Article 23: Delegated Regulation on responsibility
We welcome the Commission’s draft Delegated Regulation concerning oil and gas producers’ contributions to the EU’s 50 Mt by 2030 CO₂ injection capacity objective, as outlined in Regulation (EU) 2024/1735 (the “Net-Zero Industry Act”, hereafter NZIA).
We support the ambition to hold oil and gas producers accountable for complying with this obligation in the EU. The Delegated Regulation marks a significant step in embedding responsibility within the sector and advancing Europe’s decarbonisation goals. However, its success depends on robust enforcement, transparent implementation, and coordination across borders and sectors.
To support implementation, we recommend:
Ensuring a fit-for-purpose small producer threshold to safeguard the effectiveness and pro-rata logic of Article 23.
Clarifying shared responsibility rules for joint authorisation holders and consortia.
Requiring reporting of capacity with ranges and uncertainty disclosures.
Mandating entities to disclose how they will meet their obligated injection capacity contribution, as specified under Articles 23(4) and 23(5).
Ensuring transparency in risk disclosure and mitigation strategies.
Clarifying rules on transport responsibility and handover point definitions.
We appreciate the Commission’s leadership on industrial carbon management and support the rapid and transparent implementation of Article 23.
This response is submitted by Carbon Balance Initiative on behalf of a joint project led by Carbon Balance Initiative, Clean Air Task Force, and Bellona Europa. The project aims to strengthen the implementation of Article 23 of the Net-Zero Industry Act.