The Federal Department of the Environment, Transport, Energy and Communications (DETEC) has put a revision of the CO₂ Ordinance out to consultation. It is part of the «Verordnungspaket Umwelt Frühling 2027», a bundle of environmental ordinances that is due to enter into force on 1 July 2027. Statements can be submitted until 7 December 2026.

Most of the package deals with water protection, waste and contaminated sites. The part that matters for Power-to-X is hidden in the CO₂ Ordinance: it rewrites the rules for offset projects – the projects that generate the certificates which fuel importers need to meet their legal offset obligation.

What a consultation is

Before the Federal Council adopts a new or amended ordinance, the draft is sent out for consultation (Vernehmlassung). Cantons, political parties, business associations and other organisations – and in fact anyone – can comment on it. The administration then evaluates the responses and may amend the draft. For industry, this is the last formal opportunity to point out practical problems before the rules become binding.

What the draft changes

  • A minimum size for domestic projects: projects and programmes in Switzerland are only to be registered if they achieve a reduction of at least 10,000 tonnes of CO₂ equivalent in 2030. Projects that bind carbon are exempt.
  • Stricter programmes: small projects can still be bundled into programmes, but a programme may in future only contain projects using the same technology and providing the same type of evidence.
  • CO₂ storage abroad: geological storage is also to be accepted in partner states outside the EU and without a multilateral agreement, for example in Iceland.
  • BECCS and DACS as stand-alone projects: capturing CO₂ from biomass or directly from the air and storing it permanently can count as an offset project even if the plant is already in operation. The contractually agreed date counts as the start of implementation.
  • Permanence: proof that stored carbon stays stored is now also required for fossil CO₂, and it must be demonstrated «credibly».
  • Crediting periods: for CO₂ storage projects, crediting ends on 31 December 2035 at the latest; existing programmes abroad can be extended to 2035 under certain conditions.

Further changes exclude refrigeration plants using fluorinated refrigerants and wood-fired comfort heating that covers more than peak load, limit the admission of new validation and verification bodies, and make data on the companies subject to the offset obligation publicly accessible.

Why it matters for Power-to-X

The offset obligation for fuel importers is one of the few instruments in Switzerland that channels money into domestic emission reductions. For a Power-to-X project, selling certificates can make the difference between a feasibility study and an investment decision.

The 10,000-tonne threshold hits precisely the projects the country needs first: first-of-a-kind plants, pilot and demonstration facilities, and the upgrading of biogas plants with renewable hydrogen to turn the CO₂ in raw biogas into additional methane. Switzerland has more than 700 biogas plants; very few of them will individually reach 10,000 tonnes by 2030. Bundling into programmes remains possible, but the new single-technology rule narrows that path too.

At the same time, the draft builds a clear route for carbon dioxide removal and storage – including storage abroad. Using recycled CO₂ as a feedstock for renewable fuels and chemicals (CCU) is not mentioned at all, neither in the ordinance nor in the explanatory report. Once again, the rules are written for exporting CO₂ to storage sites rather than for recycling it in domestic carbon cycles.

SPIN’s position

This consultation fits a pattern SPIN has described in its list of regulatory blockades for Power-to-X: Swiss climate legislation is technology-neutral and forward-looking, but investment decisions fail at ordinance level. From a Power-to-X perspective, the revision should:

  • recognise CCU alongside CCS – both are needed, and domestic carbon recycling complements imports of renewable energy carriers rather than replacing them;
  • exempt pilot and demonstration plants, and projects that produce renewable fuels from recycled CO₂ from biogenic, atmospheric or industrial sources, from the 10,000-tonne threshold;
  • allow the reduction to be credited to both the CO₂ source and the renewable fuel producer for a limited period, so that the first generation of plants can be financed at all;
  • judge projects by their climate impact rather than by formal criteria about where the carbon comes from.

SPIN will submit a statement. Members who want to contribute their practical experience can reach us at info@power-to-x.swiss.

Key dates

  • Consultation deadline: 7 December 2026
  • Planned entry into force: 1 July 2027

Sources: Draft amendment to the CO2-Verordnung; explanatory report (7 September 2026); Fedlex consultation page.

🤖 AI transparency: This text and its visual were created using AI, reviewed and approved by a human.