June 25, 2024

On June 18, 2024, the EU Commission opened the consultation procedure on its draft delegated act regarding the requirements for determining that greenhouse gases are permanently chemically bound in a product (COMMISSION DELEGATED REGULATION (EU) …/… of XXX supplementing Directive 2003/87/EC of the European Parliament and of the Council as regards the requirements for considering that greenhouse gases have become permanently chemically bound in a product). This is about Carbon Capture and Utilisation (CCU).

CCU could be an important way of not only not emitting CO2, but also incorporating carbon into products (and thus killing two birds with one stone). There is a consensus that the incorporation of carbon should be permanent. Chemically, the answer is simple at first glance: mineral carbonates meet this requirement. They are stable for centuries, perhaps even millennia.

But what about organic chemistry? It is indispensable for the future of society. So far, it has been based almost exclusively on fossil raw materials. In order to achieve the feedstock change (defossilisation) of the chemical industry, e.g. the plastics sector, we also need substances that are recycled and substances that are produced from sun, wind and CO2. However, according to the EU Commission, these substances are not ‘permanent’ simply because they can be incinerated. Therefore, cycles only make sense in terms of climate policy if we can imagine that they are permanent. If we do not have this imagination, there will be no regulation to bring this about. Within the framework of the Delegated Regulation on CCU, the Commission has the opportunity to develop this imagination.

Our statement on the EU Commission’s draft in this regard and the website for the consultation procedure can be found here:



Feedback to the Commission
EU website on the consultation process