Action brought on 17 October 2025 – RockRose (NL) CS1 v Commission

(Case T-723/25)

(C/2025/6644)

Language of the case: English

Parties

Applicant: RockRose (NL) CS1 BV (Utrecht, Netherlands) (represented by: V. van ′t Lam, lawyer)

Defendant: European Commission

Form of order sought

The applicant claims that the Court should:

—	annul the Decision pursuant to Article 263 TFEU;

—	annul the Delegated Regulation pursuant to Article 263 TFEU;

—	declare Article 23 NZIA inapplicable pursuant to Article 277 TFEU;

—	order the Commission to pay the applicant’s costs pursuant to Article 134 of the Rules of Procedure of the General Court, including the costs relating to any intervening parties.

Pleas in law and main arguments

In support of the action, seeking the annulment of the Commission Decision EU 2025/1479 of 22 May 2025, specifying the pro rata contributions to the Union CO2 injection capacity objective and of the Delegated Regulation (EU) 2025/1477 of 21 May 2025, specifying the rules on the identification of authorised oil and gas producers who are required to contribute to the objective of reaching the Union target for available CO2 injection capacity by 2030, and a declaration of inapplicability of Article 23 of Regulation (EU) 2024/1735, establishing an obligation to contribute to the Union-wide target for available CO2 injection capacity, the applicant relies on two pleas in law.

First plea in law, alleging that Article 23 of Regulation (EU) 2024/1735 is incompatible with the EU Charter of Fundamental Rights and the general principles of EU law, such as the principle of proportionality, the procedural and substantive requirements of the principle of proportionality, the right to property, the principle of legal certainty, the commercial freedom as protected by Article 16 of the Charter and the principle of equal treatment. The Commission Decision EU 2025/1479 and the Delegated Regulation (EU) 2025/1477 having been adopted pursuant to Article 23 of Regulation (EU) 2024/1735, are therefore unlawful.

Second plea in law, alleging that the Commission Decision EU 2025/1479 and the Delegated Regulation (EU) 2025/1477 are incompatible with the EU Charter of Fundamental Rights and the general principles of EU law, such as the principle of proportionality, the procedural and substantive requirements of the principle of proportionality, the right to property, the principle of legal certainty, the commercial freedom as protected by Article 16 of the Charter and the principle of equal treatment.