Q&A: German law reform to permit carbon storage and transport
This Q&A is part of a large package on carbon management in Germany and Europe. For scientific and policy background on CCS, also read the factsheets Q&A: Carbon capture and storage - Hype or hope for a cooler planet? (2025) and Q&A – CCS makes comeback as Germany and the EU strive for climate neutrality (2024).
Content
- What is the government’s plan regarding CCS?
- Why does Germany need to update its carbon storage law?
- Where will Germany allow the storage of CO2?
- What are key limitations for carbon storage in Germany?
- Will Germany allow CCS on coal-fired power plants?
- Will Germany allow CCS on gas-fired power plants?
What is the government’s plan regarding CCS?
The German government has decided to enable the broad application of carbon capture and storage or utilisation in the country. It said technologies to capture, transport and permanently store carbon dioxide deep underground are “indispensable” to reach Germany’s targets of climate neutrality by 2045 and net negative emissions after 2050. It also said that CCS is needed to ensure Germany’s competitiveness.
Energy and climate researchers also say CCS will be necessary to a certain extent to reach climate targets. However, critics have argued for years that CCS could be used to extend the lifetime of the fossil fuel industry, thus hurting the climate rather than helping protect it.
Capturing CO2 is already permitted in Germany, but current laws make it impossible to start a storage project and severely limit large-scale transport. The government aims to change these framework rules as a precondition for the ramp-up of a CO2 market which connects the country to its neighbours.
It aims to use CCS mainly for hard-to-abate industry emissions, for example from cement production and waste incineration. However, the government also decided to define the scope of CCS and CCU broadly, and only forbid it for coal-fired power plants.
Why does Germany need to update its carbon storage law?
The law reform is meant to give industry, plant manufacturers and infrastructure operators the legal basis for investments in the coming years and decades.
The existing carbon storage law forbids new underground storage projects and impedes the buildout of carbon transport infrastructure. The government argued that time is of the essence, as it can take between seven and ten years to build transport and storage infrastructure, and this infrastructure will be needed by the early 2030s to achieve set climate targets.
The law reform aims to enable the permanent storage of carbon dioxide in underground rock formations under the seabed in the North and Baltic Seas for commercial purposes on an industrial scale, and to create a uniform permit regime for all carbon dioxide pipelines.
The reform would also mean that the construction, operation and significant modification of carbon dioxide pipelines are in the “overriding public interest”, which makes planning and permitting procedures easier. The law reform would in limited cases even allow expropriation of land if it was needed for pipelines.
Where will Germany allow the storage of CO2?
Carbon storage will be limited to locations under the seabed in the territory of Germany’s continental shelf, which largely corresponds to its the exclusive economic zone stretching to at most 200 nautical miles from the coast. Storage in the territorial waters along the coast as well as in marine protected areas would remain forbidden.
Storage on land is generally not allowed except for research projects. However, individual federal states can in theory opt-in and allow storage on their land because “it can be more economical and environmentally friendly than transporting carbon dioxide over long distances,” said the draft. It remains to be seen whether any state would make use of this option.
What are key limitations for carbon storage in Germany?
To reach climate targets, Germany will continue to prioritise renewable energy expansion and the ramp-up of a hydrogen economy. Thus, the draft law stipulates that there must be no significant adverse impact on the construction and operation of hydrogen pipelines, offshore wind farms and offshore connection lines, or on the preliminary investigation of areas for offshore wind energy generation.
The Federal Agency for Nature Conservation shall be involved in matters relating to marine protection and nature conservation in general, and the Federal Environment Agency (UBA) shall be involved in matters relating to the prevention of environmental risks.
Will Germany use CCS on coal-fired power plants?
No. The draft said that CCS and CCU “should not serve as an incentive for energy production through the combustion of coal.” By prohibiting the use of carbon dioxide pipelines and carbon dioxide networks for transporting carbon dioxide from coal combustion, the use of CCS and CCU in connection with coal-fired power plants and heating plants would effectively be ruled out.
Due to the quantities of carbon dioxide produced during coal combustion, alternative transport options are not economically viable, the draft argued.
Will Germany allow CCS on gas-fired power plants?
Yes. The draft law does not rule out CO2 pipeline transport from gas-fired power plants, thus paving the way for CCS for fossil gas electricity production.
This was a major point of contention during the former government’s first attempt at the law reform, which was never adopted in parliament due to the break-up of the coalition government.
