TEN-T Regulation: 24 Stakeholders call on TRAN Committee to recognise crucial ship, rail, barge and truck for transporting CO2 to storage 

Publish date: February 14, 2023

As part of Bellona and CATF’s ongoing campaign on the TEN-T Regulation revision, the campaign #TenTTuesday has sought to highlight the “faces behind the policy” with a particular focus on the important role to be played by different modes of transport for bringing CO2 to storage. 

On the occasion of the ongoing revision of the TEN-T Regulation, 24 stakeholders have signed a letter from Bellona Europa and CATF calling on the European Parliament’s Committee on Transport and Tourism (TRAN) to support amendments tabled to recognised transport of CO2 to storage via ship, rail, barge and truck.  

While transport of CO2 to storage via pipeline will undoubtedly be crucial in a European CO2 network, market development depend to a great extent on the parallel development of other modes of transport, such as ship, rail, barge and truck. In particular, these modes of transport are important for regions placed far from storage sites and for European Member States where CO2 storage is currently not permitted.  

Nearly all modelling scenarios towards EU climate neutrality by 2050 highlight the key role of CO2 capture, transport and storage. The last year has seen several important legislative steps in the right direction to facilitate the deployment of projects for industrial decarbonisation capturing and storing CO2. A missing piece of the puzzle so far has been a currently non-harmonized regulatory framework, a source of uncertainty influencing investment decisions which need to be taken today to reach the climate targets set for the EU. One such issue is the failure to recognise transport of CO2 via other modalities than pipeline, on equal footing as the latter.  

Important steps have been taken in the right direction, including the recognition of all modes of transport for CO2 to storage in the revised EU ETS and the EU Sustainable Finance Taxonomy – but a glaring exemption remains under the Connecting Europe Facility. While the revised TEN-E Regulation expanded the scope of so-called “Projects of Common Interest” (PCIs) to CO2 storage, in addition to pipeline, which was already covered, other transport modalities were left outside the scope under the assumption it would be a better fit for the TEN-T regulation.  


While storage and transport of CO2 to storage via pipeline is recognised in the revised TEN-E Regulation, recognition for other modalities of transport such as ship, rail, barge, and truck are still missing under the Connecting Europe Facility (CEF).  

While the TEN-T Regulation clearly set out the importance of fostering synergies with the TEN-E Regulation, of which the contribution of CO2 transport modes such as ship, rail, barge and truck would be a seemingly perfect fit, there is no explicit mention of such recognition. This contributes to further unclarities regarding the role of multiple transport modes in a CO2 network. As highlighted by Bellona and CATF in a Euractive Op-Ed from 2021, not recognising the role of other transport modes than pipeline on the pathway to net-zero by 2050 is a missed opportunity taking us down the wrong path, threatening shared climate ambition.  

Transport modalities, such as rail, truck, ships and barges, are key to ensuring equitable access either directly to storage or to pipelines linked to storage. Given the unequal distribution of CO2 storage sites across Europe and the significant up-front cost and investor risk associated with immobile transport infrastructure such as pipelines, mobile transport modalities can help avoid regional disparities in access to storage sites.  This will ensure equal opportunities for industrial decarbonization across Europe. By making it possible for smaller industrial emitters to start decarbonizing, mobile transport modalities for CO2 will also substantially contribute to wide-scale market development, reducing the overall cost of industrial carbon capture and storage.  

It is the signatories’ hope that the letter will highlight the importance of such recognition under the TEN-T Regulation, resulting in a strong position from the European Parliament on this vital issue before entering into Trilogues on the file.  

Do you wish to be a part of Bellona and CATF’s ongoing #TenTTuesday campaign? Get in touch with Lina Strandvåg Nagell (  


Download the letter here: TEN-T-Open letter to TRAN 09022023

Lina TenTTuesday QC