EU Emissions Trading System and market stability reserve: competitiveness and cost-effective decarbonisation

Sysav Sydskånes avfallsaktiebolag, manages waste from households and industries and recycles and recover as much as possible into new resources that are returned to society. Sysav believes that waste management should be regarded as an essential infrastructure in a well-functioning society.

My comments concern one feature only: the administrative architecture of the new conditionality on free allocation, and of the associated obligation to return allowances on relocation. I say nothing about the cap, the linear reduction factor, allocation volumes, benchmarks, carbon leakage, sectoral scope, the Market Stability Reserve or the funds.

The Confederation of Industry of the Czech Republic (SP CR) appreciates that some of the adjustments called for by industry have been made, for example in the area of the linear reduction factor, the use of revenues, or partial adjustment of the market stability reserve. The proposed adjustments give industry more room to implement decarbonisation measures, but time alone is not enough.

EUROMOT, is the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, representing the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Please find our input in the attached document.

In general, the Czech Republic welcomes the direction of the proposed revision of the EU ETS, which reflects some of the long-standing requirements of the Member States and the energy sector, in particular maintaining the important role of free allocation, adjusting the functioning of the MSR and easing the pace of the reduction of the cap.

Filed in Czech · English published by the European Commission

Please find attached our response to the consultation questionnaire. We are submitting it this way because a technical error is preventing us from using the designated link. We are also sending a separate email with a screenshot evidencing the error that prevented us from submitting the questionnaire through the proper link. We hope our input and contributions can now be duly considered for this consultation.

The Zero Emissions Platform (ZEP) is the official advisor to the European Union on industrial carbon management and seeks to accelerate its deployment in line with Europes climate ambition. Our comprehensive technical work and policy advice builds on a broad and diverse member base, ranging from energy producers and industrial companies to infrastructure developers, technology and equipment providers, financial…

The Malta International Shipowners Association (MISA) welcomes the opportunity to contribute to this consultation. Representing shipowners operating under the EUs largest flag, MISA fully supports the climate ambition of the European Union and remains committed to the fair and effective decarbonisation of maritime transport in line with global climate objectives.

ReCarber welcomes the opportunity to provide input into the European Commission's consultation. ReCarber works with project development, commercialization, and financing of BECCS projects. Our project developer and investor perspective means the response highlights certain elements that are typically not as well represented, but important to accelerate carbon removal projects.

Considering all the evidence regarding emissions from the use of biomass for energy, it is unacceptable that the EU does not include these emissions in the EU ETS as is the case at the moment. Whether the biomass is used in biofuels, biogas, direct burning or any other form, the emissions from the point of use must be included, if an emission trading system should make any sense.

Conservation International Europe welcomes the opportunity to contribute to the call for evidence on the revision of the EU Emissions Trading System 1. As a scientific organization working on the frontlines of climate change and dedicated to protecting and restoring nature for people, we support policies that reflect the scientific consensus on climate change and keeping the 1.5C target alive.

The European Waste Oils Re-refining Industry Association (GEIR) supports the inclusion of any waste incineration installations in the EU ETS, provided this step is underpinned by a robust and comprehensive impact assessment. At present, re-refining installations are covered by the ETS, while waste incineration facilities are not, creating an uneven regulatory landscape that disadvantages re-refining operators.

2025 Transición Energética July 2025 The Future of the ETS, priorities for the chemical industry . Whilst with different cost-implications and impact across sectors, the EU Emissions Trading System (ETS) provided reasonable protection against carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CDE does not support the use of free allocations, including for non-CBAM sectors, in order to ensure a full application of the Polluter Pays Principle and to provide the necessary incentives in support of lower-emission goods and practices and ensure policy coherence.

Integration of removals into the ETS is critical for the ETS functioning and scaling permanent removals. Removals are critical meet the EUs 2040 climate targets. The EU ETS is a core component of EU climate policy. Without removals, the ETS will face liquidity challenges as the number of allowances reduces towards zero towards the end of the 2030s.

The carbon price in the EU ETS is an investment signal for the power sector to reduce fossil fuel consumption, but for stationary industrial installations the system fails: the continued free allocation of emission allowances has contributed to the limited decarbonisation of the steel, cement and chemicals sectors, which remain the main sources of industrial CO2 emissions in the EU.

Filed in Polish · English published by the European Commission

NHO have been in favour of emissions trading since Rio 92 and actively pursuing in Kyoto 97. With a global carbon price as goal the EU-ETS is a predictable and cost-effective step. However, predictability got challenged by misconceptions about ETS ability to drive the energy transition and recent adjustment of the linear reduction factor is another intervention not fit to purpose.

The Polish Chamber of Chemical Industry appreciates the opportunity to provide input to the consultation on the review of the EU Emissions Trading System. The enclosed position paper outlines our key priorities and recommendations from the perspective of the Polish chemical sector.

Consultation Feedback ETS post 2030 Sustainable Mining in Europe – Sustainable Mining for Europe POSITION PAPER May 2025 ETS post 2030 Euromines, the voice of European mining industry, wants to express its position and its requests on the revision of the ETS Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached feedback from the Direct Air Capture Coalition with the following signatories: Carbon Blade Carbon Engineering DACMA GmbH Direct Air Capture Coalition Heirloom Carbon Institute for Responsible Carbon Removal Mijndert Van der Spek NEG8 Carbon Parallel Carbon Planet Savers Terrafixing Zero Carbon Systems

Unrestricted IATA’s response to the call for evidence regarding the EU Emissions Trading System Introduction The International Air Transport Association (IATA) is the global trade association for airlines, representing over 360 members and accounting for more than 83% of global air traffic.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Statement accompanying ESWET's responses to the EC Questionnaire on the inclusion of Waste-to-Energy in the EU ETS This statement accompanies ESWET's responses to the European Commissions questionnaire on the potential inclusion of Waste-to-Energy (WtE) in the EU Emissions Trading System (ETS).

The Royal Belgian Shipowners Association (KBRV) proactively looks after the common interests of all shipowners and ships managers established in Belgium and involved in international maritime transport by sea. KBRV welcomes the opportunity to provide input to the European Commission (EC) on the review of the EU ETS with this call for evidence.Please find attached our replies.

As shown in our submission (Pdf attached), we believe that biomass energy and biofuels, including for aviation and shipping, must no longer be treated as zero carbon under EU-ETS rules. Furthermore, we set out why including so-called "permanent carbon removals" in ETS would create new offsetting opportunities for polluters, even though there is no technically and scientifically proven way to permanently remove…

July 8, 2025 Re: Consultation on the EU Emissions Trading System and the Market Stability Reserve European Commission Introduction Airlines for America1 (A4A), the principal trade association for the U.S. airline industry, appreciates the opportunity to provide our comments on the review of the EU Emissions Trading System (ETS) and additional policies needed to achieve the EU’s climate targets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Edison supports the European Commission in launching a consultation on the revision of the EU Emissions Exchange System (EU ETS) and the Market Stability Reserve (MSR), confirming its willingness to contribute constructively to the process.

Filed in Italian · English published by the European Commission

Bruxelles, le 8 juillet 2025 P O S I T I O N S U R L A R E V I S I O N E T S La Commission européenne a ouvert une consultation sur le marché du carbone et la révision de la directive applicable au système d’échange de quotas d’émission (SEQE-ETS UE).

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Carbon Balance Initiative welcomes the opportunity to contribute to the European Commissions Call for Evidence on the revision of the EU Emissions Trading System and Market Stability Reserve. This submission outlines our key recommendations and policy suggestions to strengthen the coherence, ambition, and integrity of the EU ETS in line with the Unions climate neutrality objectives.

This comment recommends that the Commission consider the role of biogenic content testing (Carbon-14) in determining the biogenic carbon content of CO emissions under the EU ETS's current monitoring and reporting framework.

Please find attached WWF EU response to the call for evidence on the EU ETS 1 and MSR. The WWF European Policy Office (EPO) welcomes the opportunity to contribute to the call for evidence on the revision of the EU Emissions Trading System 1 (EU ETS for maritime, aviation and stationary installations (power and industry sectors) and the Market Stability Reserve (MSR), which aims at collecting evidence ahead of the…

EUROMALT is the trade association of the malting industry in Europe, representing and promoting the interests of the European malting industry at EU and international levels. The European malting industry accounts for approximately 1/3 of the total worlds capacity in malt production (up to 11 million tonnes of malt, produced each year and used for brewing, distilling, and food and feed production worldwide).

European Commission Sent via the Have your say Portal Reykjavík, July 8th, 2025 Regarding: EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review The Federation of Icelandic Industries (hereafter SI or the Federation) welcomes the opportunity to provide feedback on the call of evidence regarding the EU emissions trading system.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Carbon Business Council 1) strongly supports the incorporation of carbon dioxide removal (CDR) into the EU ETS to build demand for removals and 2) encourages the EU to adopt a method-neutral, criteria-based approach to help spur innovation. We outline our feedback in more detail below.

WE Soda, the largest producer of soda ash in the world, urges the EU to revise its EU Emissions Trading System (EU ETS) to genuinely support the decarbonization of the glass value chain in Europe while strengthening industrial innovation. The current EU ETS design disadvantages low-carbon soda ash compared to higher-carbon soda ash made in the EU. This is for two fundamental reasons: 1.

We express our strong support for the European Commissions proposal to update the EU Emissions Trading System (ETS), recognizing it as a pivotal step toward fulfilling the European Green Deal and achieving the revised 2040 climate targets.

Ares(2025)3030455 Formatted: Font: 8 pt Formatted: Font: 8 pt Réponse de la FNAM à la consultation de la Commission européenne sur le SEQE et la Réserve de Stabilité du Marché Formatted: Font: 8 pt Formatted: Font: 11 pt Résumé exécutif : Formatted: Font: 11 pt La Fédération Nationale de l’Aviation et de ses Métiers (« FNAM »), qui rassemble les principales compagnies aériennes françaises ainsi que leurs…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Icelandic Enterprise stresses a few key issues for consideration in the ETS review: The need to avoid double burdens in maritime shipping and take special circumstances of small island nations to create a level playing field in maritime transportation, the need to account for special circumstances of small island nations to maintain a level playing in aviation and look toward global solutions…

The International Emissions Trading Association (IETA) welcomes the opportunity to provide feedback to the Commission's consultation on the revision of the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MSR). Carbon trading is the most effective and economically efficient tool for advancing climate ambition.

[Full 4000-characters-length input attached due to issues with characters counting system] CAN Europe supports the extension of the scope of the ETS1 in line with the Polluter Pays Principle, by lowering the nominal thermal power threshold for energy production units, by including municipal waste incineration and other waste management processes, and by including further emissions of the maritime sector, and by…

Moeve welcomes the opportunity to contribute to the European Commissions review of the EU Emissions Trading System (ETS) and the Market Stability Reserve (MSR). As a central pillar of the EUs climate architecture, the ETS plays a decisive role in decarbonizing the European economy, particularly the industrial, energy, maritime, and aviation sectors.

Clean Air Task Force Recommendations for the ETS and MSR Review Clean Air Task Force (CATF) is a global climate organisation working to develop the technologies and policies needed to avoid the worst effects of climate change. CATF recognises the central role of the ETS in the EU climate law, as a key driver of decarbonisation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Régions Ultrapériphériques européennes Ref. Ares(2025)5519958 - 08/07/2025 Contribution conjointe de la Conférence des Présidents des Régions Ultrapériphériques Dans le cadre du réexamen du Système d’Échange de Quotas d’émissions carbones 08 juillet 2025 Dans le cadre du Pacte vert pour l’Europe, l’Union européenne s’est engagée à réduire ses émissions nettes de gaz à effet de serre d’au moins 55 % d’ici 2030, en…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EU LETS is a system to reduce companies’ CO2 emissions. This philosophy only works in a free market where an economic advantage leads to a situation where less sustainable companies compete outside the market.

Filed in French · English published by the European Commission

Waste-to-Energy (WtE), waste incineration with energy recovery, provides a sanitary service to communities by treating residual waste that cannot be prevented or recycled. There are ca. 500 plants in Europe treating around 100 million tonnes of residual waste every year, from municipal but also commercial and industrial activities.

HydroJeel feedback to the European Commission Call for Evidence – Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve 8 July 2025 HydroJeel is a Morocco-based company providing transformative and integrated solutions in the green hydrogen sector. It is a business of INNOVX and operates within OCP’s ecosystem.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Seas At Risk welcomes the revision of the EU Emissions Trading System and Market Stability Reserve as a vital step toward climate-aligned, ocean-safe shipping. We strongly support extending the ETS to smaller maritime vessels (4005,000 GT), which make up a significant share of emissions and operate close to coasts and communities.

The voice of Polish business and scientific community in Brussels Brussels, July 2025 Review of the EU Emissions Trading System (EU ETS) Business & Science Poland’s position Assessment of the Functioning of the EU ETS and the Market Stability Reserve – Experiences, Limitations and Recommendations An assessment of the functioning of the EU Emissions Trading System (EU ETS) to date, along with accompanying mechanisms…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Carbon Engineering’s response to the “Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve” call for evidence We support the integration of high quality, measurable, verifiable, and permanent removals into the European Union Emissions Trading System (EU ETS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The following suggestions aim to further develop and improve the system to ensure the effective reduction of emissions in the EU: - The effectiveness of the current instruments could be improved: Through the invalidation mechanism of the MSR, the carbon budget has effectively been reduced below the level implicitly agreed upon in the ETS Directive.

Calcarea Feedback - Open public consultation EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review Calcarea appreciates the opportunity to submit feedback to the review of the EU Emissions Trading System.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

E3G welcomes the opportunity to respond to the European Commission's Call for Evidence for the review of the EU ETS Directive and the Market Stability Reserve (MSR) Decision. This consultation is crucial for aligning the EU ETS with the upcoming 2040 climate target and ensuring its effectiveness in driving decarbonisation beyond the power sector. Please find attached our full response.

Please find attached Condor Airlines' feedback on the ongoing consultation regarding the upcoming review of the EU Emissions Trading System for maritime, aviation, and stationary installations, as well as the Market Stability Reserve. Thank you very much for the opportunity to contribute.

easyJet’s Response to European Commission’s Call for Evidence for An Evaluation and Impact Assessment on EU ETS Overview easyJet is one of Europe's largest airlines, offering a unique and winning combination of the best route network connecting Europe's primary airports with great value fares and friendly service.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please see the attached contribution from the Government of Iceland as regards review of the ETS with respect to aviation and maritime, and related matters. In a nutshell: Iceland remains fully committed to climate action and supports an equitable and effective carbon pricing in aviation.

A full inclusion of MWI installations in the EU ETS without any complementing additional measures is not suitable to achieve emission reductions in the waste management sector. WtE has hard-to-abate emissions that cannot proactively be mitigated by the operators in any other way than with carbon captures. Without this, the only way to reduce emissions would be to shut down facilities or rejecting certain wastes.

Sysav welcomes the EC public consultation and coming impact assessment, in particular regarding (1) expansion of the scope of the ETS to the inclusion of the waste sector; (2) inclusion of carbon dioxide removals (CDR); and (3) revision of ETS revenues use. Key messages: 1.

CCS Europe welcomes the opportunity to contribute to the call for evidence on the revision of the EU Emissions Trading System. Please find our detailed comments attached. Carbon capture technologies are indispensable for the EU to reach net-zero by 2050. For some industries especially those with process emissions, carbon capture and storage technologies are the only solution to decarbonise.

Please find attached IAGs response to the European Commissions call for evidence on the EU Emissions Trading System (EU ETS) and the Market Stability Reserve, submitted as part of the ongoing consultation process ahead of the 2026 Directive revision.

On CDR integration into the EU ETS. The full introduction of sustainable, permanent CDR (carbon removal units, CRUs) into the EU ETS would enable the most cost-effective and resource-efficient solutions to deliver mitigation outcomes. After EU allowance (EUA) issuances have reached zero, all remaining emissions covered by ETS I & II would need to be matched with a permanent CRU.

The European Regions Airline Association (ERA) welcomes the opportunity to provide feedback to the European Commissions revision of the EU Emission Trading System Directive (EU ETS) concerning aviation. ERA is the trade association representing more than 50 airlines and over 150 associate members, including manufacturers, airports, suppliers and aviation service providers, across the entire spectrum of the aviation…

A credible, reinforced and expanded EU ETS is instrumental in achieving the European 2030 climate targets and the 2050 climate neutrality objective in a cost-effective way. Any revision of the EU ETS should be made with the objectives of preserving market confidence, establishing clear and simple market rules, developing reliable standards and ensuring a stable and predictable investment framework through an EU-wide…

ACI EUROPE supports the EU ETS as a core policy instrument, complementing ICAOs CORSIA scheme for international flights. The EU ETS is seen as essential for accelerating the sectors energy transition and bridging the gap until breakthrough technologies and Sustainable Aviation Fuels (SAF) are widely available.

EuLA, the European Lime Association, represents European non-captive lime production through its 24 covered Member States (companies & national associations). Lime is one of the essential building blocks of modern industry.

We welcome the opportunity to feed into this review of the EU ETS for maritime and aviation. It is imperative that the review takes into account the wider context in which the EU chooses to decarbonise the continent: addressing climate change, ensuring strategic autonomy on energy matters, and competing globally at the highest levels through innovation.

In view of the call for a revision of the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve review and the call for evidence opened by the COM, the Directorate General for Merchant Shipping of the Ministry of Transport and Sustainable Mobility of Spain presents comments relating to the maritime sector in an attached document.

Filed in Spanish · English published by the European Commission

Towards a Stronger EU ETS by 2040: Summary The EU Emissions Trading System (ETS) remains central to the EUs climate strategy. While it has reduced emissions, it must now adapt to heightened climate goals, global competition, and faster industrial transitions.

KEY MESSAGES The ETS review needs to balance environmental ambition with the necessary enabling conditions for decarbonisation investments (internationally competitive energy and raw materials, effective trade and carbon leakage measures, funding support, lead markets).

Open public consultation concerning the review of ETS1 Snam, as Europe’s leading multi-molecule energy infrastructure operator in transport and storage, welcomes the opportunity to provide feedback on the ETS1 Review public consultation. We appreciate the progress achieved by the EU Emissions Trading System in reducing emissions across several sectors so far and the commitment to continuously improving it.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

July 8th, 2025 To: DG CLIMA Units B1, B2, B4, C2 Subject: Enerkem’s response to the Call for Evidence on the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review Enerkem welcomes the opportunity to comment on the EU Emissions Trading Scheme (EU ETS), an essential instrument of decarbonization and pillar of the energy transition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Review of the EU ETS for aviation, maritime transport and stationary installations and the Market Stability Reserve Position of the Associazione Scuolambiente for the inclusion of municipal waste incineration plants in the EU ETS.

Filed in Italian · English published by the European Commission

Touraine Propre strongly emphasizes the need to prioritize waste reduction at the source in the framework of the EU Emissions Trading System (EU ETS). The inclusion of Municipal Waste Incineration (MWI) facilities into the ETS, as currently considered, raises serious concerns regarding its environmental effectiveness, economic impact, and social fairness.

A higher carbon price is needed to incentivise faster industrial decarbonisation and reduce reliance on volatile and expensive fossil fuels. While the EU ETS functioning has improved, for certain industrial sectors the decrease of emissions is not in line with reaching climate neutrality by 2050.

Inclusion of waste incineration in the EU ETS will unlock CO2 volumes needed for European Power-to-X projects About Prime Capital Prime Capital is an independent asset management firm and alternative investment specialist with a focus on Continental Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aviation accounts for 2% of global CO emissions and 3.84% of total EU-wide emissions. It contributes 851 billion to European GDP (5%) and generates a strong multiplier effect on job creation and GDP per capita, +1.6% and +0.5%, respectively, for every 10% increase in connectivity. Yet, aviation has been included in the EU Emissions Trading System (EU ETS) since 2012, as the first transport mode.

EFIEES is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks.

BlueLayer, the leading software platform for developers of Carbon Removal projects, welcomes the opportunity to contribute to the review of the EU ETS framework. To reach climate neutrality by 2050, the EU ETS must not only drive emissions reductions but also create a robust framework for high-quality carbon removals, which can offset unavoidable residual emissions.

Please find attached a briefing note summarising our argument for the EU to consider a role for project-level risk assessment in the form of carbon ratings to deliver a more effective integration of removals into the ETS. This supplements the feedback we have provided in response to the consultation questionnaire.

The JSW Group, the largest producer of coking coal in the European Union and one of the leading producers of coke used in steelmaking, welcomes the opportunity to contribute to the review of the EU ETS framework post-2030.

July 03, 2025 The future of the European Union’s Emission Trading Scheme Solvay S.A. Position Paper We emphasize the crucial need for the EU to implement changes that provide robust carbon leakage protection, ensure fair and harmonized cost compensation, and introduce realistic and flexible pathways for emission reduction. 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Submitted by: Pyrolyse Danmark (representing the Danish pyrolysis and Biochar industry) Summary: The European Commissions upcoming evaluation of integrating permanent CDR into the EU ETS marks a pivotal moment for climate policy. BCR is a proven, scalable CDR method with a technology readiness level (TRL) of 89, already delivering over 90% of durable carbon removals in Europe.

STX Group is a global leader in environmental commodity trading, driving the transition to a low-carbon economy by enabling the market-based exchange of carbon credits, renewable fuels, and other decarbonization instruments.

08-07-2025 Ref. Ares(2025)5519776 - 08/07/2025 A.P. Moller-Maersk public consultation response on EU ETS review A.P. Moller-Maersk would like to thank the European Commission for the opportunity to comment on this public consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IDM facilities perform a public health function. They are not responsible for the nature of the inputs and cannot reduce their GHG emissions. They manage the waste produced by households on their own. The inclusion of UEVs in the ETS leads to a distortion of the incineration sector compared to the waste sector, while it avoids GHG emissions through the recovery of waste heat and emits less GHG per tonne treated than…

Filed in French · English published by the European Commission

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) is an independent environmental and consumer protection organisation that promotes waste prevention and the sensible use of valuable resources within the circular economy. DUH strongly supports the inclusion of municipal waste incineration and landfilling in the EU Emissions Trading System (EU ETS) as part of the review scheduled for July 2026.

Faerch strongly supports the inclusion of waste incineration and landfilling under the EU Emissions Trading System (EU ETS), as a critical step to drive decarbonisation in the waste sector and promote higher-value circular practices. Incineration and landfilling are the most carbon-intensive waste treatment options.

International Council on Clean Transportation consultation response on Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve July 8, 2025 The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to provide input on the review of the EU Emissions Trading System (ETS) and the Market Stability Reserve (MSR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Accelerating Renewable Carbon in Chemicals/Materials via EU ETS Core Objective: Reform ETS to drive the transition from fossil to renewable carbon feedstocks (biogenic, captured CO, recycled) in chemicals and materials, ensuring improving circularity and tackling Scope 3 emissions.

IFIEC Europe represents the interests of industrial energy users in Europe for whom energy and climate policies are significant components of production costs and a key factor of competitiveness in their activities in both Europe and throughout the world.

Danish Shipping thanks the European Commission for the opportunity to contribute to the ongoing evaluation and refinement of the EU Emissions Trading System (EU ETS) as it applies to maritime transport. The feedback below re-flects the practical experience of the members of Danish Shipping with the system during its first phase of implementation and includes concrete recommendations to enhance coherence, reduce…

The Carbon Management Alliance (CMA) is a German association bringing together companies and industry associations from industrial sectors that produce non-to-abate and hard-to-abate CO emissions, as well as companies building the CCS value chains of tomorrow.

The ETS framework is a cornerstone of EU climate policy and the revision in 2026 will hopefully increase its coverage. However, including carbon removal credits from biogenic emissions with carbon capture and storage (BioCCS) and long term storage in products may result in a strong incentive to increase biomass harvesting, thereby undermining the achievement of the targets set in the LULUCF Regulation and the Nature…

Air Liquide welcomes the European Commissions intention to propose a revision of the Emissions Trading System. We firmly believe that all available emission reduction technologies need to be supported in order to reach the EUs decarbonization and industrial objectives.

The EU sugar industry reduced its CO2 emissions by 59 % between 1990 and 2021. By this metric, we are well on the way to meeting the objective of the ETS1 to reduce emissions by 62% by 2030. Sugar manufacturers recognise the importance of continued progress in reducing greenhouse gas emissions in order to reach climate neutrality by 2050.

Please find a report on the interaction between CDR and the EU ETS in attachment. Bellona recommends an interaction approach as a pragmatic and effective way to leverage the climate benefits of CDR without prematurely fully integrating removals into the ETS, while addressing current technical, accounting and policy challenges.

In the last years EU has lost its strong industry companies and is continuously loosing production/capacities, competitiveness. Companies are not able to decarbonise as they planned due to lack of enabling conditions (competitive energy costs and certainty about stability of energy supply, weak carbon leakage and trade protection, sufficient financial support without unnecessary conditionality, availability of raw…

To strengthen the EU ETS as an effective decarbonisation tool, several reforms are necessary. First (1), all ETS 1 revenues should be fully reinvested into decarbonising ETS 1-covered industries. Currently, Member States have wide discretion over revenue use, often diverting funds away from industrial decarbonisation despite these sectors facing the steepest technological and financial barriers while competing…

IndustriAll European Trade Union (IAE) is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 200 national trade union affiliates in 39 European countries.

Envien Group welcomes the opportunity to provide input to the ongoing revision of the EU ETS framework. Based on practical experience from industrial operations within the biofuel sector, and taking into account current regulatory and economic challenges, we would like to highlight the following considerations and recommendations. 1.

Berlin, 08 July 2025 BDEW Bundesverband der Energie- und Wasserwirtschaft e.V. (German Association of Energy and Water Industries) BDEW Representation at the EU Avenue de Cortenbergh 52 1000 Brussels Position Paper Belgium www.bdew.de Statement on the Inclusion of Municipal Waste Incineration and other Waste Management Processes in the ETS 1 Open public consultation concerning the review of ETS1 The German…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Finnur Sveinsson Kt. 1109664749 Dags. 8.7.2025 14:31:53 Ástæða: Undirritun Ref. Ares(2025)5519724 - 08/07/2025 8 July 2025 European Commission – DG Clima HS Orka – Feedback letter on the EU ETS review HS Orka is a renewable energy company that operates two geothermal energy plants in Iceland.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Starch Europe is the trade association representing the European starch and starch derivatives industry. Its members include the 30 leading starch-producing companies in the EU, collectively accounting for over 95% of the sector and representing an annual market value of 9.8 billion.

Contribution of Envien Group to the Public Consultation We welcome the opportunity to provide input to the ongoing revision of the EU ETS framework. Based on practical experience from industrial operations within the biofuel sector, and taking into account current regulatory and economic challenges, we would like to highlight the following considerations and recommendations. 1.

EuDA supports the extension of the ETS to shipping and to dredging and offshore. EuDA notes that the IMO has recently agreed a Net Zero Framework that will bring shipping net GHG emissions to zero by (or around) 2050, and that the current EU ETS legislation contains provisions to align with international legislations (IMO).

The Dutch Emissions Authority (Nederlandse Emissieautoriteit, or NEa) is the competent authority in the Netherlands for the EU ETS. The NEa performs all EU ETS-related tasks, including permitting, supervision and enforcement. This puts us in a position to reflect on the effectiveness of the EU ETS. Furthermore, the NEa is as committed as the Commission is to prevent and/or remedy unintended consequences (e.g.

Equinor’s response to the revision of the EU ETS 1 Equinor supports the European Commission’s ambition to reform the EU Emissions Trading System (EU ETS) as a key instrument to accelerate decarbonisation across the European economy and uphold the EU’s climate ambition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IOGP Europe position on the revision of the EU ETS 1 Call for Evidence IOGP Europe welcomes the opportunity to contribute to the European Commission’s public consultation on the revision of the EU Emissions Trading System (EU ETS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU EMISSIONS TRADING SYSTEM FOR MARITIME, AVIATION AND STATIONARY INSTALLATIONS, AND MARKET STABILITY RESERVE – REVIEW POLISH STEEL ASSOCIATION STATEMENT The Polish Steel Association is a non-profit trade organization representing steel manufacturers and processing plants in Poland.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

________________________________________ Contribution of Envien Group to the Public Consultation on the Revision of the EU Emissions Trading System (EU ETS) We welcome the opportunity to provide input to the ongoing revision of the EU ETS framework.

July 2025 SSAB comments on EU ETS review SSAB welcomes the opportunity to contribute with input to the call for evidence and public consultation on the EU ETS review. Please find our considerations below. SSAB investing in the transformation SSAB is committed to our transformation journey and is currently investing more than €5 billion to transform our Swedish steel production system.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Business Aviation Association (EBAA) welcomes the opportunity to contribute to the evaluation of the EU Emissions Trading System (ETS) Directive. Business aviation plays a vital economic and connectivity role across Europe, contributing 100 billion annually and supporting 449,000 jobs.

08 July 2025 NetJets response to review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve – published April 2025 1. EXECUTIVE SUMMARY NetJets Transportes Aéreos, S.A (Portuguese registered company), hereinafter referred to as “NetJets”, is pleased to take part in the review of the EU ETS for maritime, aviation and stationary installations, and of the Market…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Qemeticas Position on the review of ETS1 and MSR recommendations aiming to ensure that the EU ETS is an effective, fair, and predictable instrument for achieving climate neutrality while maintaining industrial competitiveness and supporting social cohesion. 1.

The application of the Emissions Trading System (ETS) to incinerators or landfills is an innovative measure for municipalities to reduce greenhouse gas emissions and promote more sustainable behaviour. This system, which has already been successfully adopted in various industrial sectors, offers many environmental and economic advantages in a sector such as waste, where there is considerable scope for improvement…

Filed in Italian · English published by the European Commission

The Canary Islands Industrial Association (ASINCA), representing the industrial fabric of the islands, has analysed the impact of the application of the Emissions Trading Scheme on the Canary Islands economy, as part of the European Fit for 55 legislative package. The EU ETS is applied uniformly throughout the EU.

Filed in Spanish · English published by the European Commission

AVR is a progressive and advanced Waste-to-Energy treatment facility based in Rotterdam and Duiven (NL). AVR strives to retrieve maximal value from mixed household waste and commercial and industrial waste in a circular and environmentally sound manner by retrieving secondary raw materials from residual waste and converting residual waste into steam, heat and electricity.

Lloyd's Register (LR) supports the maritime sector through technical expertise, risk management, and regulatory compliance, ensuring vessels meet international safety and environmental standards. Beyond classification, LR also plays a key role in the maritime energy transition, offering guidance on decarbonisation strategies, alternative fuels, and digital transformation.

Scaling the EUs clean technologies is key to the EUs future climate and industrial leadership. As reported by the International Energy Agency (IEA), a third of the decarbonisation we need to get to net zero by 2050 will come from technologies currently at the lab or demonstration phase, and the cleantech industry will grow to 2 trillion US dollars by 2035, up from 700 billion today.

The Industrial Gas (IG) sector is strongly integrated into the value chains of industries it serves, such as steelmaking, chemical manufacturing and oil refining. In mature economies, IG consumers may decide either to selfproduce (i.e. insourcing business model) or to outsource their IG needs to IG producers (i.e. outsourcing business model).

Review of the EU Emissions Trading System for maritime, aviation and stationary installations, and Market Stability Reserve Elettricità Futura contribution July 2025 1 Elettricità Futura, Italy’s leading Association of the electric power industrial supply chain that represents over 70% of the national electricity market, welcomes the opportunity to provide feedback on the revision of the ETS Directive and the MSR…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity provided by the European Commission to give feedback on the EU ETS call for evidence. To further improve its effectiveness and impact, we would like to highlight the following points: 1) We strongly believe in the added value of the EU ETS and MSR.

CEMBUREAU and the cement industry CEMBUREAU (www.cembureau.eu), the European Cement Association, is the representative organisation of the cement industry in Europe. Our 2050 Net Zero Roadmap published in May 2020, and revised in 2024, aligns the cement industrys decarbonisation pathway with the EU Green Deal and Clean Industrial Deal objectives and spans the full value chain, from production of clinker and cement…

EU ETS Consultation – Galp’s Supplementary Remarks This document contains additional comments on the public ETS consultation. These inputs complement our submission via the online survey and address topics that could not be fully covered within its format. 5.1 Aviation emission 5.1.1 and 5.1.2 - We do not have sufficient information to assess the overall level of action by the aviation sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments by Flughafen Wien AG on the public consultation on the EU Emissions Trading System (EU ETS) Introduction: The situation of European aviation has changed significantly in recent years. In particular, the COVID-19 pandemic and international conflicts (mainly the Russian invasion of Ukraine and the Middle East war) have led to this.

Filed in German · English published by the European Commission

WISE supports the extension of the scope of ETS1 in line with the polluter pays principle. We support the lowering of the threshold for the rated thermal power of energy production units, the inclusion of municipal waste incineration and other waste management processes in the ETS, and further emissions from the maritime sector and by including emissions from international aviation.

Filed in Dutch · English published by the European Commission

The introduction of sustainable, permanent CDR (carbon removal units, CRUs) into the EU ETS would enable the most cost-effective and resource-efficient solutions to deliver mitigation outcomes. This is particularly true for high-integrity, verifiable solutions like Direct Air Capture, which offer true permanence and traceability.

Rolls-Royce recommendations for the EU ETS, in support of a competitive, innovative, and sustainable Europe and European industrial base: ETS revenues should be used to support in-sector decarbonization efforts. Project funding should support the global competitiveness of the EU aviation, maritime and energy industries.

ETS Reform: Reconciling Industrial Transformation with Competitiveness. The EU's green transformation is at a pivotal moment. Despite initial progress, the momentum has slowed significantly, putting EU industry at risk of falling behind global competitors.

IMA-Europe position Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve 7 July 2025 (FINAL) IMA Introduction Industrial Minerals Association Europe (IMA-Europe) is an umbrella organization which brings together several European trade associations specific to individual minerals such as: Andalusite, Attapulgite, Calcium Carbonate, Bentonite, Borates…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

08.07.2025 BVEG position on the revision of the EU ETS 1 Call for Evidence BVEG is Germany`s association of natural gas, oil and geoenergy, representing the interests of its members since 1945. Founded as the voice of the exploration and production industry, BVEG has grown to represent three borehole-centered sectors: upstream hydrocarbon, underground storage and geoenergy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Cargolux Airlines International S.A. is a leading European all-cargo airline, operating a fleet of 30 Boeing 747-8 and 747-400 freighters, with a further 10 Boeing 777-8F on order. The company is headquartered at Luxembourg airport and operates a worldwide network covering over 75 destinations in over 50 countries on scheduled all-cargo flights and charter services.

Assocostal represents Italian operators in the energy logistics sector, including coastal energy stores, maritime bunkering companies, biofuel producers and companies in the LNG supply chain, which form a large part of the national economic system.

Filed in Italian · English published by the European Commission

Brussels, 8 July 2025 Cerame-Unie reply to public consultation concerning the review of ETS post-2030 On 14th April 2025 the European Commission opened to public consultation its call for evidence on the revision of the EU ETS Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Review of the EU Emissions Trading Scheme SEA-LNG submission Introduction SEA-LNG represents the entire LNG maritime fuel value chainfrom producers and suppliers to shipowners, ports, engine manufacturers, and classification societies, giving us a uniquely broad perspective on decarbonisations practical, commercial, and technical realities. This makes our views on the EU ETS especially relevant and constructive.

Sistema di scambio di quote di emissione dell'UE per gli impianti fissi, il trasporto marittimo e il trasporto aereo, e riserva stabilizzatrice del mercato – riesame Assogasliquidi è l’Associazione di Federchimica che, nell’ambito del sistema confindustriale, rappresenta le Imprese produttrici, importatrici, e distributrici di GPL (gas di petrolio liquefatto) e GNL (gas naturale liquefatto) per uso combustione ed…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback on the EU ETS from the Project Carbon2Chem® The project Carbon2Chem® welcomes the opportunity to give stakeholder feedback within the 2025 consultation on the EU ETS. Comments in a nutshell Clear and unambiguous definitions and usage of key terms in the EU ETS are essential.

A short position (limit of 4000 characters) The Polish employers welcome the public consultation of the ETS system and submit requests for revision. 1. Create an EUA price channel (introduction of a lower and upper price cap) with dynamic regulation of the supply of allowances. Once the EUA price starts to approach the upper threshold, an additional pool of emission allowances will be auctioned from the reserve.

Filed in Polish · English published by the European Commission

Stellungnahme Stellungnahme des Deutschen Gewerkschaftsbundes zur Konsultation der EU-Kommission zur Überprüfung des EUEHS (See- und Luftverkehr und ortsfeste Anlagen) sowie der Marktstabilitätsreserve Ausgangslage Die Herausforderungen der europäischen Wirtschaft sind enorm.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Green Tank supports strengthening the EU ETS and MSR to better drive a socially just clean energy transition. The EU ETS has already cut emissions from the power and industrial sectors by 51.2% since 2005, moving toward the -62% target for 2030.

Statement by the German Aviation Association (BDL) on the public consultation on The EU emissions trading system for maritime, aviation, and stationary installations, and market stability reserve – review 8. July 2025 We support the EU Emissions Trading System (EU ETS) as a key climate protection instrument of the European Union.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ASD is the voice of European Aerospace, Security and Defence Industries. With 26 major European companies and 23 National Associations as our members, the overall representation adds up to more than 4,000 companies across 21 European countries. We are actively supporting the competitive development of the sector in Europe and worldwide.

ES|ECSA submission to European Commission’s call for evidence regarding the EU ETS review I. Introduction European shipping is a strategic asset for Europe and a cornerstone of the energy, food and supply chain security of the continent.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

July 2025 Consultation on the 2026 revision of the EU ETS Eurogas accompanying note This paper highlights the main points raised by Eurogas in its response to the EC consultation on the 2026 revision of the EU Emissions Trading System.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEEDBACK BY THE MALTA CHAMBER Consultation Feedback by The Malta Chamber on the Implementation and Impact of the EU ETS – Maritime and Aviation Sectors Presented to : EU Commission Date : 08/07/2025 Version : Final Version 1 1. Introduction Malta, as a small island Member State with no land connections to mainland Europe, is entirely dependent on maritime and air transport for its imports, exports and tourism flows.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DHC supplies heat to around 12% of Europes total heat demand and serves more than 70 million EU citizens . As a flexible, locally anchored solution, DHC can rapidly integrate renewable energy, waste heat, and clean technologies. Today, over 40% of the heat in DHC systems is already decarbonised, an upward trend supported by ongoing investment and policy alignment . Yet, major challenges remain.

European Aluminium, representing the full aluminium value chain in Europe, supports the EUs climate ambitions and recognises the EU ETS as a central instrument to drive decarbonisation. However, the current design and future trajectory of the EU ETS and the MSR threaten the viability of Europe's aluminium sectora strategic industry under the Critical Raw Materials Act (CRMA), Net Zero Industry Act (NZIA), and…

bp feedback to the public consultation on the review of EU ETS1 bp welcomes the European Commission’s review of ETS1 to ensure it is fit for the future. bp supports the goals of the EU Emissions Trading System (EU ETS), as a contribution to achieving global climate ambitions, while recognising the importance of implementing it in a way that addresses concerns about European industrial competitiveness, as well as…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On behalf of the Spanish Confederation of Mineral Raw Materials Extractive Industries, PRIMIGEA, we hereby submit our position paper on the revision of the EU Emissions Trading System for maritime, aviation and stationary installations, and the Market Stability Reserve.

Hazardous Waste Europe input to the consultation on the review of ETS 1 Hazardous waste represents a relatively small amount - less than 5% of the total volume of waste produced each year. The purpose of hazardous waste incineration is to protect human health and the environment by destroying the hazardous waste generated by economic activities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Metal Packaging Europe, together with our coalition partners, strongly supports the inclusion of municipal waste incineration and landfilling in the EU Emissions Trading System (EU ETS), as part of the upcoming review planned for July 2026. A recent study (attached) confirms that this measure would deliver significant climate and employment benefits: 1.

1 (2) July 8th, 2025 Bioenergia ry – the Bioenergy Association of Finland FEEDBACK TO THE CONSULTATION ON THE EU EMISSIONS TRADING SYSTEM (EU ETS) AND MARKET STABILITY RESERVE (MSR) REVIEW Bioenergia ry – The Bioenergy Association of Finland welcomes the opportunity to provide input to the European Commission’s consultation on the EU Emissions Trading System (ETS) and Market Stability Reserve (MSR) review.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Port Authority of Valencia (PAV) welcome the opportunity to contribute to the European Commission public consultation on the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MS). The PAV shares the commitment to decarbonizing the shipping industry and welcomes the initiatives taken by the Commission in this direction.

Eni S.p.A. response to the public consultation on the review of the EU Emissions Trading System for maritime, aviation and stationary installations, and market stability reserve The EU finds itself in a crucial moment in shaping the future of its industrial base for the decades ahead.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ATR welcomes the opportunity to contribute to the European Commissions public consultation on the revision of the EU Emissions Trading System (EU ETS) for aviation, with a particular focus on non-CO emissions and allocation of revenues. You will find our detailed contribution in the attached document.

Executive Briefing: Unlocking Maritime Methane Abatement for Climate and Economic Gains The European Union has a bold vision for a cleaner, greener future with climate neutrality and decarbonising industries at its heart. The shipping community supports this vision and wants to play its role.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Advanced Carbon and Graphite Materials Association (ECGA), representing 37 companies producing 100% of the EUs graphite electrodes and natural graphite, welcomes the opportunity to contribute to the review of the EU ETS1 framework post-2030.

COGEN Europe, the European Association for the Promotion of Cogeneration, in the attached feedback would like to recommend putting in place an improved and inclusive revision process of the EU ETS for areas for simplification: 1. Aligning ETS Policy to Fairly Account for High-Efficiency CHP: Ensuring Comparable Treatment with Heat- and Power-Only Installations; 2.

Position Paper 8 July 2025 Future of the EU ETS: Assessment and strategic proposals from OFICEMEN The cement industry OFICEMEN—the Spanish Cement Association—represents the country’s nine cement-clinker manufacturing groups.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) welcome the opportunity to respond to the European Commissions public consultation on the EU Emissions Trading System (EU ETS) for maritime, aviation and stationary installations, and on the Market Stability Reserve (MSR).

The European Tugowners Association (ETA) welcomes the opportunity to contribute to the ongoing review of the EU Emissions Trading System (EU ETS). We respond specifically to the aspects of the EU ETS related to maritime transport.

According to the European Commission, the EU Emission Trading system (ETS) has helped bring down greenhouse gas (GHG) emissions from European power and industrial plants by approximately 47% from 2005 to 2023. However, as the EU intensifies its efforts to reach climate neutrality by 2050, the EU ETS and the Market Stability Reserve (MSR) need to be reviewed to ensure these tools continue to create a favourable…

We welcome the opportunity to contribute to the European Commissions review of the EU ETS as applied to maritime transport. We attach a document outlining Spanish Shipowners Associations (ANAVE) main positions. In summary, we respectfully highlight the following five key points: 1. A global regulatory framework: The EU should fully align with the IMOs forthcoming Net Zero Framework (NZF).

Despite its environmental intent, the ETS regime is causing competitive distortions, business leakage, and logistical inefficiencies that counteract its very objectives. Maltas economy, heavily reliant on maritime connectivity for both imports and exports, is particularly vulnerable to shifts in transhipment activity, which is being redirected to non-EU ports with less stringent regulations.

Don Ángel Luis Mato Adrover, con DNI nº 05342937-Z, en nombre y representación de la ASOCIACIÓN NACIONAL DE REMOLCADORES DE ESPAÑA (ANARE), cuya representación ostento en mi condición de Director General y Apoderado de la misma, como debidamente tengo acreditado con mis Poderes de fecha 18 de octubre de 2011, ante el Notario del Ilustre Colegio de Madrid Don Francisco Javier Gardeazábal del Río, con número de…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UNION OF GREEK SHIPOWNERS FOUNDED IN 1 9 1 6 Union of Greek Shipowners (UGS) submission to European Commission’s call for evidence on the EU ETS review The Greek-owned merchant fleet is the largest in the world, controlling more than 20% of global shipping capacity and over 60% of the EU fleet, operating predominantly as a cross-trader, transporting cargo between third countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Malta Maritime Forum (MMF) reaffirms its full commitment to climate action and maritime sustainability. However, the success of maritime decarbonisation efforts depends fundamentally on a single, globally coherent regulatory framework. The shipping industry is inherently international.

I am responding on behalf of IMCA, the international trade association for the marine contracting industry, representing more than 800 members. The following response is based on our knowledge of the industry and ongoing discussion and engagement with our members, different National, European and International Associations, Organisations and Government Representatives.

AIRE welcomes the opportunity to contribute to the European Commissions public consultation on the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MS). To ensure that potential amendments to the EU ETS supports, rather than hinder, aviations global decarbonisation efforts, AIRE urges the European Commission to consider the following recommendations. (see the attached document)

Arkema recognises the need of a strong carbon price architecture and supports the objective of the ETS directive to unlock decarbonisation investments in a cost-effective manner. We welcome positively the simplification ambition of the European Commission and stress the need to have a flexible and pragmatic climate policy, considering the current technological, economic and geopolitical reality.

Czech Chemical Industry Association (SCHP ČR) In our opinion, the actual (negative) impact of carbon pricing on industry in the EU, in combination with other “fit for 55” regulations, has not manifested yet. It will show in the next five years, as a result of the impact of the linear reduction factor, the end of free allowances, the CBAM factor and the tightening of emission limits, which are contrary to the idea of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the opportunity to contribute to this consultation on the EU Emissions Trading System (ETS), which we regard as a critical instrument for delivering the EUs climate and energy objectives including its legally binding target of climate neutrality by 2050.

Please find attached the contribution of Federalimentare (Italian food and drink federation) to the evaluation and impact assessment process for the review of the EU ETS for maritime, aviation and stationary installations and Market Stability Reserve.

Eurits fully supports the European Commissions climate objectives, including the goal of climate neutrality by 2050, and recognises the EU Emissions Trading System (ETS) as a key instrument for decarbonisation. We also welcome the approach and timeline set out in the most recent ETS revision, which struck a careful balance between ambition and sectoral feasibility.

A new study by CE Delft, in collaboration with Zero Waste Europe and Reloop, confirms that including waste incineration in the EU Emissions Trading System (EU ETS) would bring significant climate and employment benefits. Key findings include: 1. Major emissions reductions Including incineration in the EU ETS could cut CO emissions by 47 million tonnes in 2030, rising to 1832 million tonnes by 2040. 2.

The EU needs to create carbon dioxide removals (CDR) to balance emissions that are difficult or very expensive to address, for example from aviation, shipping and agriculture. CDR are also needed to remove carbon dioxide that has been emitted historically. Yet there are almost no incentives to produce CDR in the EU today.

8 July 2025 Position Paper EU ETS Post‑2030 Position Paper EU ETS Post‑2030 Strategic Input from the Spanish Magnesia Industry MAGES — the Spanish Association of Magnesia Producers —is a private, non-profit body that speaks for Spain’s magnesia-producing sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EdEn welcomes the European Commissions public consultation in view of EU Emissions Trading System (ETS)s upcoming revision in 2026. In our response, EdEn presents recommendations as regards to how the EU-ETS could better support the decarbonisation of the aviation and maritime transport sectors in view to achieve the following objectives: 1) Earmarking revenues from the EU-ETS towards the production of sustainable…

PGE Polska Grupa Energetyczna S.A. (PGE) welcomes the opportunity to provide its feedback as part of the evaluation of the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MSR). Please find our detailed feedback attached. Our key messages: - The EU ETS managed to reduce emissions in the covered sectors by around 50% from 2005 to 2024, primarily driven by the power sectors efforts.

Thank you for the opportunity to comment. A detailed assessment of the functioning from the point of view of was presented by Grupa Azoty in the questionnaire provided. In this consultation process, we would like to draw your attention to several important elements.

CEDEC believes that the inclusion of waste-to- energy plants in the EU ETS, especially without a proper assessment of the specific characteristics of the waste sector, could significantly compromise the achievement of circular economy and climate neutrality goals.

Estonian Chemical Industry Association, which has members from more than 50 companies in Estonia, strongly advising Commission to carry out deep in-depth impact assessment while revising EU ETS directive. We are very concerned about the loss of competitiveness of EU Industry vis-a-vis third countries.

Climate change is a pressing global challenge requiring coordinated and sustained action. At the same time the transition to climate neutrality must be grounded in economic reality, technical feasibility and global competitiveness. AmCham EU companies operate extensive industrial assets across Europe.

- Free allocation phaseout as a means of simplification - Aviation: put a seat belt on EUA supply - Free allocation: switch from process to products - Link indirect cost compensation to carbon-free electricity only - Reform the Innovation Fund to better assess the carbon footprint of electricity use, reserve grants to technology risk, and reserve scale-up subsidies to poorly capitalised sectors - Market stability…

08.07.2025 Response to the call for evidence on the EU Emission Trading System (ETS) The Norwegian Confederation of Trade Unions (LO Norway) refers to the European Commission’s call for evidence on the EU ETS1 for stationary installations, maritime transport and aviation. Our below recommendations focus on industrial installations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached the response by the Netherlands to the consultation/call for evidence for: - an Evaluation and Impact Assessment run in parallel for the Review of the EU ETS for maritime, aviation and stationary installations and of the Market Stability Reserve; - an Evaluation of the operation of the Innovation Fund; - an Evaluation of the operating rules of the Modernisation Fund;

Position of Polish Association of Heat Energy welcomes the opportunity to provide its feedback as part of the review of EU Emissions Trading System (EU ETS). Key messages: 1. EU ETS must be reformed, so it can ensure market liquidity (both in short- and long-term perspective) as well as react to the major price shocks.

The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, urges the Commission not to include composting and anaerobic digestion under the EU ETS, as this would be counterproductive and would undermine the effective transition to a circular economy. Please see attached our detailed feedback.

We welcome the opportunity to provide feedback on the call for evidence on the ETS1 review. In our view, the EU ETS is a key pillar of the EU climate and industrial policies, with the potential to serve as a strong driver of significant emission reductions and global competitiveness for European industry.

CEE Bankwatch Networks main priorities to increase the effectiveness of the EU ETS are: 1) Inclusion of waste incinerators in the EU ETS from 2028, in order to promote economically efficient greenhouse gas (GHG) emissions reduction and increase the circular management of materials in the waste sector.

Open public consultation concerning the review of ETS1 Summary 4000 characters max (for the free text response) Summary of feedback - consultation elements Whilst with different cost-implications and impact across sectors, the ETS led industry towards climate transition and provided quite some protection against carbon leakage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DélégationRef. deAres(2025)5519424 la Région - 08/07/2025 Auvergne-Rhône-Alpes à Bruxelles Système d’échange de quotas d’émission (SEQE) de l’UE pour les installations fixes, l’aviation et le transport maritime, et réserve de stabilité du marché – Réexamen Contribution de la Région Auvergne-Rhône-Alpes : La Région Auvergne-Rhône-Alpes est l’autorité de planification de la gestion des déchets et de l’économie…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Abbreviated position of the Association of Private Energy Sector Employers on the revision of the EU ETS The Association of Private Energy Sector Employers organises the biggest private entities in energy, energy efficiency and heating sectors in Poland. Some of our installations have been included in the ETS 1 system for years.

Positionspapier des Zentralverbands Oberflächentechnik e. V. (ZVO) zur Überprüfung des EU-Emissionshandelssystems (ETS-I) Im Rahmen der EU-Konsultation zur Reform des EU ETS & der Marktstabilitätsreserve (Ref. Ares(2025) – Initiative 14549) Stand: Juli 2025 Der Zentralverband Oberflächentechnik e. V. (ZVO) ist die Interessenvertretung der deutschen Galvano- und Oberflächentechnik.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Emission Trading System (ETS) has by and large worked well. In the areas where it has been introduced, it has put a cap on total greenhouse gas emissions, and provided a well-functioning pricing mechanism for efficiency within the limits of that cap. Holmen AB agrees with the submission in the public consultation from the SFIF Swedish Forestry Industries Federation.

Achieving carbon neutrality by 2050 requires drastically reducing CO2 emissions in all sectors, in particular those covered by the ETS. In this context, UFE advocates for an ambitious revision of the ETS framework to ensure that decarbonisation incentives are in line with the 2040 GHG emissions reduction target while providing predictability to the EU industry to unlock the necessary instruments.

ETS1 and ETS2 must be extended to agriculture to ensure effective carbon pricing in this sector (see "Position paper on future EU climate regulation architecture") ETS1 must be extended to cover the climate impact of wood-energy (see "Position paper on future EU climate regulation architecture") Fossil fuel inputs into the production of plastic and chemicals must be covered by ETS1 (See: "Position paper on future EU…

The UK Chamber of Shipping is the trade association for the UK shipping industry. Representing around 200 member companies involved in UK shipping, both domestically and internationally. The UK Chamber of Shipping (UKCS) welcomes this opportunity to provide input to the European Commission (EC) on this review of the EU ETS. Please find attached our replies and will be happy to elaborate them further.

ROQUETTE, a leading EU producer of excipients and food ingredients, appreciates the opportunity to contribute to this important consultation, as energy and carbon management are an integral part of the competitiveness of our operations.

In the opinion of the Ministry of Climate and Environment in Poland, the revision of the EU ETS should be used for the most comprehensive review possible as we are entering in the last period of the system functioning. The goal should be to prepare the most effective system. The key issues that should be discussed as part of the revision are attached.

The Japanese Shipowners' Association (JSA), representing 135 Japanese shipping companies, some of which are serving European ports, is pleased to submit our general comments regarding the EU Emissions Trading System (EU ETS).

ClassNK appreciates the opportunity provided by the European Commission to submit comments on the review of the EU ETS. As an international classification society, ClassNK is committed to ensuring the safety of ships and the protection of the marine environment.

Carbon must have its price, said many times the European Commissions President Ursula Von der Leyen. The gradual broadening of the EU ETS1 and the upcoming ETS2 are meant to implement this vision. Globally, about 30% of the excess CO2 added to the atmosphere by humans since 1850 has come from land use change, i.e. deforestation, forest degradation, agriculture etc. Using biogenic carbon is not climate neutral.

We would like to express our sincere appreciation for the opportunity to contribute to the European Commissions call for evidence of the impact. We welcome this important review process and are grateful for the chance to share our perspective.

Carbo Culture is a European climate technology company developing high-integrity carbon removal infrastructure based on Biochar Carbon Removal (BCR). Our proprietary pyrolysis technology converts waste biomass into stable biochar, permanently removing carbon from the atmosphere for centuries while enabling circular bioeconomy benefits.

The Royal Association of Netherlands Shipowners (KVNR) is the representative of Dutch-based shipowners active in the shipping industry with slightly 1500 ships. We are committed to a maritime climate in which shipowners worldwide can have prosperous business, use clean ships which sail safely with competent crews. Attached you find our feedback on the ETS consultation with a focus on shipping.

The Confederation of Swedish Enterprise fully support the European climate ambitions to achieve climate neutrality by 2050, and the intermediate targets set up within Fit-for-55. The Confederation of Swedish Enterprise further supports a continued high ambition for the net greenhouse gas emissions target for 2040 and firmly believe that cost-efficient carbon pricing should continue to be a main feature of the EUs…

CCU Alliance Input for the EU ETS Consultation The CCU Alliance welcomes the opportunity to provide feedback on the review of the EU Emissions Trading System (ETS). CCU technologies can play a vital role in achieving the EUs climate targets and accelerating the shift to a circular carbon economy.

Interferry is a shipping association representing the ferry industry world-wide. Regulation of international shipping should primarily be done under the auspices of the International Maritime Organization (IMO) and not on a national or regional basis.

Cepi welcomes the opportunity to contribute further to the 2026 review of the EU Emissions Trading System (ETS). The European pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050. As active participants in the ETS since its inception, we have already reduced our greenhouse gas emissions by over 50% compared to 2005 levels.

Review of the EU ETS for Aviation, Maritime Transport, Stationary Installations, and the Market Stability Reserve Introduction Assarmatori welcomes the opportunity to contribute to the European Commission’s public consultation on the EU Emissions Trading System (ETS) in view of its potential revision.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Emissions Trading System (ETS) or EU ETS (Emission Trading System) is a tool developed at European level to reduce greenhouse gas (GHG) emissions within the EU. The European Commission is currently examining various developments for 2028, including: — Inclusion of municipal waste dincineration units in the ETS; — If EVUs were included, the inclusion of storage, composting, methanisation and recycling…

Filed in French · English published by the European Commission

Dear Sirs, Lloyd’s Market Association’s response to: EU Emissions Trading System for Maritime, Aviation and Stationary Installations, and Market Stability Reserve Thank you for the opportunity to comment on this important part of the Commission’s work towards decarbonisation. Below are our views on the consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

KAN Climate Cure for Waste Incineration in Norway - is an industrial collaboration consisting of 9 waste incineration plants in Norway. KAN supports the inclusion of waste incineration in the EU Emissions Trading System (ETS), provided that greenhouse gas emissions from other waste treatment methods are also included.

Comments on revision to Emissions Trading Scheme Partnership for Policy Integrity July 7, 2025 Introduction ............................................................................................................................... 1 Section 1. Emissions from bioenergy must be included in the ETS ...........................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Liquid Wind is a leading developer of eFuel facilities currently developing five e-methanol production facilities, four in Sweden and one in Finland. Upon reaching FID, these projects will deliver 500,000 tons of RFNO-compliant e-methanol (2.5 TWh) annually.

The EU ETS should incentivise production from installations that partly reduce or fully eliminate greenhouse gas emissions and ensure equal treatment of installations in the same sector. However is very unlikely that the inclusion of MWI will contribute to reduce GhG, since MWI hasn´t the power to reduce the waste production in order to be able to reduce its activity, neither the quality of the recyclability of the…

Cascade Climate welcomes the opportunity to provide feedback on the European Commission's consultation on the revision of the EU ETS. As a philanthropy-backed climate non-profit focused on Enhanced Rock Weathering (ERW) and other underrepresented climate solutions, we believe this revision is critical to clarify the potential role of durable carbon dioxide removal (CDR) within the EU ETS while maintaining strong…

Shaping a Competitive and Sustainable Future for European Energy-Intensive Industries under the EU ETS Post-2030 July 2025 Contents 1 Executive Summary ........................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Port of Antwerp-Bruges (POAB) welcomes the opportunity to contribute to the European Commissions public consultation on the revision of the EU Emissions Trading System (EU ETS). Although POAB itself is not directly subject to ETS obligations, the port is a critical hub for industrial and logistical activities that are heavily impacted by the functioning of the EU ETS. Please find out feedback in the paper attached.

The Global South Carbon Dioxide Removal (GS CDR) Coalition welcomes the EUs continued climate leadership and supports the ambition of reducing net greenhouse gas emissions by 90% by 2040. Our Coalition includes leading carbon removal suppliers from the Global South working across durable, high-quality approaches such as biochar, enhanced weathering, and direct air carbon capture and storage.

Whilst with different cost-implications and impact across sectors, the ETS provided reasonable protection against carbon leakage. Thus, ensuring ETS liquidity and sustained carbon leakage mitigation, even after 2040, is crucial to improve the climate policy framework. Regarding the MSR's effectiveness, there is more mixed feedback, with the main suggestion being to eliminate the invalidation of allowances.

July 2025 Contribution to the Call for Evidence for the EU ETS Directive and MSR Decision Directive 2003/87/EC; Decision (EU) 2015/1814 We welcome the European Commission’s continued commitment to decarbonising the maritime sector. The extension of the ETS to maritime transport, effective from January 2024, represents a significant milestone in aligning the sector with the EU’s climate objectives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Opportunity Green welcomes the opportunity to provide input to the review of the emissions trading system and will focus on the revision of the aviation and maritime sectors in its submission. On aviation, Opportunity Green strongly supports the extension of the EU ETS to extra-EEA aviation, the inclusion of non-CO2 impacts, limiting zero-rating on all SAF and maintaining it exclusively for RFNBOs, and the…

The Dutch taskforce negative emissions started in 2022, we now bring together 40+ innovators, scale-up, established companies, NGOs, knowledge institutions and public-private carbon/CC(U)S partnerships in our shared aim to develop the policy, regulatory and market conditions for a mature direct carbon removals ecosystem in the Netherlands and the European Union.

As a cross-sector association with member companies operating in different industries and stages of the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to contribute to the consultation regarding the review of the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve. Our key messages are as following: 1.

ETFuels welcomes the European Commissions call for evidence and recognises the critical role that the EU Emissions Trading System (ETS) plays in Europes energy transition. As a developer of e-fuels projects in the United States, Spain, and Finland, we are directly exposed to the carbon price signals and regulatory frameworks that underpin investment decisions across the green fuel value chain.

RIESAME DELL’EU ETS PER IL TRASPORTO AEREO, IL TRASPORTO MARITTIMO E GLI IMPIANTI FISSI E DELLA RISERVA STABILIZZATRICE DEL MERCATO OSSERVAZIONI CONFINDUSTRIA Luglio 2025 Messaggi chiave • Effettuare un serio studio di impatto che parta dalle caratteristiche dei singoli settori industriali coinvolti ed esamini attentamente le conseguenze derivanti dal funzionamento di un sistema “cap and trade” destinato ad esaurire…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bioenergy Europe welcomes the opportunity to provide feedback to the EU ETS and MSR review. As a representative of the European bioenergy sector, we strongly support the EUs 2040 climate target and the transition to net-zero by 2050. We call for the inclusion of permanent carbon removals in the EU ETS, in line with the "like-for-like" principle.

Geachte lezer, Porthos is het eerste grootschalige CO2-transport en –opslagproject in de Europese Unie. Het ontwikkelt een project waarbij CO2 van de industrie in de Rotterdamse haven wordt getransporteerd en opgeslagen in uit-geproduceerde gasvelden onder de Noordzee. Het project is een samenwerking tussen drie overheidsbedrijven: EBN, Gasunie en het Havenbedrijf Rotterdam.

Filed in Dutch · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Include Insured CRCF Nature-Based Reforestation Units generated in the EU, in the EU ETS. Under the proposed scheme, each forestry-removal unit generated in the EU would be insured in kind with a replacement unit whose permanence is considered highersuch as one generated by direct air capture (DAC), bio-energy with carbon capture and storage (BECCS), or other permanent removals accepted under the EU ETS.

COFALEC, the Confederation of European Yeast Producers, welcomes the opportunity to contribute to the EUs review of the Emissions Trading System (ETS) and the Market Stability Reserve (MSR). As an energy-sensitive sector with both large and small industrial facilities, we are directly impacted by the EUs carbon pricing mechanisms.

It is necessary to extend the ETS to road and rail transport in order to avoid distortions in modal competition and the risk of a significant shift back to road freight transport. Ro-PAX vessels are among the most impacted by the ETS, and it is essential to extend exemptions to connections with major islands (e.g., SicilyItaly).

Waste-to-energy (Wte) is a key component of modern circular economy systems. It ensures the safe, hygienic and environmentally sound management of non-recyclable waste, while at the same time contributing to the supply of energy in the use of waste heat, in particular through the provision of electricity and district heating.

Filed in German · English published by the European Commission

Ensuring Regulatory Clarity for Industrial CCU SMA Mineral is advancing detailed plans to decarbonise quicklime production by building an electrified novel lime kiln at its facility in Mo i Rana, Norway, in partnership with SaltX Technology.

1. Member States should mandatorily allocate ETS funds to the modernisation of their power and heating sectors. 2. EU ETS funds should also be directed towards investments in the development of clean technology production capacity, including the construction of installation and service vessels and associated infrastructure.

Ragn-Sells welcomes the Commissions review of the EU ETS. The scheme is a vital instrument to facilitate Europes reduction of CO2 emissions. A broadening of the EU ETS to the waste management sector would, however, need to be done with consideration of the sector's ability to produce key raw materials. Such development must not impose new barriers that risk slowing down or even preventing the circular transition.

FuelsEurope welcomes the European Commissions consultation of stakeholders ahead of the review of the Market Stability Reserve and of some of the Emissions Trading Systems elements by 2026 and of the assessment of whether additional policies are needed to each the EUs climate targets.

FNADE is concerned to hear public statements emanating from some Commission officials that their services will advocate for the inclusion of municipal waste incineration (MWI) and landfill in the EU Emissions Trading System (EU ETS). Such statements are premature and are likely to undermine the legitimacy and credibility of the impact assessment work currently ongoing.

EU Transparency Register: 05032108616-26 Ref. Ares(2025)5519189 - 08/07/2025 7 July 2025 Shell1 plc welcomes the opportunity to respond to the Commission’s Call for Evidence on the EU Emissions Trading System (ETS) for maritime, aviation, and stationary installations and the market stability reserve. We believe that carbon pricing is a cornerstone of any comprehensive net-zero emissions policy framework.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Negative Emissions Platform welcomes the European Commissions public consultation and forthcoming impact assessment on the integration of permanent CDR into the EUs climate policy architecture. Key messages: 1. The case for integrating CDR into a compliance market: By 2050, we will need to be removing globally up to 10 gigatonnes a year of CO2 from the atmosphere if we want to be under the 1.5C pathway.

Iberdrola welcomes the ECs initiative to review the ETS as a key pillar of the European climate end energy targets and the Clean Industrial Deal. The ETS Directive has been very efficient in achieving its objectives in a cost-effective manner. Similarly, the MSR Decision has been very effective in addressing the structural surplus of allowances and improving the systems resilience to major shocks.

The World Shipping Council (WSC) recommends a structured and strategic alignment of the EU Emissions Trading System (EU ETS) with the forthcoming IMO Net Zero Framework. Alignment with global GHG pricing can help achieve EU climate objectives while avoiding the double burden of two GHG pricing systems for the same emissions.

The ETS review needs to balance environmental ambition with the necessary enabling conditions for decarbonisation investments (internationally competitive energy and raw materials, effective trade and carbon leakage measures, funding support, lead markets).

Novo Enviro is pleased to provide suggestions and recommendations for the revision of the EU ETS Directive. To achieve the EU's climate neutrality objective by 2050, it is crucial to foster a robust and diverse permanent carbon dioxide removal (CDR) sector. We strongly advocate for a technology-open approach when integrating CDR into the EU ETS.

BAV e.V.’s opinion on the inclusion of waste incineration plants in the EU Emissions Trading System (EU ETS) is critical of the planned inclusion of thermal waste treatment plants (TABs) in the EU ETS. In our view, there is no control effect in this area, as there are no alternative disposal routes for non-recoverable waste.

Filed in German · English published by the European Commission

The EU ETS effectively reduced emissions in its early phases, particularly in the energy sector and in sectors not exposed to carbon leakage. However, MOL Group does not believe the ETS in its current design will be able to further reduce emissions in hard-to-decarbonize sectors in a way that allows these industries to remain competitive at the same time.

The Enel Group believes the EU ETS has demonstrated to be a key and market-oriented component of the EUs energy transition, delivering real emissions reductions for the environment and important price signals for investments. In light of recent developments as well as reviews planned within existing legislation a number of regulatory changes are being explored.

EuroChem Antwerpen is grateful for the opportunity to provide feedback on the EU-ETS directive in light of its planned revision in 2026. EuroChem wants to take this opportunity to highlight the climate benefits (throughout the lifecycle of a product) of so-called substitution effects, in EuroChems case the substitution of mined natural limestone by synthetic lime (produced with industrially emitted CO2) for use as a…

MLIT (Japan) would like to appreciate for the opportunity to comment on the EU ETS public consultation for its review to reach the climate targets. EU-ETS in maritime sector needs to be reviewed urgently as the IMO Net-Zero Framework was approved at MEPC83 and will come into force in March 2027 if it is adopted at the upcoming meeting in October.

Position Paper: Review of the Proposed Extension of the EU Emissions Trading System The foremost objective of Austria’s municipal waste-management sector is to ensure that waste management remains outside the scope of the EU Emissions Trading System (EU ETS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EU Emissions Trading System (EU ETS) is a key instrument to reduce greenhouse gas emissions and aims to achieve climate neutrality by 2050. Under the Fit for 55 package, review clauses were added to ETS Directive 2003/87/EC. By 2026, consider possible adaptations for stationary installations, aviation and maritime transport, as well as an extension to new sectors such as waste management.

Filed in German · English published by the European Commission

The Shipyards & Maritime Equipment Association of Europe (SEA Europe) represents the maritime technology industry across 17 European countries. This includes the full spectrum of shipbuilding and maritime equipment manufacturingranging from the design, construction, maintenance, repair, retrofit, and conversion of all types of commercial and naval vessels, to the entire supply chain of maritime systems, equipment…

Subject: Call for evidence for an impact assessment - Ares(2025)3030455 The infrastructure and regulatory framework governing freight transport are key factors influencing the competitiveness and international outreach of Greek enterprises. Transport conditions and costs directly affect access to international markets.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Stellungnahme der MVV Energie AG zur Überprüfung des EUEmissionshandelssystems (EU-EHS) sowie der Marktstabilitätsreserve Art des Rechtsakts: Thema: Vorschlag für eine Richtlinie Klimaschutz Über die MVV Energie AG Mit über 6.600 Beschäftigten sowie einem Jahresumsatz von rund 7,2 Milliarden Euro im Geschäftsjahr 2024 ist MVV eines der führenden Energieunternehmen in Deutschland.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a leading European energy producer, CEZ Group has long supported the optimal setting of the EU ETS system, so that it provides predictable and, as far as possible, stable price signals for the entities covered.

Oggetto: Consultazione pubblica per la valutazione e la revisione dell’ETS1 e per la valutazione dell'Innovation Fund – Posizione Gruppo Grimaldi Introduzione Il trasporto marittimo è essenziale per il commercio internazionale delle merci ed allo stesso tempo rappresenta la modalità̀ di trasporto attualmente più̀ sostenibile; infatti, il 90% delle merci mondiali viaggiano via mare, contribuendo solo per circa il…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROPEAN COMMISSION’S CALL FOR EVIDENCE REGARDING THE EU ETS REVISION ARMATEURS DE FRANCE’S SUBMISSION July 2025 1/ INTRODUCTION Armateurs de France is the professional organization representing more than 60 French shipping companies, which operate across various segments, including passenger transport, freight shipping, energy supply, and specialized maritime services.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

July 04, 2025 Position Paper: Creating Lead Markets for Low-Carbon Products in Europe IFIEC Europe - July 2025 IFIEC welcomes the European Commission’s initiative to establish lead markets for low-carbon products as part of the Clean Industrial Deal (CID).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

LYB continues to support the European Green Deal including the EU climate targets. However, current economic conditions in conjunction with geopolitical challenges necessitate a revision of the strategy for delivering those targets, to preserve the EU industrial basis that will drive the EU decarbonization strategy. The transition to a low-carbon economy must go hand in hand with industrial competitiveness.

The Danish District Heating Association (DDHA) would like to thank the Commission for the opportunity to comment on the EU ETS post-2030 public consultation focusing on evaluation of the EU ETS and impact assessment of whether additional policies are needed in the EU ETS to reach the EU climate targets. Heating and cooling account for half of the EUs total energy consumption.

Resortecs strongly supports the inclusion of municipal waste incineration, hazardous waste incineration, and landfilling in the EU Emissions Trading System (EU ETS). These waste management routes generate significant greenhouse gas emissions but currently operate outside of the EUs carbon pricing framework.

Wiener Kommunal- Umweltschutzprojektgesellschaft mbH rejects the inclusion of waste incineration in the EU Emissions Trading System! Justification: *) Promoting landfilling that is harmful to the climate: More than 50 million tonnes (!) of mixed municipal waste are landfilled in the EU each year, i.e. 50 % of mixed municipal waste, untreated!

Filed in German · English published by the European Commission

Jernkontoret, the Swedish iron and steel producers association call for the following important steps regarding EU climate policy and specifically ETS. The details are further developed in the attached document. A long-term perspective and stability in climate policy are crucial. Conditions in terms of access to energy, permits, trade and economic conditions are absolutely crucial for investments to take place.

Towards appropriate and legally consistent proportionality in the accounting of biogenic CO2 capture under the EU ETS Annex to the questionnaire completed by the German Cement Works Association (Verein Deutscher Zementwerke, VDZ) for the ETS1 review of the European Commission.

The Chamber of Commerce Polish District Heating welcomes the opportunity to provide feedback as part of the review of the EU Emissions Trading System (EU ETS). Key messages: 1. Introduction of an EUA price corridor (with a floor price and a cap price) with dynamic regulation of the supply of allowances.

With regard to including smaller vessels into the ETS, we could also see that as a logical next step as long as the administrative burden is kept at the absolute minimum and a reliable mechanism is installed to ensure that they will also benefit from the ETS revenues. This would incentivize early movers and innovation.

essenscia, the Belgian federation of the chemical industry and life sciences sector, continues to support the goal of the Emissions Trading System as a policy tool to reduce emissions at the lowest cost to society. However some crucial changes to the ETS are needed to safeguard this goal and the competitiveness of the industry.

The City of Vienna rejects the inclusion of waste incineration in the EU Emissions Trading System! Justification: Promoting landfilling which is harmful to the climate: In the EU, more than 50 million tonnes (!) of mixed municipal waste are landfilled directly every year. In total, the EU Landfill Directive allows 12 EU Member States to landfill their mixed municipal waste directly until 2035.

Filed in German · English published by the European Commission

The Swedish Forest Industries Federation (SFIF) welcome the opportunity to contribute further to the 2026 review of the EU Emissions Trading System (ETS). The Swedish pulp and paper industry fully supports the EU objective to reach climate neutrality by 2050.

The inclusion of incinerators in the EU ETS, without complementary measures, will not in itself ensure a significant reduction in emissions. In order for this reduction to take place without causing unintended externalities, an integrated strategy is required to combine regulation, incentives and co-responsibility, including economic responsibility, by all actors involved in the waste value chain.

Filed in Spanish · English published by the European Commission

The Chambre Syndicale des Importateurs Français de Fruits et Légumes et Bananes (Chambre Syndicale des Importateurs Français de Fruits et Légumes et Bananes) (CSIF) brings together companies importing fresh fruit and vegetables, mainly from third countries.

Filed in French · English published by the European Commission

Ensuring that EU policy frameworks align to enable recycling of flexible packaging at scale is essential for the flexible packaging value chain The experience of CEFLEX--the Circular Economy for Flexible Packaging initiative--is that it is currently economically preferable to divert consumer flexible packaging waste to municipal incineration / waste-to-energy or landfill, instead of recycling The exclusion of…

The Carbon Capture and Storage Association (CCSA) is pleased to provide a response to the European Commissions consultation in the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve review.

Westenergy Ltd welcomes the European Commissions initiative and appreciates the opportunity to provide feedback on the Review of the EU Emissions Trading System (EU ETS). Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland.

ESPO welcomes the inclusion of maritime transport in the ETS as a necessary first step toward decarbonising the shipping sector. ESPO also recognises the important role of the European Commission in negotiating an ambitious global agreement within the framework of the IMO. Key considerations: 1.

The General Aviation Manufacturers Association (GAMA) thanks the European Commission for the opportunity to submit comments in response to the Call for Evidence for an Evaluation and Impact Assessment of the European Unions Emission Trading System Regulation. Please find our detailed feedback in the attached document.

HAROPA PORT, premier Port de France, remercie la Commission européenne pour l'opportunité d'exprimer ses priorités sur la révision du mécanisme de tarification carbone européen à venir. En pièce jointe, notre contribution en français et en anglais. Nous nous sommes concentrés sur la dimension maritime de l'EU-ETS.

We would ask you to take into account our opinion on the possible extension of the scope of the Directive to the incineration of municipal waste and other waste management operations (Chapter 5.8.1). We strongly oppose the inclusion of municipal waste incineration installations in the EU ETS!

Filed in German · English published by the European Commission

Wiener Stadtwerke-Positionierung zur Überprüfung des EU-Emissionshandelssystems (EU ETS) Für einen sektorspezifischen, zielgerichteten und klimaeffizienten Umgang mit Abfallemissionen 4. Juli 2025 1. Abfallsektor erfordert einen sektorweiten Ansatz für das EU ETS System Die energetische Verwertung von Abfällen ist Teil eines komplexen Systems.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the cornerstone of the EU climate architecture, the ETS is an essential tool to reach EU climate targets and internalise the climate costs of emitting GHG. To meet the EUs 2040 climate targets and ensure a fair, effective decarbonisation of the shipping sector, the EU Emissions Trading System (ETS) must be preserved and strengthened alongside other policy measures.

Our feedback to the European Commission outlines strategic steps to modernize the EU Emissions Trading System (ETS) through digital innovation, ensuring it becomes a globally integrated, data-driven carbon market.

The ETS1 regulation creates distortion in the application of the criteria for offshore vessels with a tonnage slightly above 400 GT and it is necessary to support the path of shipowners to improve their carbon footprint with tools that are adequately accessible even by non-complex organizations.

Estonian Renewable Energy Association supports the EU ETS as an effective tool for achieving climate neutrality and the renewable energy transition. We thank the Commission for the opportunity to give feedback and propose the following. We support the development and implementation of bioenergy carbon capture and storage (BECCS) technologies and the inclusion of the subsequent carbon removals in the ETS.

JULY 2025 Designing an EU ETS post-2030 framework is urgent to restore a business case for sustainable flat glass manufacturing in Europe The European flat glass sector is key to achieving the EU’s decarbonisation goals and the recently proposed target of a 90% reduction in GHG by 2040 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear DG CLIMA team, SkyNRG appreciates the opportunity to contribute to the consultation on the revision of the EU ETS for aviation. As a leading developer of Sustainable Aviation Fuel (SAF) projects in Europe, we see the ETS as a vital tool to unlock investment in SAF, particularly e-SAF, and accelerate the sectors decarbonisation.

Shaping a Competitive and Sustainable Future for European Energy-Intensive Industries under the EU ETS Post-2030 July 2025 Contents 1 Executive Summary ........................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This feedback and the position paper attached provide a stocktaking of measures supported by Eurometaux in view of the Commissions preparatory work for the EU ETS review proposal. Eurometaux represents European producers of Non-Ferrous Metals like Aluminium, Copper, Lithium, Nickel, Zinc, Silicon, but also ferro-alloys, among other energy transition metals.

The EU ETS carbon price supports the investment signal for the power sector to lower its consumption of fossil fuels and switch to renewable energy sources, but thats not the case for industrial stationary installation: the continued allocation of free emission allowances has contributed to the limited decarbonisation of steel, cement and chemicals sectors, which remain the major sources of EU industrial CO2…

Stora Enso welcomes the opportunity to provide feedback on the forthcoming EU ETS Review. Our points relate primarily to the inclusion of MWI in the EU ETS to create a level playing field, and to consider alternatives to the EU ETS regarding the regulation of negative emissions. We also make suggestions for simplification regarding stationary installations. Please see the attached position paper for more detail.

Shaping a Competitive and Sustainable Future for European Energy-Intensive Industries under the EU ETS Post-2030 July 2025 Contents 1 Executive Summary ........................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Review of the Emissions Trading System: EUROFER paper • • • • • • • KEY MESSAGES The ETS review needs to balance environmental ambition with the necessary enabling conditions for decarbonisation investments (internationally competitive energy and raw materials, effective trade and carbon leakage measures, funding support, lead markets).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Public consultation for the evaluation and revision of ETS1 and for the evaluation of the Innovation Fund. CONFITARMA POSITION 1. Preamble. Maritime transport accounts for over 90% of world trade by volume, contributing only around 2.5% of global greenhouse gas emissions, and of these emissions only 7.5% in European waters.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The ETS mechanism has a financial impact on all traffic passing through the ports of the French Antilles, in some cases amounting to the full cost of a port call. As a result, this additional costtypically passed on by shipping companies to the end customeradds to the inflation already affecting these territories.

For decades, SUEZ has been playing a key role in converting waste in energy in Europe. SUEZ currently manages a third of Waste-to-Energy (WtE) installations across the French territory and produces each year 950 GWh of electricity and 2100 GWh of heat from waste incineration.

- While recognizing the necessity to pace and scale-up existing and new technologies such as carbon removals and carbon capture, and the consequential need for both public and private support, we do support the inclusion of permanent (industrial) removals in the ETS1, but not the inclusion of CRCF credits from carbon farming into the ETS 1.

We would like to thank the European Commission for the opportunity to contribute to this important consultation process. The Port of Algeciras fully supports the European Green Deal objectives and remains firmly committed to the European Unions ambitious decarbonisation agenda.

CCU (Carbon Capture and Utilisation) is crucial for growing fruit, vegetables, flowers and plants in Europe as it provides a sustainable way of supplying CO to greenhouses, which is essential for plant growth. Instead of obtaining CO from fossil energy, CCU CO can be captured from industrial processes and reused in the greenhouse.

Filed in Dutch · English published by the European Commission

Avenida Francisco Dirección La Roche, completa n.º 35A –|Edif. CP 00000 Servicios Santa Múltiples Cruz deI,Tenerife plta.9 | CP | Tfno: 38071 922 Santa 00 00 Cruz 00 de - Fax: Tenerife 922 000 | Tfno: 000 922 92 48 92 C/ Profesor Agustín Millares Dirección Carló, n.º completa 22 - Edif.BServicios | CP 00000 Múltiples Las Palmas I, plta.9 de|Gran CP 35071 CanariaLas| Palmas Tfno: 928 de Gran 00 00Canaria 00 - Fax: |…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The inclusion of thermal waste treatment plants in the EU ETS from 2028 onwards is rejected as regulatory disincentives, to the detriment of the implementation of the waste hierarchy, to avoid energy supply and heat transition; a differentiated approach is necessary. Isolated exposure to thermal waste treatment plants would undermine the waste hierarchy and shift flows towards landfilling.

Filed in German · English published by the European Commission

Opinion of the FGW on the public consultation of the EU Emissions Trading System (maritime, aviation and stationary installations) and the Market Stability Reserve – Call for evidence on why energy recovery is in line with existing EU legislation and initiatives and is an indispensable part of the energy, waste and circular economy: Compliance with the waste hierarchy shall be based on all considerations. 1.

Filed in German · English published by the European Commission

Dear Members of the European Commission, please find attached our Feedback on the Call for Evidence for the ETS-Reform as well as our key points below. A successful industrial transition toward climate neutrality depends on establishing the specific framework conditions, especially planning reliability by setting up a political framework allowing for business cases to enable companies to invest in long-term, low…

CIN - Compagnia Italiana di Navigazione welcomes the opportunity to contribute to the European Commissions public consultation on the EU Emissions Trading System (ETS) in view of its potential revision. We consider this consultation a timely and significant opportunity not only to assess the effectiveness of the Directive to date, but also to lay the groundwork for possible improvements that could make the system…

There is a clear commitment by the Austrian Waste Management Associations (Arge AWV) to the objectives of Fit for 55, and the waste and circular economy is already making a significant contribution to climate objectives, as recycling of waste achieves significant emission savings compared to primary production.

Filed in German · English published by the European Commission

Summary of KIGOs position: KIGO opposes the inclusion of municipal waste incineration with energy recovery into the EU ETS since it undermines the EUs transition to a circular economy. However, if municipal waste incineration with energy recovery is covered by the EU ETS it should come within the scope of the system alongside other waste management processes, in particular landfilling.

ADAC e.V. is a non-economic association which sees its primary role in promoting and maintaining the mobility of its members. Help, advice and protection after breakdown, accident and illness describe the core of the activities. ADAC has shown a high level of commitment to transport safety and education.

Filed in German · English published by the European Commission

Proposals for revision of the EU ETS Directive – CZ 1) Regulation mechanisms in EU ETS 1 and EU ETS 2 Regulation mechanisms in EU ETS should be set up in such a way that they are functional when needed, but at the same time allowing market to do its job and do not reduce the overall climate ambition and goal of the system, i.e.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The foremost objective of Austrias municipal waste-management sector is to ensure that waste management remains outside the scope of the EU Emissions Trading System (EU ETS). A balanced and socially acceptable regulatory framework can be achieved only through a package of instruments combining a landfill tax, eco-modulation within extended producer-responsibility (EPR) schemes, and dedicated funding for carbon…

Finnish Marine Industries position for EU ETS: EU ETS should be evaluated from the view of a competitive, sustainable and efficient European waterborne transport and ensure coherence between the IMO Net Zero Framework and the FuelEU Maritime Regulation. EU ETS should be extended to cover emissions from smaller ships (i.e. between 400 GT and 5.000 GT).

As Krakowski Holding Komunalny SA, we strongly oppose the inclusion of Waste-to-Energy (WtE) facilities in the EU ETS 1. In our view, the current ETS system is not the right tool to reduce GHG emissions in the waste sector. Only a thorough structural reform could make it effective for this purpose. WtE plays a vital role in treating non-recyclable waste and provides an essential public service.

Comments from Tekniska verken i Linköping AB regarding the consultation on the EU Emissions Trading System for maritime, aviation and stationary installations, and the Market Stability Reserve Tekniska verken i Linköping AB hereby submits the following comments in response to the consultation on the EU Emissions Trading System (EU ETS) for maritime, aviation and stationary installations, and the Market Stability…

In considering the possible inclusion of permanent CDR into ETS, Carbfix feels it is important that the Commission also considers including another category of climate mitigation that may have been overlooked in this context, namely capture and storage (CCS) of CO2 emissions from industrial installations not covered by ETS.

3. 7. 2025 EUROPEAN COMMISSION CALL FOR EVIDENCE EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve – review FEEDBACK PERIOD: 15 April 2025 – 8 July 2025 HSE GROUP’S CONTRIBUTION DATE: 3 JULY 2025 HSE Group appreciates the opportunity to share its perspectives on the revision of the ETS Directive and the Market Stability Reserve decision.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Kanadevia Inova firmly asserts that the EU ETS is not an appropriate or effective mechanism for decarbonizing the waste sector. Furthermore, including the waste sector in the ETS would jeopardize Europe's crucial sustainable and circular economy goals.

The Austrian Association of Municipalities rejects the inclusion of municipal waste incineration plants in the emissions trading scheme. This would have to lead to a significant increase in charges for households, although at the end of the waste hierarchy there is always a need for proper and environmentally sound disposal. Modern waste incineration plants must in any case be given priority over landfilling.

Filed in German · English published by the European Commission

It is a feedback on EU ETS directive by the National Centre for Emission Management (KOBiZE, Poland). It is widely observed by various stakeholders that policy instruments currently in place are unlikely to deliver the Unions emission reduction targets on their own, without any flexibilities.

Vantaan Energia, Finland's largest Waste-to-Energy centre, specialising in the thermal treatment of non-recyclable waste and the recovery of waste heat for district heating and electricity production, thanks the European Commission for this opportunity to contribute feedback on the Review of the EU Emissions Trading System (EU ETS).

The position of Finnish shipping companies on the review of the EU ETS and shipping is a representative of 23 foreign shipping companies transporting around 30 % of Finland’s foreign trade tonnes. Shipping is critical for Finland, as more than 95 % of foreign trade is carried by sea, and geographical location and winter conditions pose particular challenges.

Filed in Finnish · English published by the European Commission

Summary of the Norwegian Coastal Shipowners consultation response on the review of the EU ETS and related climate regulations The Norwegian Coastal Shipowners, representing over 230 shipping companies with nearly 10,000 seafarers, support the EUs ambition to reduce greenhouse gas emissions from shipping.

Belgian waste-to-energy (BW2E) represents all Belgian installations that valorise household and comparable residual waste energy. Each year, the 14 members process 2.75 million tonnes of residual waste and produce more than 1.5 million MWh of electricity that is partially renewable. In addition, BW2E is increasingly deploying heat and steam to residential and industrial heat networks. 1.

Filed in Dutch · English published by the European Commission

Celanese is a global chemical and specialty materials company with over 11,000 employees worldwide and a strong European presence, including manufacturing sites in Germany, Belgium, the Netherlands, Italy, and more. Our engineered materials are used in critical industrial and consumer applications from automotive and construction to electronics and healthcare.

One of the main objectives of the EU-ETS is to promote the reduction of greenhouse gas emissions in a cost-effective and economically efficient manner. The review object of this consultation is a great opportunity to consider and incentivize the uptake of clean carbon feedstock, including recycled plastic waste.

SGI Europe, representing employers of public services and services of general interest, expresses strong opposition to the potential inclusion of Municipal Waste Incineration (MWI) under the EU Emissions Trading System (ETS 1).

We support the Commissions ambition to reform the EU ETS as a key driver of Europes decarbonisation, and we welcome the opportunity to contribute to this consultation. In particular, we are committed to providing constructive input on the potential inclusion of waste-to-energy in the ETS. The EU ETS has proven to be an effective tool in driving shifts towards cleaner technologies, through market-based signals.

It is important to include Biochar carbon removal (BCR) on par wtih BECCS and DACS in the ETS scheme. BCR is by far the most mature CDR method and significantly cheaper than DACS per ton of CO2e removed. Biochar removal has been demonstrated to be permanent when the carbon has a random reflectance > 1,5 and and the carbon has turned into inertinite or semi-inertinite.

EDF group is pleased to contribute to the ETS review consultation and to share its feedback. Please find enclosed our feedback document. In a nutshell, we particularly welcome the upcoming ETS Review (EU ETS 1) as a key opportunity to strengthen the framework for an EU Emissions Trading System that supports a competitive and effective decarbonization pathway at the EU level, in line with the goal of climate…

IDM facilities fulfil a public health mission and cannot select the nature of incoming waste, thereby reducing their ability to reduce their GHG emissions. It results from the fossil share of waste, and the environmental cost is to be borne by the producer as a matter of priority.

Filed in French · English published by the European Commission

Carbon Gap welcomes the opportunity to provide feedback on the European Commissions consultation on the revision of the EU ETS 1. As an organisation dedicated to responsibly scaling carbon dioxide removal (CDR) in Europe and advancing effective climate policy, we believe this revision will be critical to clarify the potential role of permanent CDR within the EU ETS, maintaining a strong alignment with the EUs…

The European Commission is preparing proposals to amend the Emissions Trading Directive. It gives the opportunity to comment on the review of the EU Emissions Trading System (ETS, here ETS 1: Maritime, aviation and fixed installations).

Filed in German · English published by the European Commission

Call for evidence & public consultation EU ETS Input Natuur & Milieu Dutch NGO Natuur & Milieu welcomes the opportunity to provide input for the review of the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve. Our input focusses on four subjects: aviation emissions, carbon leakage, carbon removals and nonpermanent carbon capture and use.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

TIC Council represents the independent verifiers in the EU ETS. Since the beginning of EU ETS 20 years ago, many of our members have been accredited to the different scopes of the system. The services of validation and verification of emissions that the TIC industry delivers are essential to ensure the robustness of the EU ETS and the comparability of the reported data.

The European fertilizer industry is under mounting pressure from non-EU producers that benefit from lower environmental standards, subsidized energy, and cheaper raw materials. To ensure a genuine level playing field and defend Europes strategic industrial base, the Carbon Border Adjustment Mechanism (CBAM) must be urgently and comprehensively reinforced.

Observations of the Czech Republic on the Market Stability Reserve: In order to further calm the price of the allowance, it is necessary to adjust the current functioning of the Market Stability Reserve (MSR). At present, the MSR only operates unilaterally – constantly withdrawing allowances from the market and thus triggering an increase in their price.

Filed in Czech · English published by the European Commission

Recommendation for the impact assessment regarding municipal waste incineration and other waste treatments Sirk Norge recommends that the EU ETS includes several waste treatments simultaneously, to ensure equal pricing conditions up to and included the highest included treatment level in the waste hierarchy: 1) incineration* (with and without utilization of energy) 2) landfilling** 3) waste water treatment and…

As soon as IMO mid term GHG will enter in force, both FuelEU and EU ETS should disappears for international shipping. International shipping through IMO has been the first ONU agency to adopt a policy stricter than the EU regional one and it should not be penalized with "double charges/invoices" but the contrary.

Polish position on ETS reform It is a common truth that ETS is a major solution to drive decarbonization in the EU in sectors covered by it. It has proven to be effective in mobilizing the power production industry to invest in lower emission assets, mainly renewables.

EU ETS Consultation Feedback Submission by tgo AG Proposal: Integrating Temporary Carbon Removals via Time Carbon Credit (TCC) Why we are submitting this feedback: We believe that temporary carbon removals from land such as soil carbon storage and agroforestry deserve clear recognition in the EU ETS. These solutions are fast, affordable, and backed by science.

Incorporating permanent CDR into the EU ETS is critical to achieving net-zero by 2025. To succeed, this integration must unlock large-scale private financing, establish a predictable market for removals, and maintain technology neutrality to support a diverse portfolio of CRCF-certified, permanent CDR. BCR is delivering climate impact already.

We encourage the Commission to ensure full inclusion of municipal waste incineration under the EU ETS with the following considerations: (1) Both power and heat from MWI should be covered without free allowances, aligning with ETS coverage of the buildings sector in 2027.

Waste Incineration must be included in the EU ETS. as shown in the recent study by the Zero Waste Europe/ Reloop and CE Delft - such an includion at the EU level would benefit the citizens though better recycling, waste prevention measures, more jobs created and less GHG emissions. These findings must serve as a wake-up call for the European decision-makers currently under heavy pressure from the incineration lobby.

Introduction Childrens Rights Over Flights is a campaign by parents, grandparents, and other concerned people, calling for children's rights in the context of the climate emergency to be prioritised over aviation growth. We are volunteers who have come together due to our huge concern on this issue, and have worked together as a group on this submission.

The tomato processing industry call for a critical review of the ETS and CBAM The ongoing discussions at the European level have yet to adequately consider the potential impacts that ETS and CBAM policies could have on the primary food processing sector, particularly one as export-driven and closely tied to its agricultural supply chain as the tomato processing industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NRDC (Natural Resources Defense Council) is a North American NGO concerned about the EU’s use of woody biomass for energy. We believe the large-scale use of forest biomass for energy should be ended, since it cannot be achieved without harm to climate, forests and biodiversity. Some EU Member States import several million tonnes of woody biomass from North America every year for use in its energy sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The inclusion of municipal waste energy recovery units (which you call an incinerator) in the EUTS could be a prima facie appealing idea, as these plants inevitably discharge CO2 from the combustion of non-recyclable waste from manufactured products, consumed and ultimately disposed of by people.

Filed in French · English published by the European Commission

Criticism of the EU emissions trading system Risk of carbon leakage: The industry sees a risk that rising CO costs will lead to production and investment being relocated to non-European countries where less stringent climate protection requirements apply. This shift threatens the competitiveness of European companies and could lead to a net increase in global emissions.

We encourage the Commission to ensure full inclusion of municipal waste incineration under the EU ETS with the following considerations: (1) Both power and heat from MWI should be covered without free allowances, aligning with ETS coverage of the buildings sector in 2027.

The ODV Forumenvironmentalist Association supports the full inclusion of municipal waste incineration plants and all installations * burning biomass in the EU ETS. Inclusion has no impact on carbon leakage and would encourage technological innovation, the reduction of imports of virgin raw materials and the ecological footprint of their extraction, which often takes place in countries where environmental standards…

Filed in Italian · English published by the European Commission

In order to manage and solve the climate problem in the most cost effective way possible it is important to maintain solution-neutral incentives for all viable and verifiable methods to be treated equally. In our case, we are developing a biological way to increase the photosynthetic uptake of CO2 from the ocean surface water.

To meet the EUs climate neutrality objective and transition to net-negative emissions after 2050, it is essential to scale a permanent carbon dioxide removal (CDR) sector that includes a diverse portfolio of high-integrity solutions. The EU Emissions Trading Scheme (ETS) is one of the most powerful tools at our disposal to achieve that.

Spanish company Carbon Fields on Earth SL develops, builds and exploits plants that transform biomass waste into organic soil improvers and bioproducts. Carbon Fields is formulating a soil amendment, Nutrichar, from 2 biowaste streams, biochar and digestates/compost, obtained from pyrolysis and anaerobic digestion/composting.

FEEDBACK PAPER Ref. Ares(2025)4841539 - 18/06/2025 Datum 2025-06-18 Swedenergy feedback Call for evidence for an impact assessment of review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve Swedenergy collects and gives voice to around 400 companies that produce, distribute, sell and store energy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BASF supports the goal of a climate-neutral Europe by 2050 and is actively committed to climate-neutral production. We aim to actively and responsibly shape this transition towards a climate-neutral society and aspire to become the preferred supporter of decarbonization in our customer industries.

NG Nordics key messages: NG Nordic supports the full inclusion of municipal waste incineration installations in the EU ETS. The inclusion would both incentivize decarbonizing Waste-to-Energy (WtE) sector and boost recycling. Hazardous waste incineration should remain out of scope of the ETS Directive, as its primary function is not energy production but safe destruction of harmful substances.

VVSG does not see the added value of including the incineration of municipal waste under the ETS. Placing the incineration of municipal waste under the EU ETS would have a strong cost-increasing effect on the incineration of the residual household waste of all Flemish municipalities, while the effectiveness of this policy measure has not been proven.

Filed in Dutch · English published by the European Commission

A legally binding target of net zero greenhouse gas emissions at the latest by 2050, and an intermediate target of reducing net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels. We mean that our company have the best solution to all this.

Carnival Corp. expresses thanks for the opportunity to contribute to the EU Call for Evidence and for the Public Consultation on the ETS Directive. In addition to the input provided to the Public Consultation questionnaire, Costa, Aida Cruises and Carnival Corp.

EU ETS system in maritime transport. At present there are not and will not be in the coming years widely commercially available zero-emission drives or radically reducing ship emissions, that could be immediately used on vessels. At the moment, there are technologies available on the market, that reduce CO2 emissions only to a certain extent.

1. Extension of entities included: we support the extension of entities including 2. Introduction of new measures to reduce the risk of carbon leakage: we support the adoption of new measures 3. Inclusion in the ETS of permanent removals of captured and stored CO2 underground: we support the inclusion of any technology that can bring a benefit in terms of atmospheric CO2 reduction 4.

Filed in Italian · English published by the European Commission

Specific Feedback on Key Points: 1. Emissions from Aviation and Maritime Sectors: We support the EU's efforts to encourage a global carbon pricing system through the ICAO and the IMO. H2SITE's technology can play a crucial role in reducing emissions from maritime transport by enabling the use of clean hydrogen as a fuel source. 2.