During a comprehensive stakeholder consultation organised by the previous government in 2024, several organisations provided insights into some of the challenges which lay ahead. Industry association BDI said the market ramp-up of carbon removal technologies had to happen “very soon” in light of the target of climate neutrality by 2045, branding existing support as insufficient. It called for “stable funding structures” for a broad range of technologies, and a rapid expansion of CO2 infrastructure.
Energy industry association BDEW warned that emissions reduction, and the expansion of natural carbon sinks, should remain the priority of German climate action. It also called for a consistent alignment of German CDR instruments with EU rules, and called on the government to make cross-border projects possible.
Research initiative CDR terra said that the strategy could provide planning security and make Germany a pioneer of carbon removal technologies. The government must lay out how these could be rolled out at “massive” scale and how to finance it.
Environmental NGO Bellona said the strategy must contain a “robust” definition of what counts as carbon removal technologies, and called for separate targets for emissions reduction, permanent removals, and non-permanent storage. WWF Germany also called for separate targets and warned that emissions reduction should continue to be the top priority in climate action. It added that a clear definition of unavoidable residual emissions was needed to limit CDR to cover these sectors.
In an article for the German Institute for International and Security Affairs (SWP), researchers Felix Schenuit and Domenik Treß highlighted that action is needed in the short term to first help larger CDR projects get off the ground. “The existing framework conditions for companies are generating investment uncertainty, to the extent that there is a ‘valley of death’ that lies between small-scale innovation prototypes and large-scale implementation projects,” they wrote. They called for leveraging synergies between CDR and fossil CCS, an incentive mechanism prioritising low-hanging industrial CDR capacities that can be implemented relatively easily and quickly, and promoting cross-border projects.
Carbon removal industry association DVNE said the strategy would create the foundation for long-term development and set targets. Germany should back a broad portfolio of methods.
