19.09.2025

ORLEN input to the Call for Evidence on CO2 markets and infrastructure

ORLEN sees the upcoming European Commission regulations on CO₂ markets and infrastructure as a key chance to create a well-structured, investment-friendly system that encourages early adoption while building the groundwork for a stable, long-term CO₂ market. We stress the importance of designing policies carefully to avoid locking in or limiting market development before it has fully matured.

ORLEN advocates for a gradual, adaptable, and market-driven strategy—one that combines initial public support with sustained private investment, while steering clear of rigid or inappropriate rules in the early stages.

ORLEN calls, among others, for:

  • Introducing support systems for the construction of CO₂ capture facilities.
  • Clarifying legal provisions in the Helsinki Convention related to CO₂ storage under the Baltic Sea.
  • Integrating planning with natural gas and hydrogen networks.
  • Including CO₂ transport under the ETS Directive as CO₂ transport for product usage at different locations.
  • Enabling temporary ETS fee reductions (50–70%) for installations producing synthetic fuels, algae, or plastics using fossil CO₂.
  • Prioritizing operator capacities by limiting Third-Party Access (TPA) to only remaining capacity, and exempting direct-line pipelines from TPA rules.
  •  Extending the use period for fossil CO₂ in RFNBO, RCF, and low-emission fuel production from 2036/41 to 2050.

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