Pricing It Right: Accounting for Non-Permanent CCU While Safeguarding the EU ETS

The role of carbon management, including that of carbon capture and utilisation (CCU) and the re-use of captured carbon, is gaining increasing traction among policymakers in the EU.

As part of the 2026 revision of the EU Emissions Trading System (ETS), the European Commission has been mandated to assess how to account for emissions from CO₂ that is captured and used in non-permanent products and fuels, which are later re-released, and how the inclusion of municipal waste incineration (MWI) and landfilling may affect this accounting.

This joint analysis by CONCITO and Clean Air Task Force (CATF) explores two main policy options for how to account for non-permanent CCU based on fossil CO₂ under the EU ETS, taking into account the potential inclusion of MWI in the ETS from 2028.