CB in the European Union

We entered the EU space in 2023 through targeted advocacy on Article 23 of the Net Zero Industry Act, which elevated it into law and demonstrated that long-term carbon storage obligations can shape EU climate policy.

Now, as the political landscape shifts, we’re working to influence how Article 23 is implemented, ensure robust 2040 climate targets, and engage on new initiatives like the Clean Industrial Deal. Our 2025 focus includes expanding our presence in Brussels, building academic-policy partnerships, and embedding durable storage policy in the EU’s next wave of industrial legislation.

Our EU priorities

  • Holding the EU's oil & gas sector accountable

    Article 23 of the Net Zero Industry Act is the world’s first policy requiring oil and gas producers to contribute to carbon storage. We are tracking its implementation closely, working to close loopholes, clarify compliance obligations, and shape the regulation’s long-term future as a cornerstone of EU industrial decarbonisation.

  • Unlocking long-term funding through storage obligations

    The EU lacks scalable funding mechanisms for permanent CDR. We’re exploring how storage obligations, rooted in extended producer responsibility, can evolve into credible, compliance-grade tools that drive investment in durable removals and help the EU reach net zero and net-negative.

  • Align the 2040 target with geological net zero

    In 2025, the Commission will recommend the EU’s 2040 climate target. We’re advancing proposals to ensure that the target reflects geological net zero principles, balancing any fossil and industrial production with permanent storage. Our goal is to anchor net zero in legislation that is transparent, accountable, and truly Paris-aligned.

Publications

Publications
Amicus Curiae: Obligated entities under Article 23, Net Zero Industry Act
Briefing
Amicus Curiae: Obligated entities under Article 23, Net Zero Industry Act
Briefing

An amicus curiae brief, written by Bellona Europa and Carbon Balance Initiative, assessing the legal challenges to Article 23 around its legal basis, proportionality, and alignment with EU legal principles.

Briefing
The First Year of Article 23: Tracking Compliance, Progress and Perspectives
Report
The First Year of Article 23: Tracking Compliance, Progress and Perspectives
Report

A first-of-its-kind report assessing the progress of Article 23 implementation in the EU, written by Carbon Balance Initiative, Clean Air Task Force, and Bellona Europa.

Report
Net Zero Industry Act: Who Pays for Net Zero?
Policy brief
Net Zero Industry Act: Who Pays for Net Zero?
Policy brief

Policy brief focused on the EU’s Net Zero Industry Act’s new proposal for an oil and gas injection capacity obligation (Article 18, now Article 23) as a key pillar of fossil fuel accountability

Policy brief
More Publications
More Publications

EU Updates & News

Featured
Fossil giants fight to avoid accountability, leaving Europe’s industry to face the consequences
Fossil giants fight to avoid accountability, leaving Europe’s industry to face the consequences

Press release in response to oil and gas legal challenges,against European Commission, over the injection capacity obligation in Net Zero Industry Act

Open Letter to call for comprehensive lead market measures in the Industrial Accelerator Act
Open Letter to call for comprehensive lead market measures in the Industrial Accelerator Act

Open letter to include comprehensive lead market measures in the Industrial Accelerator Act

Open letter against international credits integration into the EU 2040 climate target and NDC
Open letter against international credits integration into the EU 2040 climate target and NDC

Open letter on separate targets and Article 6 in 2040 climate framework

Who should pay for net-negative in the EU? Invite-only workshop
Who should pay for net-negative in the EU? Invite-only workshop

Event announcement: Invitation-only workshop exploring how Extended Producer Responsibility could help finance net-negative emissions and address the EU’s climate overshoot challenge