On Monday 16 February 2026, Citizens for Ecological Learning & Living (CELL) and climate strategy consultancy firm Carbone 4 Luxembourg published three recommendations and points of attention in relation to Luxembourg’s policy framework for carbon capture.
In a press release, CELL and Carbone 4 said Luxembourg’s policy framework for carbon capture is welcome and that it must lead to a realistic and ambitious implementation towards negative emissions.
The environmental associations published three recommendations and points of attention and stressed carbon capture “must remain a last resort after reductions, particularly in energy and resource consumption.”
To complement the national plan to decarbonise the Grand Duchy’s economy, the Luxembourg government published in December 2025 a policy framework on carbon capture, utilisation and storage (CCUS) and atmospheric carbon dioxide removal (Carbon Dioxide Removal – CDR).
According to UN body the Intergovernmental Panel on Climate Change (IPCC), CDR encompasses all human activities aimed at durably removing CO₂ from the atmosphere and storing it in geological, terrestrial or ocean reservoirs, or in products. It includes, in particular, direct air capture with storage (DACCS – which can be visualised as large vacuum systems capturing CO₂ from the air), bioenergy with carbon capture and storage (BECCS – for example for energy production, when wood that has already absorbed CO₂ is burned and this CO₂ is captured again), as well as the human-enhanced increase of biological or geochemical sinks, such as forest carbon sinks through trees. CCUS applied to fossil or industrial point sources mainly aims to avoid additional emissions (for example, CO₂ is captured at a gas power plant before it is released into the atmosphere). According to the IPCC, the use of CDR as a last resort is necessary.
CELL and Carbone 4 noted that Luxembourg’s natural sink, its forest areas, become saturated over time and its capacity is insufficient compared with the country’s emissions and added that it is also “increasingly fragile”.According to a study by Science.lu, in Luxembourg, only 15% of trees are currently regarded as in good health, compared with around 80% forty years ago. In this context, CELL and Carbone 4 stressed that CCUS and CDR solutions are essential to achieve climate neutrality by 2050 - an objective that is not yet fully guaranteed by the current National Energy and Climate Plan (PNEC) - and subsequently to achieve net negative emissions after this date in order to return to pre-industrial concentration levels.
Carbone 4, said that through its role as a technical expert on ecological issues and its methodological support on carbon emissions, and CELL, as a local actor in the transition and partner of the Climate Pact, welcomed the government’s initiative and offered three recommendations.
Recommendation 1: Reducing Energy and Resource Consumption Must Remain the Priority Lever
CELL and Carbone 4 said that the SER action framework (sufficiency, efficiency, renewable) mobilised by the IPCC must remain the priority lever, while CCUS and CDR must remain a last resort reserved for sectors without alternatives. The core challenge remains the elimination of emissions, for which the potential to manage and reduce energy and resource consumption remains significant in Luxembourg.
The associations highlighted Luxembourg’s resource and carbon footprints, reflected on the country’s Overshoot Day position, and called for “strengthening a system that promotes, facilitates and makes more competitive a lifestyle with low emissions and low resource and energy consumption”.
Recommendation 2: Transparent and Robust Accounting of Removed Emissions
CELL and Carbone 4 said: “This is necessary to provide an effective and efficient incentive; a robust and transparent accounting system must be established and ensured.”
They stressed that such a system must make it possible to verify emission reductions linked either to industrial carbon capture or to increased carbon sinks through technologies such as DACCS and that accounting traceability throughout the value chain must demonstrate that carbon has been emitted, transported and ultimately stored durably. They remarked: “Only a robust and shared accounting system will make it possible to measure the climate impact of CCUS and CDR through operational indicators.”
Recommendation 3: The Need for a Complete and Well-Coordinated Ecosystem
CELL and Carbone 4 noted that the success of Luxembourg’s CCUS and CDR strategy will also depend on close collaboration among all stakeholders involved. Given the country’s size and industrial characteristics, cross-border and international cooperation will be essential, particularly for CO₂ transport infrastructure such as pipelines, logistics hubs and alternative transport solutions. In addition, involving citizens in governance, financing or the development of certain technologies may strengthen legitimacy, territorial anchoring and the dynamism of CCUS and CDR projects.
The associations emphasised: “The effective coordination of these collaborations therefore represents one of the central levers for making the CCUS and CDR strategy an operational and credible instrument that is fully integrated into European dynamics.”
In closing, CELL and Carbone 4 agreed that carbon capture and storage are necessary. However, they emphasised that while the policy framework is positive, these solutions must remain a last resort compared with other decarbonisation levers and require an accounting system which prevents greenwashing. They said: “Luxembourg has an opportunity to play a role at European level,” but that accompanying measures are required to ensure a just transition for households and business alike.
