An open letter published on 15 July 2026 by 25 industry, sector associations, research institutes and civil society organisations highlights how the Helsinki Convention creates legal uncertainty and practical barriers to geological CO₂ storage in the Baltic Sea Area, impacting industrial decarbonisation, Europe's climate objectives, and the development of a European integrated CO₂ market.
The Baltic Marine Environment Protection Commission (HELCOM) has recently commissioned a legal review to assess whether carbon capture and storage (CCS) is compatible with the Helsinki Convention – a regional sea convention treaty that protects the Baltic Sea's marine environment. While welcoming this process, the coalition warns that a legal review alone will not unlock geological CO₂ storage in the region in the near term.
CCS is widely recognised as an essential component of Europe's climate objectives and industrial competitiveness. The EU has already established a clear policy signal in support of CO₂ storage: the Industrial Carbon Management Strategy and the Net-Zero Industry Act (NZIA) set out a vision of a single European market for CO₂ transport and storage services, and the forthcoming CO₂ Market and Infrastructure Package is set to translate that vision into a functioning internal market for storage services. Realising this vision requires removing barriers at the EU, regional and international levels.
Legal uncertainty is a real bottleneck for CCS projects. It affects permitting, investment, and financing decisions across the CCS value chain. An enabling policy and regulatory framework at the EU level is necessary, but not sufficient. It needs to be matched by legal clarity at the regional level too.
Cristiana Foglia, Policy Officer at Carbon Management Europe
Access to environmentally sound, safe geological carbon storage will be critical for many countries in the Baltic Sea region, particularly to support the decarbonisation of energy-intensive industries. Several Member States have limited suitable geological formations and will therefore depend on access to storage capacity elsewhere in Europe.
This is reinforced by Article 20 of the NZIA, which establishes a Union-wide objective of at least 50 million tonnes of annual CO₂ injection capacity by 2030. Several Contracting Parties to the Helsinki Convention also host obligated entities that must contribute to the target, yet barriers under the Helsinki Convention are currently keeping that potential out of reach.
Left unresolved, the current legal framework will continue to impede access to storage resources, delay investment in CO₂ transport and storage infrastructure, and leave industries in the region with fewer pathways to decarbonise.
The coalition therefore calls on the Contracting Parties to the Helsinki Convention to explore practical legal mechanisms to provide the certainty needed to enable environmentally safe CO₂ storage while remaining fully consistent with the Convention's environmental objectives.