EU emissions trading system - update of Activity Level Changes Regulation

Monitoring and Reporting Complexity The new rules defined in article 5 and annex I add considerable complexity in terms of monitoring and reporting. For installations with heat BM and/or fuel BM sub-installation with several products (under the same PRODCOM code or not), but with differing energy intensities per product the changes proposed could lead to significant administrative burden and substantial additional…

Summary: We commend the proposed reform of the Activity Level Change Regulation (ALCR) as it is key for promoting climate-friendly and competitive production of critical raw materials such as silicon, manganese, and other ferroalloys.

Euroheat & Power welcomes the opportunity to provide feedback on the draft Commission Implementing Regulation amending Implementing Regulation (EU) 2019/1842 regarding adjustments to the free allocation of emission allowances due to activity level changes (the "draft ALCR"). We value the Commission's efforts to enhance clarity and coherence following the EU ETS revision.

ATEDY Position on the European Commission (EC) public consultation on emissions trading system (ETS) update of Activity Level Changes Regulation We would like to use this opportunity to highlight the challenging situation for Historical activity level for new entrants in emission trading system that have been included in 2024.

As TomatoEurope, the European federation of tomato processors, we think it is indicated to use the expected activity levels as proposed to calculate the variation of activity levels for the dynamic adjustment of allowances.

The Federation of Icelandic Industries (the Federation) celebrates the amendments proposed to the Activity Level Changes Regulation. The Federation represents the ferroalloys and silicon industry in Iceland as well as other sectors.

CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

The EU ETS implementation rules are becoming more challenging and complex with every revision of the directive. One example is the CO2 that is not emitted, and which is now part of the EU ETS coverage and needs to be reported on. Similarly, smaller emissions that are allocated for free on basis of a high benchmark that is covering products that have never been part of the carbon leakage assessment.

The European ferroalloys and silicon sector represented by Euroalliages is 100 % process emission and fully electrified. The sector is committed to find viable and sustainable solutions to further reduce CO2 emissions even though the production process has reached physical limits in terms of process CO2 emissions.

This answer provides the position of the non-ferrous metals industry on the draft text of the revised Commission Implementing Regulation (EU) 2019/1842 as regards further arrangements for the adjustments to free allocation of emission allowances due to activity level changes (ALC Regulation) (see pdf attached).

EU Emissions Trading System, update of Activity Level Changes (ALC) Regulation. Response on public consultation of the ALC Regulation from Finnfjord. Finnfjord AS is a Norwegian family-owned company specializing in the production of ferrosilicon, a key material used in the steel and aluminum industries.

The VCI would like to express its gratitude for the opportunity to comment on the draft revised version of the ALC Regulation as part of the stakeholder consultation. — Article 6(1) has been deleted from the draft regulation.

Filed in German · English published by the European Commission

We suggest that the concept of average expected activity level and the associated changes in the Annex (which is now Annex I) and in Article 5 should not be added to the ALCR. This new rule seems not be legally mandated but adds considerable complexity.

Position of PGE Polska Grupa Energetyczna S.A. on the draft Commission Implemented Regulation (EU) amending the Activity Level Changes Regulation PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide feedback on the draft Commission Implemented Regulation amending and correcting Implementing Regulation (EU) 2019/1842 laying down rules for the application of Directive 2003/87/EC of…

PTEC is pleased to provide the following response on the draft Commission Implemented Regulation amending and correcting Implementing Regulation (EU) 2019/1842 laying down rules for the application of Directive 2003/87/EC of the European Parliament and of the Council as regards further arrangements for the adjustments to free allocation of emission allowances due to activity level changes (draft ALCR). 1.

In our opinion, the amendments introduced in the ALC regulation concerning the additional allocation of allowances for district heating (Article 3d) are beneficial for the sector. The flexible system of allocating additional allowances, which takes into account both annual allocation during the implementation of investments that are expected to lead to significant emission reductions, as well as the possibility of…

ECOS welcomes the opportunity given by the European Commission to provide input on the EU Emission Trading System (ETS) update of the Activity Level Changes Regulation (ALCR). In principle, we support the rational of the proposed changes as they contribute to the objectives of the ALCR.

The European Union is hard working to produce legislations and policies to achieve the ambitious targets laid out in the Green Deal, and in particular, regarding both decarbonisation and plastic recycling, with the aim of Substituting more feasible fossil materials.

Filed in Italian · English published by the European Commission