in limited quantities, as it is difficult and expensive to monitor and at the same time that it can be problematic to ensure additionality. In addition, natural carbon storage is not permanent, so negative emissions should not apply to temporary and reversible storage in e.g. forests and on agricultural land. Natural carbon storage should only act as a supplement to other reduction strategies.
Economic responsibility
RGO believes that the costs of the CO2 capture technologies should be placed entirely with the private industrial energy sector and storage operators. Public government support should be minimized, as it may otherwise delay or prevent the research, development and deployment of renewable technologies.
Find our full consultation response (in English) below.




