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Freshfields Transactions

| 5 minute read

Inside Infrastructure: Belgian Market Update

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We are observing three key trends in Belgium:

  1. Construction sector outlook: a rebound is expected in the Belgian construction market as from 2025. The average growth rate is expected to reach 3.1% by 2028 and will mainly be supported by investments in both the transportation and renewables sectors.
  2. Data centres: according to the Belgian Digital Infrastructure Association (BDIA), the Belgian data centre market is expected to grow by 50% in 2025, mainly driven by international investments and the rise of cloud and and knowledge engineering innovations. However, we see that data centres are concentrated around Brussels and in Flanders, while Wallonia only represents approximately 4% of the Belgian data centres. 
  3. Battery storage: numerous battery energy storage system (BESS) projects have been developed or have been kicked-off in Belgium over 2024. The further development of BESS in Belgium will play a critical role for the nation to reach the EU 2050 Net Zero objective, alongside the ongoing expansion of Belgium’s renewable energy capacity. 

Latest infrastructure deals and opportunities 

  1. Giga Storage Belgium will kick-off the construction works of its new BESS in the summer of 2025. The facility will be in Dilsen-Stokkem and will become one of Europe’s largest BESS. The project will be designed by Sweco and the planned Green Turtle battery park will have a capacity of 700 MW and a storage capacity of 2,800 MWh of electricity.
  2. Vioneo BE (fossil-free methods of plastic production), with support from Vopak Belgium and the Port of Antwerp, will establish its first production complex in Antwerp, expected to kick-off operations in 2028. Vioneo BE intends to pioneer the defossilisation of the chemical sector by using green methanol to produce fossil-free polypropylene and polyethylene at a commercial scale. With its first plant, Vineo aims to cut at least 1.5 million tonnes of CO₂ emissions annually.
  3. In June 2024, Equans started the construction works for its new BESS in Vilvoorde, commissioned by ENGIE. The aim is to finalise the project by early 2026, with a capacity of 2 x 100 MW and an energy storage of 800 MWh.
  4. Energy Solutions Group and Tesla have started the construction works of their BESS in La Louvière, in collaboration with BSTOR and Duferco Wallonie. The finalised project will feature 36 Tesla Megapacks, providing a total capacity of 50 MW.

Legal update on the Belgian CCS landscape

In Belgium, the regulatory framework for CO₂ transmission and storage via pipelines is still under development. As of now, no specific regulatory authority has been designated at the federal level to oversee and appoint the transmission system operator (TSO) for onshore CO₂ pipelines, even if the Commission for Electricity and Gas Regulation (the CREG) is often mentioned in publications.

Recognising the need for a structured approach to CO₂ transport, Fluxys Belgium has proactively collaborated with Pipelink, Socofe, and SFPIM to establish the "Fluxys c-grid," a dedicated CO₂ network operator (e.g. "Antwerp@C" (Port of Antwerp-Bruges - project aimed at capturing and transporting CO₂ from chemical and petrochemical industries to storage sites) and "CO₂TransPorts" (European CO₂ transport corridor linking industrial clusters in Belgium, the Netherlands, and Germany)). However, Fluxys has not been officially recognised as (federal or regional) CO₂ TSO to date.

As of May 2025, Belgium's regulatory framework for CO₂ transmission and storage is shaped by both federal initiatives and regional collaborations: (i) the federal regulator is responsible for national and cross-border transport infrastructure, including aspects that require international cooperation, and (ii) the regions handle regional transport infrastructure, including roads, waterways, and local public transport of CO₂. 

We note the following significant developments:

  1. Federal level: in April 2024, Belgium, alongside Denmark, the Netherlands, Norway, and Sweden, signed international arrangements to facilitate cross-border CO₂ transport and storage. These agreements aim to remove obstacles and promote a well-functioning CCS market in the North Sea region. Despite these advancements, as of March 2025, Belgium has not appointed a national CO₂ TSO, nor has the federal regulator issued a decree with respect to the transmission and storage of CO₂. The establishment of a national / interconnected CO₂ network will require the appointment of an official Belgian TSO.
  2. Wallonia: the Walloon government published a decree dated 28 March 2024 with respect to the transmission of CO₂ via pipelines (the Walloon CO₂ Decree). Following entry into force of the Walloon CO₂ Decree, the Walloon Air and Climate Agency (AWAC) has released a call for applications for the appointment of a CO₂ TSO in Wallonia. The application period expired on February 26, 2025, and the Walloon government should appoint its TSO by the end of October 2025. However, since this decision-making process is not subject to sanctions, we cannot exclude that the designation of the Walloon CO₂ TSO will take longer.
  3. Flanders: on March 29, 2024, the Flemish Parliament adopted a decree with respect to CO₂ transmission via pipelines in the Flemish Region (the Flemish CO₂ Decree). The Flemish CO₂ Decree will only enter into force on June 30, 2025, and differentiates between a main CO₂ transmission network and several local clusters, particularly in port areas. This distinction allows the Flemish government to select different TSOs for these clusters, with the aim to prevent a potential monopoly by the main network TSO. The public consultation with respect to the designation of the main network TSO in Flanders ended on 20 May and the VREG has published its report on 2 June 2025, concluding that (i) the Fluxys-grid meets all statutory “capability” tests, (ii) scores sufficiently on the seven qualitative criteria, and (iii) additional safeguards (including reporting obligations and tariff-setting rules) should be strengthened. The Flemish Government has until 2 March 2026 to assess the complete application file.

We cannot rule out that once the federal government issues federal regulations with respect to the transmission and storage of CO₂, this could lead to amendments to the regional regulations in order to facilitate collaboration and the creation of an interconnected CO₂ grid in Belgium.

Please get in touch if you would like more information or would like to discuss any of the above.

And finally…. Real Asset or Fake News?

As some of you spotted last week “Aquamarine hydrogen” was the imposter hiding in the hydrogen rainbow. 

This week, with all of the interest in BESS,  we are raiding the toy box to explore other solutions that are being tried and tested to store energy in the short term. But which of the following is a pipe dream amongst the green dreams?

  1. All aboard the “Energy Train”: Using surplus electricity to send heavy trains up hill, and harnessing the power generated as they roll back down again. The best grown up train set.
  2. Deep sea balloons: Utilising excess energy at times of low demand to pump compressed air into huge balloons anchored deep under the sea, and then allowing the deep sea pressure to drive the air back up and through turbines when energy demand is high.
  3. Fantastic elastic: Filling large underground caverns with a web of high strength elastic fibres. Surplus energy is used to power robotic arms to stretch and wind the elastic storing mechanical tension, which when energy is needed can be released, powering generators as the elastic snaps back. A robo-catapult.
  4. Concrete block battery packs: Giant cranes powered by excess renewable energy lift and stack huge concrete blocks  ready to lower and turn the stored energy back to electricity when needed. The ultimate game of Giant Jenga.
  5. Ready salted batteries: Solar plants storing unharnessed heat from the sun by using it to melt massive tanks of salt. This savoury liquid will stay hot for days, allowing the heat to be harvested and turned to energy when needed.

If you think you have spotted the fiction amongst the facts, please get in touch. We will publish the answer in our next post.

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