Exporting CO2 for Offshore Storage – The London Protocol’s Export Amendment and Associated Guidelines and Guidance

Publication Overview

The London Convention and London Protocol are the global treaties that protect the marine environment from pollution caused by the dumping of wastes. Since 2006, the London Protocol has provided a basis in international environmental law to allow carbon dioxide (CO2) storage beneath the seabed when it is safe to do so, and to regulate the injection of CO2 into sub-seabed geological formations for permanent isolation. However, Article 6 of the London Protocol prohibits the export of waste or other matter for dumping in the marine environment. Therefore in 2019, Contracting Parties to the London Protocol adopted a resolution to allow provisional application of the 2009 amendment to Article 6 of the Protocol to allow export of CO2 for storage in sub-seabed geological formations in advance of its ratification, which was progressing slowly.

Publication Summary

The provisional application of the 2009 amendment to Article 6 of the London Protocol allows countries to agree to export and receive CO2 for offshore geological storage. This removed the last significant international legal barrier to CCS and means that CO2 can be transported across international borders to offshore storage. Because of the previous work by London Protocol Parties on the requirements for permitting and responsibilities, the environmental protection from the original 2006 amendment and subsequent guidelines is maintained for transboundary CCS activities. This is an enabling event in the truest form for CCS, and consequently also towards the immense CO2 mitigation which is needed to achieve the Paris Agreement goals. This report describes the background, details and requirements of this provisional application of the CCS export amendment, and the details and requirements provided by the two associated guideline and guidance documents, and their implications. This report is intended to assist project operators and regulators in accessing and applying the CO2 export aspects of the London Protocol