Why the IEA Numbers Matter to Belgian Compliance Calendars

The IEA’s 5 August 2026 CCUS update is not merely an infrastructure report — it is a forward indicator for the cost and availability of captured CO₂, the feedstock that underpins every e-fuel and Power-to-Liquid pathway subject to RED III’s renewable-fuel-of-non-biological-origin (RFNBO) rules. If the bulk of new storage capacity does not come online until 2035, compliance directors targeting 2030–2032 RED III milestones cannot assume cheap, verified CO₂ will be available at scale when they need it. Procurement strategies, offtake agreements and carbon-accounting frameworks must be stress-tested against a constrained-supply scenario.

Belgium’s BE.Hydrogen programme — the geological survey launched in March 2026 by Minister Crucke in partnership with Belspo and the Geological Survey of Belgium (GSB) — is investigating the Hercynian basement and the former coal basins of the Greater Region for natural hydrogen indicators. No accumulation, flow or commercially exploitable resource has been confirmed on Belgian territory. However, the programme’s subsurface data — porosity, permeability, structural traps — is directly relevant to CO₂ storage site evaluation, meaning the survey could yield dual-use insights for Belgian CCUS siting even before any hydrogen conclusion is reached.

The Regulatory Squeeze: RED III, ReFuelEU and CO₂ Supply

RED III obliges fuel suppliers and large industrial emitters to source increasing shares of renewable and low-carbon fuels, with RFNBOs — produced from renewable electricity and, critically, non-fossil CO₂ — counting toward the most demanding sub-targets. ReFuelEU Aviation layers blending mandates onto aircraft operators at EU airports, with the e-fuels sub-mandate rising steeply toward 2030 and beyond. Both frameworks presuppose an accessible, certified supply of captured CO₂; the IEA’s finding that significant capacity remains delayed to 2035 injects structural uncertainty into every compliance projection for 2030–2032.

The efficiency objection to e-fuels in road transport is well documented: a Power-to-Liquid powertrain uses roughly five times more renewable electricity per kilometre than a battery-electric vehicle. That argument loses much of its force in aviation and deep-sea shipping, where batteries cannot serve the duty cycle — precisely the sectors where ReFuelEU mandates apply. For those sectors, closing the CO₂ supply gap is not optional; it is a prerequisite for legal compliance.

What Compliance and Marketing Directors Should Do Before 2028

Three concrete steps follow from the IEA data. First, audit your CO₂ feedstock exposure: if your e-fuel or RFNBO pathway depends on point-source capture that is not yet operational, model a 2035 delivery scenario and identify alternative bio-CO₂ or direct-air-capture sources that could bridge the gap. Second, engage with Belgian and Greater Region subsurface data as it emerges from BE.Hydrogen’s GSB survey — geological characterisation of the Hercynian basement may identify CO₂ storage formations that reduce transport costs for regional industrial clusters. Third, begin documentation now: RED III’s chain-of-custody and carbon-intensity verification requirements demand audit trails that take 18–24 months to establish.

The IEA’s 425 Mt/yr potential figure is large enough to meet ambition — but ‘potential’ is not ‘contracted’. Compliance timelines do not flex to match infrastructure delays. The organisations that will meet their 2030–2032 obligations are those locking in CO₂ sourcing agreements in 2026 and 2027, not waiting for the project pipeline to clear.

Sources

• What EU RED III compliance for biofuels means for renewable fuel operators – RSB
• ReFuelEU Aviation · blend trajectory & scope | e-fuels

Featured image via Unsplash.