1. Introduction

All Nordic countries have set ambitious targets to achieve net-zero and even net-negative greenhouse gas (GHG) emissions in line with a (global) 1.5-degree pathway, both individually through various national goals and legislation, and jointly through the 2019 Helsinki Declaration on Nordic Carbon Neutrality

The Helsingfors Declaration, a declaration from the meeting between the Nordic Prime Ministers and the Ministers of Environment, 25 January 2019. Available at: https://www.norden.org/en/declaration/declaration-nordic-carbon-neutrality

(“the Declaration”). In the Declaration, the Prime Ministers declare that the Nordic countries want to lead by example and intensify cooperation. The Declaration underlines the important role of carbon capture and storage (CCS), including bioenergy with CCS (BECCS) which is the leading technology that can deliver permanent carbon dioxide removal (CDR) in the Nordics.

Other CDR methods that are being considered for their potential future contributions include biochar and Direct Air Carbon Capture and Storage (DACCS).

Furthermore, the EU has an ambition to achieve a balance between emissions by sources and removals by sinks of GHG domestically within the EU by 2050 and, as appropriate, achieve net negative emissions thereafter.

European Climate Law. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1119

CCS may have different roles to play:

CCS is a solution that has potential to enable rapid and deep reductions of CO₂ emissions from fossil sources where potential alternative mitigation solutions are insufficient.
In addition, BECCS and direct air carbon capture and storage (DACCS) has the capacity to actively remove CO₂ from the atmosphere permanently, which is of significant importance in relation to net-zero targets. Any country (or region) aiming for a net-zero target will need to counterbalance some “residual” emissions due to the difficulty to fully mitigate within certain sectors such as agriculture. This is where CDR can play a significant role.

However, when discussing CCS, it is important to bear in mind that it should primarily be seen as a tool to manage emissions in sectors where full mitigation by alternative measures is difficult. In particular, the capacity of BECCS and DACCS to remove CO₂ from the atmosphere should not be seen as a tool to allow for business-as-usual and the perpetuation of GHG emissions across other sectors. Once net-zero has been attained, continued and increased use of BECCS (as well as other CDR methods) can also play a role to achieve net-negative GHG emissions (on a national, regional or global scale). CCS will play an important role, but its role should not be overstated.

This project aims to analyse regulatory aspects in relation to CCS (including BECCS and DACCS) development and deployment that are of relevance for the Nordic context. Project objectives specifically include to investigate:

Similarities and differences between the Nordic countries concerning CCS regulation.
Can barriers to CCS and/or BECCS deployment be identified which are caused by current regulatory frameworks?
Are there plans to change regulatory frameworks in order to promote the development of CCS and/or BECCS?
Whether there is a need to develop models for how CCS co-operation between the Nordic countries, especially when it comes to co-operation at project level.
The issue of division of responsibilities between actors in CCS projects. Is it clear who in the legal sense is responsible for what at different stages of a cross-border CCS project?
The need to coordinate monitoring, reporting and verification of BECCS mitigation outcomes on a Nordic level.
The need to develop Nordic co-operation on CCS at the institutional level, as well as how increased interaction between the Nordic countries in the CCS area could be promoted.

The gathering of information for this report has been done through interviews with actors within ministries and government agencies in all Nordic countries. Information has also been collected by studying reports, scientific literature, and relevant legal documents such as acts and regulations. The analysis of the different countries’ legal documents has mainly been done through an analysis of the wording as it has been carried out by researchers without in-depth understanding of each country’s respective legal system or language. The differences in depth of the information regarding the Nordic countries CCS regulation relates, at least in part, to the fact that some countries have come further than others towards implementation of CCS activity and therefore have more information to provide. In addition, authors of the report attended a Nordic workshop where representatives of Nordic ministries and government agencies presented national perspectives on CCS and discussed potential needs and benefits of Nordic cooperation related to CCS. Findings from the workshop have been useful as input for this report. Representatives of the NME reference group and Nordic ministries and government agencies have been given the opportunity to comment on an early draft of the report as well as a final draft.

The project has been carried out IVL Swedish Environmental Research Institute (co-ordinating partner) and Perspectives Climate Group (project partner). Contributors from IVL: Sofi Marklew and Kenneth Möllersten (project leader). Contributors from Perspectives: Hanna-Mari Ahonen. The authors are grateful for valuable comments and guidance from the NME project reference group, Svante Söderholm and Nicki Carnbrand Håkansson (Swedish Energy Agency), Eve Tamme (Climate Principles), Adrian Lefvert and Malin Pehrs (KTH Royal Institute of Technology) as well as several colleagues at IVL and Perspectives Climate Group.