Monitoring, reporting and verification of greenhouse gas emissions from maritime transport

EU ETS - feedback from Holocenic Holocenic is a Swedish management consulting company working in the energy and transportation sectors towards a green transition. Our mission is to reduce global warming. Holocenic welcomes the proposal to add shipping to the EU ETS because it will be an effective instrument to incentivize emission reduction. However, we have a few remarks below.

The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector. Under the EU plan, shipping is set to be added to EU’s ETS gradually from 2023 and phased in over a three-year period.

ZOE Institute for Future-fit Economies welcomes the opportunity for feedback on updating the EU Emissions Trading System (ETS). We strongly support initiatives which aim to change behaviour and curb unsustainable lifestyles in an equitable way in the mobility and housing sectors.

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised.

The Global Alliance Powerfuels welcomes the revision of the EU Emissions Trading System Directive and endorses the European Commission’s goal to enable Member States to fulfil the EU's climate objectives of the European Green Deal in a cost-effective way by strengthening the scale and scope of carbon pricing in the EU. Please find attached our detailed feedback.

Dear Commission, We would like to fully support the comments and their justification expressed by Eurofer in its position document (attached). While we are aware of the need to increase the EU ETS goal to reach the 55% emission reduction in the EU, we cannot accept that instead of strengthening carbon leakage protection adequatelly to the higher EU climate ambitions, the COM proposals would lead to the opposite…

COGEN Europe welcomes the publication of Fit for 55 package and its objective to accelerate the cost-effective decarbonisation of our economies for all consumers. The Fit for 55 climate proposals, namely the original EU ETS revision (ETS I), the new ETS for buildings and transport (ETS II) and the Effort Sharing Regulation Revision (ESR), formally add up to delivering the required ambition.

Puertos del Estado shares the urgent need for the reduction of emissions from the maritime transport, and fully support the implementation of market based measured like the extension of the EU ETS to the maritime sector. That said, we would like to express our concern about the impact of this measure on maritime transit traffic (“transhipment”). On that sense, the following aspects need to be considered.

Puertos del Estado shares the urgent need for the reduction of emissions from the maritime transport, and fully support the implementation of market based measured like the extension of the EU ETS to the maritime sector. That said, we would like to express our concern about the impact of this measure on maritime transit traffic (“transhipment”). On that sense, the following aspects need to be considered.

NHO supports the EU's climate ambitions for 2030 and 2050 and we welcome the EU Fit for 55-package, which will be essential for achieving both climate goals and green growth. We appreciate the opportunity to comment on the revision of ETS. ETS is a core framework for ensuring both cost-efficient emission reductions, incentives for businesses and a transparent and harmonized climate policy across Europe.

In short below and for details please find enclosed EDF(Electricité de France)'s contribution EDF welcomes the ambitious revision of the EU-ETS to align it with the new 2030 target. A meaningful carbon price will drive cost-effective energy transition by promoting investments in renewable and low-carbon technologies.

Naturgy welcomes the opportunity to submit feedback to the European Commission's proposal to update the EU Emissions Trading System (ETS). The main takeaways of our response focus on the proposed establishment of an adjacent EU ETS for buildings and road transport: - An ETS for buildings and transport would not achieve its decarbonization goals since the price signals would be insufficient and volatile.

The Dutch Platform Renewable Fuels welcomes the extension of the ETS to include road transport and the maritime sector. It provides a clear path towards a net zero, climate neutral 2050. In particular we support the proposed reduction path that sets an inevitable over years decreasing ceiling for the deployment of fossil fuels.

The European Public Health Alliance (EPHA) welcomes the opportunity to provide feedback on the proposed extension of the EU Emissions Trading System (EU ETS) scheme to the transport and building (heating) sectors. The transport and buildings sectors are two massive contributors to both air pollution and greenhouse gas emissions in the EU.

PGE Polska Grupa Energetyczna S.A. welcomes the revision of the Directive of the European Parliament and of the Council on establishing a system for greenhouse gas emission allowance trading within the Union as an opportunity to ensure just transition and help the European Union in reaching its climate targets in the most cost-efficient way.

Solvay has set itself an objective of carbon neutrality in 2040/2050 and we need an Emission trading System ( ETS) allowing us to succeed in our endeavor. The EU is leading the climate transition in the world and the ETS Directive is the essential tool for keeping at the same time our international competitiveness.

Recognized as Europe’s most sustainable airline (2021 World Finance Sustainability award winner; named the Greenest airline in Europe by JP Morgan), Wizz Air supports the implementation of the European Green Deal and the achievement of the 55% CO2 reduction outlined there.

Future electricity agrees with the revision of the EU ETS Directive, which is essential to ensure its central role in European climate policies and to provide stable and predictable signals on the price of emission allowances. Given the broad scope of the reform, it is crucial to assess its impacts in terms of sustainability, competitiveness and social fairness.

Filed in Italian · English published by the European Commission

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Statkraft input to the public consultation for the updating of the EU Emissions Trading System Introduction Statkraft is Europe’s largest provider of renewable energy. We have for long been a vocal supporter of a strong EU Emissions Trading System (ETS) as the most efficient tool for driving the transition of the European energy system in a technology neutral and marked-based manner.

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint.

Dear Sir/Madam, APQuímica, the Portuguese Petrochemical and Refination Association, presents in the attached document its comments and contributions as part of the “Fit for 55” legislative package, and in particular with regard to the proposed revision of the ETS/ETS Directive.

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Immediate social concerns and unclear climate benefits Environmental Action Germany (DUH) welcomes pricing in climate damage costs in the transport and building sectors, where emissions reductions are slow at best. We are concerned, however, that the introduction of a new emissions trading system is not the right instrument.

We welcome the opportunity to comment on the Commission proposal to revise thoroughly the European Emission Trading System. The European ambition of -55% of CO2 emissions by 2030 and carbon neutrality by 2050 requires a strong and efficient system.

Gas Infrastructure Europe (GIE), representing almost 70 European companies operating storage facilities, transmission pipelines and LNG terminals, welcomes the European Commission’s initiative to revise the EU Emission Trading System (EU ETS).

E.ON welcomes the revision of the EU Emissions Trading System to strengthen the carbon price and a second mechanism for transport and buildings. Robust carbon pricing is the foundation of cost-effective decarbonization solutions needed to deliver on Europe’s energy and climate targets.

Key messages: (1) Air Liquide supports ETS’ focus on clean technologies, such as renewable and low-carbon Hydrogen; (2) Europe should maintain CO2 price levels high enough with foreseeable price signals for carbon over the long-term; (3) We welcome the clarification regarding the eligibility of CO2 transport for the purposes of CCS by ships, trucks, etc. (i.e.

Ambitious climate targets dramatically increase the demand for metals and minerals for climate technologies. Good conditions for the European metal and mineral industry could increase the EU's self-sufficiency of sustainable metals and minerals, and reduce dependence on unsustainably sourced metals and minerals from geopolitically unstable countries.

EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of District Heating and Cooling (DHC) networks.

The European Expanded Clay Association (EXCA) welcomes the opportunity to provide feedback on the legislative Proposal for the revision of the EU ETS Directive. EXCA represents the major expanded clay producers throughout Europe. Expanded clay is a natural, light and durable material, widely used in construction and as a growing media all over Europe. EXCA represents 90% of the European expanded clay industry.

UFE thanks the Commission for the opportunity to react on the proposed revision of the ETS Directive. Please find enclosed and below our contribution. UFE, the association representing the French Electricity Industry, is mainly aligned with the Commission's proposal on the revision of the existing EU ETS.

EU EMISSIONS SYSTEM TRADING DIRECTIVE FEDENE’s contribution to revision of the EU ETS directive November 2021 FEDENE is a French professional association representing 500 energy and environmental service companies.

In order to achieve the CO2 reduction target of the sectors covered by the EU ETS, the Commission intends to address both the reduction of the total number of allowances (cap) and an increase of the auctioning share of allowances (reduced free allocation). It is worth recalling that the intention of the free allowances in aviation was to address competitive disadvantages in relation to third countries.

Please find attached the contribution of the Spanish association of ceramic tile manufacturers (ASCER) to the public consultation on the proposed revision of the EU ETS Directive. Attached to the reply is a document containing the results of a study carried out by the Research Centre for Energy Resources and Consumption (CIRCE) for ASCER

The VKU is grateful for the opportunity to comment on the European Commission’s proposal to amend the European Emissions Trading Directive 2003/87/EC, Decision (EU) 2015/1814 on the establishment and operation of a market stability reserve for the greenhouse gas emission allowance trading scheme and Regulation (EU) 2015/757.

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FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission.

Sandbag welcomes the opportunity to provide feedback on the update of the EU ETS under the FF55 package. Our analyses show that the proposed changes are not enough to guarantee that emissions will stay below the cap and that they could exceed it by 45% in 2030.

The European Copper Institute (ECI) supports the EU’s climate ambitions for 2030 and 2050. The copper industry is ready to do its part. Copper makes a significant net contribution to the clean energy transition as a sustainable raw material that is needed to decarbonise the economy. Copper delivers energy savings and CO2 reductions across the electricity system, in transport, buildings and industry.

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU has the potential to reduce CO2 emissions to the atmosphere. CCU is an important element in the innovation challenges for a low-carbon and circular economy and should therefore logically be recognised by ETS.

Polish Glass welcomes the opportunity to provide feedback on the Commission proposal to review the EU -ETS. Modification of Carbon Leakage measures In order to achieve ambitious reductions, industry will have to invest massively in low-carbon technology. Unfortunately, the high carbon prices, and the lack of a level playing field with non-EU countries, makes this really challenging.

The achievement of the more ambitious GHG emission reductions target, eventually leading to reaching climate neutrality by 2050, necessitates an adjustment of the EU ETS functioning. The 'polluter pays' principle should be at the core of the EU energy and climate policies, while covering all emissions of fossil fuel combustion and integrating them in the EU ETS, would present important benefits in terms of…

Revising the EU Emission Trading System Directive (ETSD) and improving the proposal COM(2021) 551 are of utmost importance – but given today’s urgency of industry’s decarbonisation, the ETS needs complementary measures via the EU Industrial Emissions Directive (2010/75/EU (IED)) that is being revised in parallel. ClientEarth’s feedback focuses on crucial changes to the interactions between the ETSD and IED.

HYBRIT - Hydrogen Breakthrough Ironmaking Technology - is an initiative developed by SSAB (global leader in high strength steels), LKAB (Europe’s largest iron ore producer) and Vattenfall (one of Europe’s largest electricity producers) that aims to revolutionize iron- and steelmaking by replacing coking coal, traditionally needed for reduction of iron ore, with fossil-free hydrogen.

Hydrogen Europe stands for reforming carbon markets to enable a liquid, sustainable and affordable hydrogen market. A revised, more ambitious EU ETS will be an essential for deep decarbonisation. In this context, carbon content of energy carriers should become the “new currency” of the EU economy, as well as the basis for a stable economic recovery.

Even though ECSA's first preference always is an international regulation for shipping at IMO level, the sector should contribute its fair share to address the climate crisis at EU level as well. European shipowners firmly support a dedicated fund to be set up under the EU ETS to stabilise the carbon price.

RTE Réseau de Transport d'Électricité, a player in the energy transition in France and Europe, has taken note of the European Commission's proposals in the Fit for 55 package. Concerning the revision of the EU-ETS, RTE Réseau de Transport d'Électricité notes that : - the emission reduction target in 2030 (compared to 2005) is increased from -43% to -61% for the EU as a whole and that allowances must decrease by 4.2%…

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union, Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas…

The YESO Technical and Business Association, ATEDY, welcomes the “Goal 55” package which aims to introduce the necessary policy and legislation for Europe to reduce its greenhouse gas emissions by at least 55 % by 2030 and strongly believes that low carbon building solutions, such as plaster-based products, are key to achieving the ecological transition.

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The Spanish association of magnesia manufacturers (MAGES) appreciates the opportunity to translate its considerations into the proposed Directive to update the EU Emissions Trading System (ETS). Some of the comments on the proposed amendments to the EU ETS, which are detailed in the annexed document, are briefly set out below: The European magnesia sector has a high risk of carbon leakage due to its high exposure to…

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The Bioenergy Association of Finland welcomes the Commission proposal to revise the EU ETS as part of the Fit-for-55 package. The EU ETS is an important tool to implement the enhanced 2030 Climate Target. The EU ETS has proven its ability to reduce greenhouse gas emissions in the Union. It is technology-neutral and provides plenty of flexibility for its participants to fulfill the related obligations.

The Dutch dairy Association welcomes the opportunity to comment on the Commission proposal of the review of the ETS and would like to draw the attention to the following points of interest: • Strengthening of the scheme means a cost increase for the participants of the ETS.

WISE, World Information Service on Energy Netherlands, welcomes the opportunity to participate in the consultation for the revision of the EU ETS directive. WISE supports the increased ambition in reducing greenhouse gas emission by 2030 and towards climate neutrality by 2050 through the EU ETS.

UNESID, the Spanish Steelmaking and Steel transforming Association views in relation with a future improvement of the EU Emission Trading Scheme Promoting the electrification, either direct or indirect instead of hamper it.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on updating the EU emissions trading system (ETS ). Our main messages are: 1. Reinforcing the role of the EU ETS as a key driver of a cost-effective decarbonisation of the EU economy. 2. Creating a pathway for a gradual expansion of the EU ETS. 3.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

voestalpine supports the Paris Agreement and its implementation, and that on all levels of potential action. However, it needs to be secured and prioritized that any business activity as well as investment remains economically viable. Thus, any according business case needs to enable positive returns on investment.

The Swedish Gas Association supports the Commission's proposal to revise the EU ETS so that the regulations are in line with the goal of reaching net greenhouse gas emission reductions of at least 55% compared to 1990 levels, by 2030. According to the stated proposal, the combustion of biofuels will continue to be assigned an emission factor of zero, and will therefore not be affected by emission allowance costs.

essenscia welcomes the opportunity to participate in the consultation on the revision of the ETS and continues to support emissions trading as a policy tool to sustainably achieve agreed emission reductions at the lowest cost to society: Emission mitigation options and investment decisions of companies and sectors in the emissions trading scope will be triggered according to their economic, environmental and social…

Because of the rural location of sugar factories and limited access to high-voltage grids, full electrification is neither a cost-effective nor even feasible decarbonisation pathway for our sector. The use of biomass, especially own-produced (from residues and waste), in combination with the partial conversion to renewable electricity, presents a more promising avenue to decarbonise the industry.

This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.

Frank Bold Society welcomes the opportunity to comment on the proposal of the revised ETS Directive. Please find attached our analysis on ETS revenues use (Art. 10(3) of the Directive) - current practice in the Czech Republic. The main outcomes of the analysis are: - FBS welcomes the revision draft of the ETS Directive, which suggests that 100 % of ETS revenues should be used for environmental measures.

Oesterreichs Energie welcomes the general increase in the CO2 savings target in the EU ETS sector, as well as the proposal to achieve this target by raising the linear reduction factor (LRF) from 2.2% to 4.2%. We also take a positive view of the extension of the EU ETS to include maritime transport.

The members of E4FC are fully committed to reducing their carbon footprint and support the ambition set out in the European Commission’s Fit for 55 package. The proposed initiatives will however require substantial investments and will add to the costs of European airlines, thereby impacting the global competitiveness of European network airlines and their employees.

BV Glas, the German association of the glass industry, is part of Glass Alliance Europe (GAE) , the European Alliance of Glass Industries. We welcome the opportunity to provide feed back based on the position of our European sector federation GAE: A more elaborated position paper is attached to the contribution.

FinCo Fuel Group and GoodFuels welcome the revision of the Emission Trading System (ETS) as part of the Fit for 55 Package. With the inclusion of the road and maritime sector we believe an important step will be taken to advance further CO2-emission reductions and to reach European climate goals.

This document comprise Danish Energy’s updated positions on: 1. The ETS-directive and the Market Stability Reserve (MRS) 2. The Carbon Border Adjustment Mechanism (CBAM) Generally, we find that the proposed revision of the ETS-directive is very positive.

FEDIOL welcomes the Commission’s ETS revision proposal and ambitious GHG emission reduction targets and is committed to continuing its efforts to reduce emissions. It is however commenting on this proposal as follows - Increasing the maximum benchmark update rate would seriously impact our industry, which considering past efforts is already stretched in terms of energy efficiency gains; further emission cuts are…

In light of the worsening climate crisis, the primary objective of the ETS revision is to strengthen its ambition in line with the Paris Agreement goal of limiting temperature rise to 1.5°C. This requires the EU ETS target to be increased to at least 70% emission reductions in 2030, compared to 2005 levels, in order to allow the EU to overshoot its -55% net emissions target and cut total emissions by at least 65% by…

Neova Group would like to bring to the Commission’s attention the issue of activated carbon, that is used in air and water purification. Activated carbon production is exposed to a significant risk of carbon leakage, as most of world’s activated carbon is made outside the EU using coal. Importing coal based activated carbon seriously undermines the goals of the European Green Deal.

PLINOVODI d.o.o. as a TSO of gas infrastructure would like to highlight that low carbon and renewable gases, such as green hydrogen, biogas and e-gases will play important role to decarbonize the EU ETS sectors.

Corbion is the global market leader in lactic acid and its derivatives. Our sustainable solutions provide an alternative to fossil-based ingredients or building blocks across a wide range of industries and we therefore thank the European Commission for the opportunity to react via this consultation to its proposal for a regulation to reform of the EU Emissions Trading System (EU ETS).

Vattenfall strongly welcomes the European Commission’s initiative to further improve and strengthen the EU ETS in line with the EU’s increased climate ambitions for 2030 and 2050. Most importantly, the new LRF (4.2 %) should take effect as early as possible to promote early action and investor certainty.

The European Commission adopted on 14 July 2021 a major step towards reducing Europe’s greenhouse gas emissions. The “Fit for 55” Package aims to introduce the necessary policy and legislation for Europe to cut its greenhouse gas emissions by at least 55% by 2030.

FEVE , The European Container Glass Federation, welcomes the opportunity to provide feed back on the Commission proposal to review the Emission Trading Directive (ETS). Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution.

Glass Alliance Europe (GAE) , the European Alliance of Glass Industries, welcomes the opportunity to provide feedback on the Commission proposal to review the Emission Trading Directive (ETS). Given the 4,000 characters limitation, this input will focus on the main elements. A more elaborated position paper is attached to the contribution.

FinCo Fuel Group and GoodFuels welcome the revision of the Emission Trading System (ETS) as part of the Fit for 55 Package. With the inclusion of the road and maritime sector we believe an important step will be taken to advance further CO2-emission reductions and to reach European climate goals.

APEMAR supports the decarbonisation objectives of the Green Deal and the FIT FOR 55 package. Following the publication of the FIT FOR 55 legislative proposals, the APBA has carried out a study on the potential impact of the implementation of the Emission Trading Scheme and the EU MARITIME FUEL in the Port of Algeciras.

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CEWEP Ireland welcomes the continued exclusion of municipal and hazardous waste incineration from the EU ETS. There is no change in the definition for WtE in Annex I of the proposed Directive which continues to provide an exemption for hazardous and municipal waste. The exemption was introduced for good reason.

Please, find below a synthesis of Enel’s view on EU ETS revision proposal. For further details, please see the attached document. Enel welcomes the EU ETS Directive’s “Fit for 55” proposal of reform as it fits with the increased EU climate ambition and will help provide stable and predictable carbon price signals.

Please find below a summary of the views of the power sectors on the proposal of the European Commission on the ETS. For more details, please see the document enclosed. • Increase the ambition in the EU ETS. We welcome several of the Commission’s proposals to strengthen the EU ETS in line with the increased 2030 climate target, including the increased linear reduction factor (LRF) to 4.2% in combination with a…

DTEK welcomes this opportunity to comment on the proposal of the revised EU ETS Directive. We would like to reiterate our statement from the previous comments under these consultations that DTEK supports Ukraine’s commitment to implement an Emission Trading System based on the EU ETS Directive.

Luossavaara-Kiirunavaara AB (LKAB) is an international high-tech mining and mineral group that mines and processes iron ore in Sweden for the global steel market. More than 80% of the iron ore produced in Europe comes from LKAB’s mines.

On 14 July, the European Commission presented a legislative package to achieve the stricter target of a 55% CO2 reduction compared to 1999 by 2030 and, thus, contribute to solving the climate problem. As a business organisation for trade and logistics, ESC takes the view that the client of a transport mode must be able to make a well-informed, transparent, uniform, and fair assessment between the various…

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality.

GENERAL COMMENTS: • The effects of raising the contribution of the ETS towards a higher emissions reduction target will not be felt equally across the EU. Some MS will be more affected than others. • Required investment in Polish energy sector in the years 2021-2040 (according to the Polish government), are estimated at over PLN 560 bln (about EUR 125 bln). • PGNiG is concerned whether additional resources (2,5 p.p.

In our opinion, it is recommended to phase out the free allowances for the aviation earlier than assumed in the draft amendments to the Directive 2003/87/EC It is in perfect to maintain the current level of free allowances in aviation (worth about EUR 800 million in 2019) and the proposal to phase them out by 25 % in 2024, 50 % in 2025, 75 % in 2026 and 100 % in 2027.

Filed in Polish · English published by the European Commission

Danish Shipping welcomes the Fit for 55 proposals as an important contribution to drive GHG reductions and incentivize the uptake of renewable fuels. Danish Shipping would like to take the opportunity to comment on the elements that we support i.e., the proposed definition of legal entity and the phasing-in period.

As PFP member, Starch Europe fully supports the PFP position. In particular, we welcome the ETS proposal and remain committed to further reducing our emissions, but note several critical points in the proposal that could cause serious difficulties in our sector - The new ambitious linear reduction factor will likely lead, despite the higher maximum benchmark update rate, to the implementation of the CSCF, which…

The Port Authority of Valencia (APV) is fully aligned with the environmental objectives set by the European Union and the International Maritime Organisation (IMO). To this end, and as a key element of its strategy in the short, medium and long term, it is developing a number of projects that will lead it to reach the “zero emissions” target by 2030.

Filed in Spanish · English published by the European Commission

The revision of the EU Emissions Trading System (ETS) represents a huge opportunity to strengthen the Directive to ensure it is in line with the 1.5˚C target under the Paris Agreement. However, the European Commission’s proposal includes two major shortcomings that should be reconsidered.

Technology Industries of Finland: Viewpoints on Revision of the EU Emission Trading System (ETS) TIF supports the increased ambition level of 2030 and 2050 EU emission reduction targets and recognizes the need to adjust the ETS system accordingly. We consider RDI activities and investments to low carbon industrial processes and solutions as key elements to achieve both sustainable recovery and growth.

The Finnish Shipowners’ Association (FSA) welcomes the opportunity to provide comments to the Commission’s proposal to revise the EU Emissions Trading System (ETS). The FSA welcomes the European Commission’s Fit for 55 -package and supports its ambition to deliver the European Green Deal.

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to establish an emissions trading system for road transport. It is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. - Achieving the necessary emission reductions by 2030 and on the way towards climate neutrality requires unprecedented efforts by all stakeholders.

Tata Steel’s position is that climate policy should not only stimulate the transition to net zero CO2 emissions in 2050, but also ensure the competitiveness of Europe’s industry during the process. The current proposal does not have that balance.

Alfaport Voka is the platform by and for companies and professional associations in the port of Antwerp, Belgium. Alfaport Voka is aiming for an accessible, facilitative, cost-competitive and sustainable port of Antwerp with a view to embedding sustainable employment and added value at the port.

The Government of Japan, as a country threatened by climate change and at the same time heavily dependent on international shipping, has expressed its concerns about the extension of the EU’s emissions trading system (ETS) to international shipping at every opportunity. However, the regulation package for international shipping in the Fit for 55 published in July 2021 brings Japan much deeper concerns.

Fertilizers Europe welcomes the possibility to share its views as part of the European Commission’s public consultation on the proposed amending directive of the EU ETS. The EU ETS has been a key driver for emission abatement in the fertilizer industry.

Finnish Forest Industries Federation Register ID number: 39671713910-36 [name removed], Senior Adviser, Energy [email removed] Finnish Forest Industries’ response to the consultation on the Emissions trading system (ETS) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ETS will provide regulatory stability which promotes the industry’s investments in climate friendly products…

We believe that it is not a good idea to set up a stand-alone ETS for transport and buildings alone as it is proposed in the fit-for-55 package. The larger the scope of the ETS, the more efficient the system, and thus the lower the overall abatement costs for a given CO2 reduction.

Polish Steel Association is a non-profit trade organization of steel manufacturers and steel processing plants that represents Polish steel industry. In this letter, the Polish Steel Association provides the official position of the polish steel industry regarding the proposed amendments to the Directive of the European Parliament and of the Council amending Directive 2003/87/EC establishing a system for greenhouse…

Ahead of a more detailed European Sea Ports Organisation (ESPO) position that specifically considers the proposal for a maritime EU ETS, European ports welcomes the proposal as part of the new “Fit for 55”-proposals as an important first step towards reaching the European Green Deal ambition and the 2030 and 2050 goals enshrined in the EU Climate Law.

Build Europe supports the EU’s environmental objectives and ambitions, and welcomes the objective to turn Europe into the first carbon neutral continent by 2050. Build Europe is concerned, however, the continuous introduction of additional environmental requirements could threaten housing affordability across Europe, unless strong financial incentives are put in place.

If Europe wants to play a role in helping the shipping industry to make this propulsion revolution a reality, support needs to be given to shipping in overcoming the multiple hurdles to fully decarbonise. For a possible decision of Europe to integrate shipping in the EU Emission Trading System (ETS) this means that specific conditions need to be met when structuring the underlying regulation of the ETS.

The ETS currently covers around 10.000 energy-intensive installations responsible for about 40 % of GHG emissions in the EU. In our view, the necessary tightening of greenhouse gas emissions in high-emission sectors, in particular fossil GHG emissions, has been partially implemented, but is insufficient in view of the increased climate target.

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Key messages: ➢ The higher 2030 target should be achieved in the most cost-efficient way: the one-off cancellation (rebasing) and strengthening of the Market Stability Reserve cause unnecessary additional costs for EU society that should be avoided ➢ Higher climate ambition and rising carbon costs require strengthened carbon leakage protection • Full benchmark based free allocation and indirect costs compensation…

COMPORT BAHIA DE ALGECIRAS, Association representing the Algeciras Bay Port Community, shares the aspirations to make Europe a climate-neutral continent by 2050 and fully supports all the objectives of the European Green Deal. However, it believes that the guarantee of a level playing field with other countries in our neighbourhood should be taken into account when designing European decarbonisation policies.

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IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

North European Oil Trade (NEOT) contributes to this consultation from the perspective of a Finnish fuel distributor. Our supply represents approximately 40% of the total fuel consumption in Finland, an EU Member State that has one of the highest emission reduction targets for transportation sector in the EU.

SEA-LNG Feedback on the Proposed Revision of the Emission Trading System (ETS) SEA-LNG Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the…

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal for the extension of the EU ETS to cover maritime shipping. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and scientific analysis to environmental regulators.

Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for 55 package.

The Emissions Trading System (2021 – 2030) should remain the main market instrument for Europe’s industries to cost-effectively reduce their emissions. Carbon and graphite products are commodities that are traded worldwide. This leads to high trade intensity and a globally competitive market.

- The Volvo Group strongly welcomes an emissions trading system for road transport. It is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. - Volvo Group has committed to climate neutrality by 2050 at the latest, leading to that all vehicles put on the market from 2040 must be carbon neutral.

This paper provides the initial reaction of the Finnish Steel and Metal Producers (FSMP) to Commission’s proposal for the review of the EU Emissions Trading System (EU ETS). FSMP represents Finnish Steel and non-ferrous metals producers including various Steel products, Copper, Nickel and Zinc.

Clean Air Task Force (CATF) welcomes the EU climate ambition, leadership on decarbonisation, and pursuit of policies to decouple greenhouse gas emissions from economic growth. As the backbone of the EU climate legislation, the revision of the Emission Trading System (ETS) should ensure that it matches the EU’s climate ambitions and that it provides the tools necessary to reach its ambitious targets.

We as EurECCA are representing 70% of all cabin crew in Europe and are their voice in Brussels. The planned revision of the EU ETS is one of the major measures to significantly contribute to the goals set in the Paris agreement.

Dear Sirs, The steel group MEGASA operates on the global market. Due to its electro-intensive nature, the group sees its competitiveness strongly affected by CO2 costs in Europe. MEGASA therefore endorses EUROFER’s position, as set out in the attached document. For MEGASA, Alvaro Alvarez

Filed in Portuguese · English published by the European Commission

The CEA supports the exemption from coverage of chemically and permanently bound CO2 (storage) provided for in the revised Directive. In the context of carbon capture and use, the Commission must ensure that carbon emitted into the atmosphere is subject to the emissions trading scheme only once (neither avoidance possibility nor the need for multiple coverage by allowances for a single emissions).

Filed in French · English published by the European Commission

PFP welcomes the Commission’s ETS revision proposal and ambitious GHG emission reduction targets and is committed to continuing its efforts to reduce emissions. PFP notes several critical points in the proposal that could cause serious difficulties in our sectors - The new ambitious linear reduction factor will likely lead, despite the higher maximum benchmark update rate, to the implementation of the CSCF, which…

The legislative proposals released by the Commission to reach the 55% target by 2030 are an important milestone towards a climate-neutral society with a growing economy. Yara has already reduced its global direct and indirect emissions by 45 % compared to 2005 (and by 57 % in Europe).

Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the proposal to amend the Emissions Trading System (ETS) Directive. Increased Targets: GNI welcomes the increased target to reduce emissions under the ETS by 61% versus 2005, to align with the increased emissions’ reduction target of at least 55% by 2030.

With “Fit for 55,” the European Commission has presented a comprehensive package aimed at reshaping the European Union’s climate policy. Among other things, the Commission’s proposal envisages the introduction of a separate emissions trading system (ETS) for road transport and buildings (ETS-2) from 2026, alongside the existing EU ETS for the energy and industry sectors.

VIK e.V. supports the European Commission’s plans for an improved emissions trading mechanism. However, it must be ensured that the planned reform of emissions trading does not lead to an increased risk of carbon leakage. A price corridor can accelerate the convergence of the two systems and thus provide planning certainty.

Filed in German · English published by the European Commission

EDA calls upon the EU Commission to develop cost-efficient policy tools in the context of the ETS revision and the Fit for 55 package. Such implementation tools should be in line with the EU environmental commitments and the SDGs and at the same time should not undermine food safety, quality, security, affordability, and the European food culture, and should not damage nutrition and health.

Maintaining the free allocation of emission allowances is crucial to safeguard competitiveness and prevent carbon leakage 1) Tightening up the existing emissions trading Neste welcomes the Commission's proposals to strengthen the carbon price signal through the EU Emission Trading System (ETS), thus creating the conditions for low-emission investments in new technologies.

Federacciai (Federation of the Italian Steel Companies) supports Eurofer's position "Recommendations for a revision that delivers higher climate ambition, cost-efficiency, strengthened carbon leakage protection and faster industrial decarbonisation", for the EU ETS public consultation. Please see document attached.

Plastics Europe contributes to the stakeholder consultation as follows: 1) Waste: Annex I In order to contribute to the EU climate neutrality objective, plastic producers aim at maximizing the plastics circularity, which is a key means to reduce GHG impact of the plastics value-chain.

This organisation fully supports all the objectives of the European Green Deal and shares the aspirations to make Europe a climate-neutral continent by 2050. The Campo de Gibraltar region has a land border with Gibraltar (UK) which is the third largest territory in the world with the highest income per capita and a more attractive tax system for businesses; Moreover, it is just 13 km away from Morocco, whose labour…

Filed in Spanish · English published by the European Commission

Liquid Wind welcomes the European Commission’s proposed revision of the Emissions Trading System (ETS) as a part of the Fit-for-55 legislative package. Liquid Wind is a Swedish Power-to-Fuel Development Company committed to reducing carbon emissions.

The Fit for 55 Package risks weakening the existing carbon leakage protection measures as the EU increases its climate ambition in light of the European Green Deal. As long as competitors in third countries are not subject to equivalent carbon costs and constraints, carbon leakage is a major threat for the EU industrial value chain.

Feedback from the federation ENERGIA, the sector organisation in Belgium of companies proposing mobility and energy solutions. Our members are active in the refining, distribution and storage in Belgium of energy solutions for transport, heating and industry as well as in the production of feedstock for the petrochemical sector.

LanzaTech commends the European Commission’s ambition in its revision of the Emissions Trading Scheme (ETS). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal.

The Algeciras Bay Port Authority (APBA) supports the decarbonisation objectives of the Green Deal and the FIT FOR 55 package. Indeed, the Algeciras Port Green Strategy is aligned with the objectives of the Green Deal and underpins initiatives aimed at the sustainability of our activity.

Filed in Spanish · English published by the European Commission

Opinion of the Deutscher Braunkohlen- Industriverein e.V. (DEBRIV) on the Fit-for-55 package (Fit for 55), in particular, the proposed amendments to the EU ETS Directive and the Energy Tax Directive of 14 July 2021 Energy security as a challenge of the Fit for-55 climate policy package must always take into account the need to ensure energy supply, in particular electricity, at all times and in every place.

Filed in German · English published by the European Commission

The paper attached is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on two of the Fit for 55 package proposals: The review of the Emission Trading Scheme and the Social Climate Fund.

The Norwegian Oil and Gas Association (NOROG) organises companies which produce oil and gas on the Norwegian continental shelf, supply the operations there, or work at sea with renewable energy or mineral production. We support the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050.

The North CCI takes a critical view of the practical arrangements for extending the EU ETS to maritime transport and calls on the European Commission to: — To promote a return of revenue by extending the EU ETS to maritime transport through a maritime decarbonisation fund.

Filed in German · English published by the European Commission

The Official Chamber of Commerce, Industry, Services and Field Navigation of Gibraltar fully supports all the objectives of the European Green Deal and shares the aspirations to make Europe a climate-neutral continent by 2050. However, it also believes that this needs to be done taking into account a number of other factors that ensure a level playing field with other countries in our neighbourhood.

Filed in Spanish · English published by the European Commission

PKEE members are committed to achieve climate neutrality and 55% emissions reduction target. As pointed out by i.a. Eurelectric, if carbon neutrality in entire economy is to be achieved by 2050, hard-to-abate sectors need to be electrified, which cannot be implemented with skyrocketing power prices, observed nowadays in Europe.

Dear Commission, Please find Energy Norway's feedback on the EU ETS proposal attached. Energy Norway is an association that represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting and trading electricity. Our members produce 130-140 TWh annually, which is around 95 percent of all power production in Norway.

The European flat glass sector takes it as its role to produce the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe.

EURACOAL is pleased to submit its attached position paper on the proposed amendments to the EU ETS Directive. In summary, we have twelve key points to make in response to the European Commission's proposal: 1. The current energy crisis highlights the need for secure, reliable and diverse energy supplies at affordable prices. Coal provides these and so benefits EU society. 2.

“FIT FOR 55” PACKAGE UNDER THE EUROPEAN GREEN DEAL Feedback to the European Parliament and Council for legislative debate In Algeciras, 3rd of November 2021 Total Terminal International Algeciras S.A. (TTI ALGECIRAS) is the common user container terminal operating in the Port of Algeciras Bay in Southern Spain, a strategic point in the Strait of Gibraltar.

France Hydrogène considers that the reform of the EU ETS carbon market is going in the right direction to strengthen the carbon price signal and encourage the transition to low-carbon technologies provided that adequate carbon leakage protection is guaranteed to trade intensive sectors.

The eFuel Alliance is a stakeholder initiative committed to promoting the political and social acceptance of eFuels and to securing their regulatory approval and represents more than 150 companies along the value chain of eFuel production. Carbon pricing ensures that the costs of greenhouse gas (GHG) emissions are tied to the polluters – producers and consumers.

The Federal Association of Energy-Efficient Buildings envelope (BuVEG) welcomes the planned revision of the Directive of the European Parliament and of the Council amending Directive 2003/87/EC and Decision (EU) 2015/1814 to strengthen and extend the EU emissions trading scheme in line with the Union’s more ambitious climate targets for 2030.

Filed in German · English published by the European Commission

CONTRIBUTION OF “STRAIT PORT STEVEDORING COORDINATOR” TO UPDATE THE EU EMISSIONS TRADING SCHEME The trade union “Coordinadora de Estibadores Portuarios del Estrecho” fully supports all the objectives of the European Green Deal and shares the wishes for Europe to be a climate-neutral continent by 2050, but also supports all the rights recognised in the European Social Charter, so that we are sufficiently concerned…

Filed in Spanish · English published by the European Commission

Removal of the exception for the financing of fossil fuel-fired district heating (DH) in certain Member States from the Modernization Fund may hinder transformation of the DH (the so-called coal-to-gas switch) and is not in line with a cost-effective decarbonization pathway of the Czech Republic, which threatens the fulfillment of the Czech Republic's future climate and energy commitments.

E.DSO welcomes the revision of the EU’s approach to the Emissions Trading Scheme and the FF55 package as a tool to equip the EU’s economy for climate neutrality. However, we acknowledge also that the role of DSOs is not sufficiently recognized in the ETS revision or the FF55 despite their central role to the energy transition.

Re : Response to the European Commission’s Proposal to Extend the ETS to International Shipping Kawasaki Kisen Kaisha, Lyd. as a member of The Japanese Shipowners' Association (JSA), fully supports the comment (Reference No. F2745740) submitted by JSA on 27th October. Best Regards

The Japanese Shipowners' Association (JSA) is strongly opposed to the EU’s intent to extend the EU Emissions Trading System (ETS) to the maritime sector and introduce regional regulations which impact on international shipping. The reasons for our opposition are as attached.:

The impact of extending ETS to buildings should be carefully assessed, especially in terms of social implications. Low-income households – already exposed to sky-rocketing energy prices – could be disproportionately affected by this reform. If pursued, the extension to buildings should be coherent with the existing framework and related reforms. The framework should cover all energies and fuels used (i.e.

Inclusion of sector 24.32 in a separate European Emissions Trading System (EU ETS) upstream scheme and an appropriate carbon leakage list for sectors not yet subject to ETS Dear Sir/Madam, with your proposal for a reform of the European Emissions Trading System (EU ETS), you announce an extension of EU emissions trading to the buildings and transport sectors.

Filed in German · English published by the European Commission

On 14 July, the European Commission took an important step towards reducing greenhouse gas emissions in Europe. The “Fit for 55” package aims to introduce the necessary policy and legislation for Europe to reduce its greenhouse gas emissions by at least 55 % by 2030.

Filed in Spanish · English published by the European Commission

CEMBUREAU supports the review of the Emission Trading Scheme (ETS) to align it with an increased climate ambition. The reform is important to provide the right market signals to enable the industrial transition, which will require significant investments from the European industry. With this in mind, we highlight in this paper a number of key aspects that are essential to strengthen the draft ETS Directive.

SEKAB position on THE PROPOSAL FOR A REVISED EMISSIONS TRADING SYSTEM Introduction SEKAB, a key player in the European bio-ethanol industry, welcomes the proposed revision of the Emissions Trading System (ETS) as a part of the Fit-for-55 legislative package. The ETS is one of the most effective tools in the Comission’s arsenal to achieve the goals of the EU Climate Law.

HSE Group welcomes the extension of the EU ETS to new sectors, such as maritime, and that a special ETS system will be introduced for the buildings and road transport sectors, so bearing a more proportionate burden of achieving GHG emissions reductions, as currently the financial burden of emission remaining allowances encounter on the energy sector.

Filed in Slovenian · English published by the European Commission

Europex welcomes the holistic ‘Fit for 55’ Package as a decisive step towards achieving Europe’s green transition. The package underlines the common understanding that competitive energy and emissions markets must drive decarbonisation efforts to achieve the EU’s green policy objectives at least cost to the economy and consumers, while ensuring a high level of competition and innovation.

EuLA Position on the European Commission (EC) Proposal amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading: • Under the current framework, it is essential for hard to abate sectors with a high share of irreducible process CO2 to have large and affordable access to a global infrastructure to collect the CO2 and transport it with the view to utilise or store the captured…

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation.

The IOGP supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies, and behavioural changes.

The Danish Chamber of Commerce’s consultation response regarding the revision of the EU Emissions Trading System (ETS). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU emissions trading system (ETS).

Helen Ltd. thanks the European Commission for the opportunity to give feedback on Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union, Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading scheme…

The Spanish Cement Manufacturers’ Grouping OFICEMEN appreciates the opportunity to translate its considerations into the proposed Directive to update the EU Emissions Trading System (ETS). OFICEMEN’s comments on the proposed amendments to the EU ETS are summarised below.

Filed in Spanish · English published by the European Commission

A reform of the EU emissions trading system is indispensable to enable emissions trading to contribute to the achievement of the Union’s new climate objectives and, in particular, to the climate objectives of the Paris Agreement. Summary • The reform needs to take effect by 2023 at the latest. • Ambient level needs to be further increased.

Filed in Swedish · English published by the European Commission

Overall: - The ETS-proposal suggests a significant acceleration in the reduction of CO2-emissions by 2030 for industry, underpinned by a higher overall target of -61% and increased LRF of 4,2%. However, this is not followed through by an equivalent increase in protection against carbon leakage.

Zero Waste France welcomes the EU-ETS revision, but would like to suggest amending the EC proposal to include municipal solid waste incinerators in the scope of the Directive (Annex 1.2). Indeed, despite its growing carbon emissions, this sector is currently excluded, unless Member States expressly agree.

Zero Waste Europe welcomes the revised EU ETS. We would like to suggest amending the EC proposal to include municipal solid waste incinerators (MSW) in the scope of the Directive. Currently, the municipal solid waste incinerators are one of the few sources of fossil CO2 that is left out of the scope of the Directive despite of the growing emissions.

Grupa Azoty is one of the leading producers on the European fertilizer and chemical markets. We welcome the opportunity to share our initial views on the planned Amendment of the EU Emissions Trading System - our comments can be found in the attached document.

Tesla recommends not to extend the Emissions Trading System to road transport for the following reasons: • The EU CO2 regulations for cars, vans and trucks has proven to be the single most important driver for emission reductions in the transport sector and for accelerating the transition to an electrified fleet in the EU.

COGEN Europe welcomes the opportunity to comment on the EU ETS Impact Assessment consultation. The EU ETS has been a key instrument to deliver the decarbonisation of the industry and electricity sector. As Europe and the world move to higher climate ambition to reach the Paris Agreement, there is a need for the decarbonisation burden to be more evenly and fairly distributed among all big emitters (in both EU and…

Statkraft is Europe’s largest provider of renewable energy, with a basis in hydropower, a significant presence in wind power and strong growth ambitions within solar and wind in Europe. We have for long been a vocal supporter of a strong EU ETS, as the most efficient tool for driving the transition of the European energy systems in a technology neutral and market-based manner.

In preparation for a possible revision of the EU Emission Trading System, the VBO would like to highlight the following points: — The impact assessment of the 2030 climate and energy targets leads the VBO to conclude that, if the reduction target is raised to 50 % or 55 %, the European Commission assumes a disproportionate additional effort for the ETS sectors.

Filed in Dutch · English published by the European Commission

WWF fully supports the revision of the EU ETS Directive in line with an increased 2030 emissions reduction target. Emissions from EIIs have been stagnating since 2012 (see recent European Court of Auditors https://www.eca.europa.eu/en/Pages/DocItem.aspx?did=54392).

Eurelectric supports the ambition of net-zero greenhouse gas emissions in the European economy by 2050 and an at least 55% target of GHG emissions reduction by 2030 as proposed by the Commission. All sectors of the economy need to contribute to making the EU a climate-neutral economy.

The Swedish Forest Industries Federation represents companies that use forests to provide the raw materials for their products and services. This includes producers of pulp, paper, cardboard, packaging and biofuel. Similarly, sawmills producing all sorts of boards, planks, roof trusses and other prefabricated construction elements are also included.

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the amendment of the EU Emissions Trading System. Our association supports the clean energy transition towards a climate-neutral EU, while safeguarding competitiveness of the industry.

We applaud the increased climate ambitions of the Union, but we have to emphasise that setting a goal of climate neutrality by 2050 still is to take unacceptable risks. Emissions have to stop much earlier. The consequences of being wrong about how high atmospheric CO2 levels can be before irreversible effects set in are Catastrophic. EU climate policy should follow the precise principle (cf.

Filed in Swedish · English published by the European Commission

Please find enclosed feedback from Norsk Hydro, aluminium producer. Summary of our contribution: By increasing the climate target to 55% GHG emission reduction, the EU is taking a considerably stronger leading role on climate action on the global scene. For industries competing globally, as aluminium, the higher ambition creates higher operational costs, leading to additional competitiveness concerns.

Please see the attached file for IFIEC's full response, from which the following selected comments are extracted: IFIEC welcomes the opportunity to participate in the consultation on the roadmap to update the EU Emissions Trading Scheme and supports the EU Commission's discussion on an improved emissions trading scheme.

Comments by International Chamber of Shipping (ICS) Our full comments can be found here: https://www.ics-shipping.org/wp-content/uploads/2020/11/Inception-Impact-Assessment-for-the-proposed-Amendment-of-the-EU-Emissions-Trading-System-Directive-2003-87-EC-1.pdf The International Chamber of Shipping (ICS) appreciates this opportunity to comment on the Inception Impact Assessment for the proposed Amendment of the EU…

Climate Leadership Coalition (CLC) is a non-profit organization committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. During the first six years CLC has become the largest European climate business network when measured by the number of members.

SOLVAY’s response to the Inception Impact Assessment on EU Emission Trading Scheme (EU ETS) EU ETS should remain the pivotal instrument of the European industry against the risk of carbon leakage for a successful transition 1) A new pull strategy to boost demand for low carbon products enabling a fair effort sharing Under the European Green Deal, the Commission is proposing a higher EU greenhouse gas emissions (GHG)…

Reducing greenhouse gas (GHG) emissions demands concerted action on all fronts; the EU Emissions Trading System (ETS) cannot be considered in isolation from the Effort Sharing Regulation or any other measures at the EU level, such as minimum tax rates under the Energy Taxation Directive or any carbon border adjustment mechanism.

Danish Energy highly welcome the opportunity to comment on the European Commission’s Roadmap as part of the EU Emissions Trading System (ETS) review process. In light of the EU target of climate neutrality and the Commission’s proposal to increase the 2030 reduction target to at least -55%, Danish Energy supports reviewing and strengthening the EU ETS in order to ensure the ETS remains a primary driver of Europe’s…

The Zero Emissions Platform (ZEP) is a European Technology and Innovation Platform (ETIP) under the Commission’s Strategic Energy Technology Plan (SET-Plan), and acts as the EU’s technical adviser on the deployment of Carbon Capture and Storage (CCS), and Carbon Capture and Utilisation (CCU) under Horizon2020 R&I programme (grant agreement 826051).

Feedback on the European Commission Inception Impact Assessment for the Amendment of the EU ETS (Directive 2003/87/EC) Armateurs de France welcomes the inception impact assessment carried out by the Commission aiming at studying the impact of the extension of the EU ETS to the maritime sector.

Confederation of Industry of the Czech Republic (SP CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment (IIA) of the EU Emissions Trading System. SP CR understands that following increase in overall ambitions in emission reduction until 2030 changes in ETS are necessary. SP CR would like to submit comments in the attached file for further consideration by the Commission.

Luossavaara-Kiirunavaara AB (LKAB) is an international high-tech mining and mineral group that mines and processes iron ore in Sweden for the global steel market. More than eighty percent of the iron ore produced in Europe comes from LKAB’s mines. LKAB’s new sustainability strategy, a strategy for the future, involves transformation and radical changes in the company’s operations and a new position in the market.

An effective and cost-efficient path towards de-fossilization must build on a holistic and consistent mix of policy instruments. The planned revision of the EU Emission Trading System should therefore be closely aligned with the EU Effort Sharing Decision, the EU Tax Directive, the EU’s sectoral policies as well as national mitigation policies in order to avoid excessive regulation and an increase of CO2 abatement…

Answer from Svebio - Swedish Bioenergy Association We strongly support extension of carbon pricing to the sectors outside ETS. But we are not convinced that inclusion in ETS of the heating and transport sectors are the right way to do this. We would instead prefer introducing carbon taxes on sectors outside ETS. It is a simpler and more straightforward incentive than carbon emission trading.

SSAB's overall goal is to be fossil-free by 2045. SSAB's plan is to convert to a fossil-free steelmaking process based on the hydrogen-based HYBRIT technology, developed by SSAB together with our partners within the framework of the HYBRIT initiative. SSAB's ambition is to be the first to offer fossil-free steel to the market in 2026.

The VDA and its members aim at a substantial and holistic reduction of GHG-emissions on the pathway towards a climate neutral economy in 2050. The European Green Deal proposes several significant changes in climate protection policy.

EEX welcomes the increase of the 2030 ambition as a pivotal step for Europe to achieve its climate targets and assert its role as global climate action leader. Emissions markets will be a crucial instrument in delivering on Europe’s long-term climate ambitions. EEX has been providing an organised market for European Emission allowances (EUA) since the inception of the EU ETS in 2005.

While the IIA raises several issues within a possible ETS extension, the Regulatory Assistance Project (RAP) focuses here on just four, all related to the buildings sector. 1. Simply extending the ETS to the buildings sector is not an effective answer.

AFEP (French Association of Large Companies) member companies emphasise their support to the target of the Paris Agreement and are committed to make the European Green Deal a success. In the context of the revision of the EU Emissions Trading Scheme (ETS) Directive, the following enabling factors will be key for companies: - strike the right balance between current and forthcoming GHG emission constraints, and more…

DI appreciates this opportunity to comment on the framing and scoping of the coming EU ETS revision. The EU ETS has been developed over 1,5 decades, and is the key instrument for decarbonisation in Europe and also nationally. The current target design builds on an objective to form a coherent, cost-effective and balanced marked-based regulation.

Updating the Emission Trading System Opinion of the Danish Agriculture & Food Council The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within the ETS.

It is reasonable to reduce energy demand and thus greenhouse gas emissions through financial incentives. On the one hand, emissions trading and, on the other hand, energy taxes are being discussed. The first argument in favour of emissions trading is that it makes it possible to define definitive limits for emissions.

Filed in German · English published by the European Commission

The European Cabin crew Association fully supports E4FC feedback: "E4FC supports the ambition of the EU to reduce carbon emissions. European airlines have long been working to reduce their CO2 output with investments in new aircraft and technologies, the development and use of sustainable aviation fuels, operational improvements and the participation of aviation in the EU Emissions Trading System (ETS) as well as…

Bioenergy Europe welcomes the opportunity to comment on the Roadmap on the Amendment of the EU Emissions Trading System. It is a matter of great urgency to strengthen the current ETS by aligning the emissions ceiling with the increased target of at least 55% GHG reduction for 2030, and to further pathways towards carbon neutrality by 2050.

HYBRIT - Hydrogen Breakthrough Ironmaking Technology - is an initiative developed by SSAB, LKAB and Vattenfall that aims to revolutionize steelmaking by replacing coking coal, traditionally needed for steelmaking, with fossil-free hydrogen. The result will be the world’s first fossil-free steelmaking technology, with virtually no carbon footprint.

Central Europe Energy Partners (CEEP), an organisation which represents the interests of companies from Central Europe, welcomes the possibility to provide feedback to the Commission’s Inception Impact Assessment on the revision of the ETS. Implementation of the European Green Deal requires a significant reduction in global emissions to achieve a climate neutrality goal by 2050.

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently.

FEDIOL, the EU Vegetable oil and protein meal industry, acknowledges the EU carbon neutrality objective by 2050 and the associated need to increase its emissions reduction target by 2030. Reducing GHG emissions in the transport sector is comparatively more difficult and costly than in any other sector.

The European Roundtable on Climate Change and Sustainable Transition (ERCST) welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment for the Revision of the EU Emissions Trading System (EU ETS).

Please, find attached FEAD’s full feedback to the EC Roadmap on updating the EU ETS. FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste.

The EC inception impact assessment proposes to explore six policy options for the revision of the EU ETS directive in light of the European Green Deal. FuelsEurope welcomes the opportunity to comment on the key design elements of the current scheme, in particular the ambition level, the carbon leakage protection measures, the scope, the ETS versus the Effort Sharing Regulation, and finally the Market Stability…

Our vision of EU action has at its core the following objective: a level playing field for European energy-intensive industry. And a reviewed ETS can contribute to this objective through the following measures: - A linear reduction factor that is based on technological breakthrough, technology availability and economic viability of technology - and not on artificial, administrative decision.

Feedback from UNEM on amending the EU Emissions Trading System (Directive 2003/87/EC) The Italian refining industry, represented by UNEM, is ready to address the decarbonisation of the economy in line with the environmental objectives set by the European Union in the Green Deal. In this context, UNEM welcomes the opportunity to contribute to the modernisation of the EU Emissions Trading System (ETS).

Filed in Italian · English published by the European Commission

Please find the full feedback attached. The steel industry in Germany is committed to achieving climate neutrality by 2050. It also intends to significantly reduce its CO2 emissions already in the coming years. Low CO2 steel technologies can save many millions of tonnes of CO2 — under the right policy framework — to enable the steel industry to contribute towards a socially demanded climate neutrality.

Filed in German · English published by the European Commission

•Enel welcomes the approach of the legislative initiative, aimed at strengthening the EU ETS, and the ambitious package of policies and measures to accelerate the just transition to a low-carbon economy. It is critical for the EC to adopt a holistic approach enhancing carbon pricing alongside complementary policies and measures.

Climate Leadership Coalition (CLC) is a non-profit organization committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. During the first six years CLC has become the largest European climate business network when measured by the number of members.

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points concerning the updating of the EU emissions trading system (ETS) Emissions in the EU must be cut at least 65 % by the year 2030 in order to keep the global temperature rise to 1.5 °C.

UFE supports the EC’s initiative to strengthen the ETS to contribute to achieving the new ambitious climate targets for 2030 and 2050. 1. The ETS must be reinforced as the core instrument of decarbonisation in the EU A predictable carbon price is essential to ensure the ETS plays a key role in decarbonising the EU economy while guaranteeing a smooth and fair transition.

Climate Leadership Coalition (CLC) is a non-profit organization committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. During the first six years CLC has become the largest European climate business network when measured by the number of members.

We consider emissions trading as a market-based measure to limit and reduce CO2 emissions and to price CO2 in aviation to be the most appropriate solution. The inclusion of global aviation in the EU ETS could not be achieved in the international community, so EU-ETS is limited to intra-EU flights. This means that EU ETS distorts competition with regard to transfer traffic.

The climate and energy framework regulatory overhaul to step up 2030 climate is a unique opportunity to improve policy coherence and address the existing loopholes. The EU ETS is an important driver of decarbonisation but it needs to be strengthened and cannot work alone. The market mechanism must be reinforced and go in hand with a stronger regulatory approach and by no means replace it.

In order to achieve the planned increase in the EU's climate targets to 55% reduction in greenhouse gas emissions by 2030, the EU CAP, the linear reduction factor and the Market Stability Reserve (MSR) are expected to be modified. These options will result in a shortage of allowances as well as an increase in CO2 prices.

The upcoming revision of the EU Emission Trading System (ETS) represents a crucial opportunity to strengthen the Directive and ensure it contributes to the goals of the Paris Agreement. The Rethink Plastic alliance welcomes this opportunity to feedback, and considers that the review should include the following elements: - A higher Linear Reduction Factor (LRF) and an one-off reduction of the cap : The new LRF and…

The upcoming revision of the EU Emission Trading System represents a crucial opportunity to strengthen the Directive and ensure it contributes to the goals of the Paris Agreement. Carbon Market Watch believes that the upcoming review should include the following elements. 1.

[Please refer to attachment for full response] The European Emission Trading System (EU ETS) is the central EU policy to regulate CO2 emissions and deliver effective signals to support the energy transition and fight climate change. A well-functioning ETS creates effective price signals for market operators and investors.

Enviva is a leading global energy company specializing in sustainable wood bioenergy. Our mission is to provide an alternative to coal and grow more trees. We do this by producing sustainable, renewable wood pellets and delivering them to customers around the world. Sustainable biomass is central to reducing European carbon emissions and meeting ambitious 2030 and 2050 climate goals.

The Polish Electricity Association welcomes the opportunity to participate in the Commission’s public consultation for the amendment of the EU ETS Directive and would like to point the Commission’s attention to the following aspects.

Eurofuel is the European Heating Oil Association, which represents the national organisations that promote the use of liquid fuels for domestic heating in 10 European countries. Our members are well aware of the huge challenge we are facing, as individuals and as a sector, to limit climate change.

ACEA welcomes the opportunity to comment on the Inception Impact Assessment “Amendment of the EU Emissions Trading System” and would like to provide the following comments. We welcome the recent communications by the Commission which open up the possibility for an expanded ETS which could be developed as an upstream trading system regulating at the point of fuel distributors or tax warehouses.

CEWEP, the Confederation of European Waste-to-Energy Plants, fully supports the principle that all sectors will need to contribute to higher climate targets and Waste-to-Energy (WtE) is ready to do its part. WtE, incineration with energy recovery, plants fulfil a sanitary task, treating polluted substances in an environmentally sound way, reducing the volume of the waste and recovering climate-friendly energy and…

GENERAL COMMENTS: • Extension of EU ETS should not be considered as most effective solution across all sectors. Individual approach in specific sectors should be applied in order to maximize environmental benefits. • As regards waste sector, one of the main identified sources of methane are uncontrolled emissions of landfill gas in landfill sites.

As data shows, the EU ETS has been an effective tool for reducing CO2 emissions in the sectors covered by it. But there is a need to strengthen the system to enable a delivery of necessary emissions reductions and by doing so, to deliver a robust CO2 price.

Comments from the Confederation of Swedish Enterprise on the roadmap consultation on the EU ETS The Confederation of Swedish Enterprise fully supports the objectives of the European Green Deal and we strongly support the goal of reaching net zero greenhouse gas emissions by 2050. Further the Confederation of Swedish Enterprise is open to discuss a more ambitious 2030-target.

There are several aspects to the ETS reform. This response focuses only on how the ETS reform can better support energy-intensive industries to invest in climate-neutral solutions. Agora believes it is urgent to begin to set EIIs on path to climate neutrality before 2030. The timeline is critical because a large number of assets face major reinvestment decisions in the next decade.

AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power), welcomes the possibility to voice its opinion on the amendment of the European Emission Trading System Directive. AGFW is convinced that the extension of the European ETS poses a unique opportunity to develop a carbon price signal that creates sufficient incentives for an efficient market based energy transition.

T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.

EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities.

The Swedish Society for Nature Conservation's demands for EU-ETS reform in brief: - The EU needs to reduce its total emissions by at least 75 percent by 2030 compared to 1990 levels and reach near zero emissions by 2035.

CIROM welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment for the “Amendment of the EU Emissions Trading System”. CIROM wishes to highlight that the proposed revision of the EU-wide, economy-wide net target for greenhouse gas (GHG) emissions reduction - of at least 55% by 2030 compared to 1990 - will need to be met through actions from all areas of society.

St1 Nordic Oy welcomes the initiative of the Commission to review the ETS regulation. As climate change is a global challenge, also the proposed solution for solving it should be designed in a flexible manner to avoid sub-optimization.

Making the European Green Deal a success requires market conditions that favour zero and low-carbon investments. But the “price signal” that the EU Emissions Trading System (ETS) was supposed to set takes a long time to materialise and impact EU emissions, while the ETS remains vulnerable to external shocks, as we have seen with the recent pandemic and halt to many economic activities.

ETS reform as part of a package to collectively increase climate ambition Deutsche Umwelthilfe (DUH) notes that even with a 2030-climate target of 55%, Europe remains off track to reach the Paris Agreement 1.5°C objective. Emission cuts of at least 65% are required for the EU to fully honor its international commitments.

CO2 Value Europe represents the CO2 utilisation community in Europe aiming to develop CO2 re-use as a feedstock for a new industrial sector making a significant contribution to Europe’s low-carbon economy. We call for a financial recognition of CO2 emissions that are avoided through putting CO2 to use in different applications - generally known as CCU (Carbon Capture and Utilisation).

Essenscia supports the European ambition to reach climate neutrality and asks that any increase in the 2030 targets should be chosen in line with this ambition and with realistic innovation evolutions. Further GHG emission reductions will require significant innovation in technologies and energy carriers.

Neste fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. In our view higher targets within the existing legislative framework can deliver these results.

Our vision of EU action has at its core the following objective: a level playing field for European aluminium industry. And a reformed ETS can contribute to this objective through the following measures: - A linear reduction factor that is based on technological breakthrough, technology availability and economic viability of technology - and not on artificial, administrative decision.

The revision of the EU Emission Trading System Directive 2003/87/EC must solve important policy design issues between EU ETS and CORSIA, including the changed world post-COVID-19. An intelligent coexistence of both systems is of utmost importance. Europe should not undermine the credibility of CORSIA. Moreover, airlines should not pay twice for the same single ton of CO2.

Elettricità Futura welcomes a revision aimed at strengthening the EU ETS, in line with the enhanced climate targets. This effort requires a coordinated strategy, where carbon pricing evolves in synergy with other policy instruments. In the next 10 years, the GHG emissions of the power sector are expected to decrease, supporting a parallel strengthening of the LRF.

Climate change is a global and cross-regional challenge. As the challenge does not recognize any borders, also the proposed solution for solving it should be as flexible as possible. The ongoing review of ETS and Effort Sharing Regulation (ESR) initiated by the EU Commission should be conducted as a tightly interlinked integrity with an objective to create a cross-sectoral framework that enables Member States and…

With cogeneration (simultaneous generation in one process of thermal and electrical or mechanical energy), starch plants replace a separate heat-only boiler and full grid power purchase with a solution reducing in many cases CO2 emissions by up to 30%.

The European Trading System would be reformed so that it no longer treats biomass combustion as carbon neutral. This assumption is based on an accounting error that dates to the misinterpretation of IPCC national reporting guidance. In that guidance, countries can ignore the emissions from burning biomass only if they count the carbon removed from a forest or otherwise in the land use sector.

I refer to the entire opinion in annex, which covers all open policy areas and includes general policy considerations. On the revision of the ETS trading system (Directive 2003/87/EC) We support the intention to broaden the policy area of the ETS. However, the energy-intensive installation-based approach based on the polluter pays principle should be maintained.

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Westenergy is a circular economy company from Western Finland. We welcome the opportunity to comment on the Commission’s Inception Impact Assessment roadmap on the revision of the EU ETS directive. Waste to energy (WtE) is a crucial part of the European waste management system and an indispensable component of circular economy.

Boliden consider EU ETS to be the key tool for addressing the reduction of CO2-emissions and protect the competitiveness of the energy intensive industries. We believe that an adequate indirect compensation scheme and free allocation are the optimal way to protect our sector from carbon and investment leakage. Therefore we would like to change the current system as little as possible.

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EU ETS. The primary objective of the ETS revision should be to ensure that the mechanism will provide clear price signals to support decarbonisation meeting the more ambitious climate targets for 2030, as recently revised by the EC.

We strongly recommend the inclusion of municipal waste (MSW) incineration in the EU ETS scheme in the upcoming review. Evidence shows that municipal waste incineration has a growing negative impact on climate, yet because they are not part of the EU ETS or any similar scheme to progressively reduce CO2 emissions, these incinerators are not compensating for the resulting climate damage.

Dear Sir/Madam, The European Emissions Trading Scheme (ETS) is undoubtedly an important tool for reducing greenhouse gas emissions in a market-based environment. Greenhouse gas emissions from the incineration of hazardous waste are rather minor. To date, these installations are excluded from the scope of the Emissions Trading Directive.

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Fertilizers Europe welcomes the possibility to share its views as part of the European Commission’s Inception Impact Assessment of the Amendment of the EU Emissions Trading System. Our main views can be summarized as follows: • The EU fertilizer industry has already an outstanding record in emission reduction and long experience in handling hydrogen and ammonia (which is a raw material for fertilizers and many…

Vattenfall input to European Commission’s Inception Impact Assessment roadmap on the revision of the EU ETS directive. Vattenfall believes that the EU Emissions Trading System (EU ETS) needs to play a central role in achieving the EU’s ambitious climate objectives with regards to the sectors that it covers.

The German Shipowners’ Association (VDR) welcomes the opportunity to provide input to the revision of the EU Emission Trading System Directive of the European Commission. You will find our feedback on the roadmap on the revision of the EU ETS Directive regarding shipping in the attached document.

The Nordic Logistics Association (NLA) represents around 17.000 road transport operators and companies in the Nordic countries. NLA welcomes the green transition and is keen to be a constructive part of the climate solution. To this end, it is crucial with measures to support decarbonisation of road freight.

Eurima shares the vision that the EU ETS has proven to be effective in reducing GHG emissions of energy intensive industries. The Mineral Wool industry itself has undertaken important steps to reduce emissions in the manufacturing process as well as contributing to the transition to climate neutrality through its enabling, energy saving insulation products.

REVISION OF THE EU ETS - POLISH STEEL ASSOCIATION’S CONTRIBUTION TO THE INCEPTION IMPACT ASSESSMENT Introduction The Commission’s Strategic Vision “A Clean Planet for all” indicates that deep CO2 emissions reductions in the steel sector are possible through a combination of technological pathways, including steel recycling, carbon capture utilisation and storage, process integration, and electricity/hydrogen-based…

The Polish Copper Employers’ Association position paper on Amendment of the EU Emissions Trading System (Directive 2003/87/EC) – COMMENTS ON THE INCEPTION IMPACT ASSESSMENT (IIA) Proposal for a directive - Inception impact assessment - Ref.

The French Climate Action Network opposes the proposal to extend the European carbon market (ETS) to the road transport and building sectors, as this proposal contains more social and climate risks than benefits. First, by including these sectors in the HTA, the Commission would consider removing binding national targets from the Climate Effort Sharing Regulation.

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No ETS for waste management The European Emissions Trading Scheme (ETS) is an important tool for reducing greenhouse gas emissions in a market-based environment. In future, it is desirable to focus on relevant point sources and sectors, with appropriate and detailed consideration of the consequences. Greenhouse gas emissions from the incineration of municipal/special waste and substitute fuels are rather minor.

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The Polish Copper Employers’ Association position paper on Amendment of the EU Emissions Trading System (Directive 2003/87/EC) – COMMENTS ON THE INCEPTION IMPACT ASSESSMENT (IIA) Proposal for a directive - Inception impact assessment - Ref.

NHO supports emission trading under a shrinking quota ceiling as the primary mitigation instrument. Moreover, as a tool to lead, attract and eventually merge with trading schemes elsewhere, incentivised by the green development mechanisms, finally leading to a common global carbon price.

The planned revision of the ETS is a good opportunity to account for more GHG emissions stemming from waste management operations. In particular, we feel the incineration of municipal solid waste has so far been unduly excluded. As a result, there has been little pressure to reduce GHG emissions, which would automatically also reduce toxic emissions, ticking the box also for the "zero pollution" ambition of the EC.

The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.

The International Union of Property Owners (UIPI) welcomes the possibility to comment on the revision of the Emission Trading System, in particular its possible expansion to new sectors including to the emissions from buildings as well as from all fossil fuels combustion.

Euroheat & Power (EHP), representing the District Heating and Cooling sector (DHC) in Europe and beyond, is committed to pursuing the full decarbonisation of its European networks, in 2050, to contribute to the goals set out in the Paris Agreement (see our sector’s pledge). EHP also supports a higher ambition for 2030 to set the EU on track to carbon neutrality by 2050.

As the recognized representative of the European mineral raw materials industry, covering more than 42 different metals and minerals and employing 350.000 directly and about four times as many indirectly, the first segment of most strategic value chains and a critical supplier of materials vital for a transition to a low-carbon society, Euromines welcomes a European Green Deal and is prepared to take the necessary…

COFALEC, the European federation of Yeast producers, welcomes the initiative to review the EU Emissions Trading System Directive to align with the challenging -55% GHG reduction target by 2030 and to achieve carbon neutrality by 2050. COFALEC agrees with the proposal to broaden the scope of ETS to involve more economic sectors as we share the opinion that the efforts should be supported among the highest numbers.

The EU-ETS is one of the world’s foremost carbon pricing systems. It represents a significant political achievement in establishing the EU’s primary climate legislation. It has evolved over the years and now has the political attention and public demand for further ambition to meet the concerns of citizens regarding the latest science.

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on imported oil.

The EU-Commission has recently acknowledged the importance of critical minerals and metals for the green transition. Sweden has resources of more than 50% of the critical raw materials identified by the Commission. The Swedish Association of mining, minerals and metal producers, Svemin, has already adopted a roadmap to reach fossil-free mining operations by 2035 and climate neutral processing by 2045.

EU ETS should continue to play a pivotal role for the protection of European industry against the risk of carbon leakage UNIDEN represents French energy intensive industrial consumers where energy is a major component of operating costs and directly affects competitiveness.

The EU needs to cut emissions by at least 65% in 2030 to honor the Paris Agreement objective of keeping global temperature rise to 1.5°C. In order to deliver the necessary emission reductions in a socially fair and cost-effective manner, a holistic and comprehensive approach towards the entire policy architecture is needed.

Eurits is an association of hazardous waste management companies across the EU. Its membership represents over 90% of the hazardous waste incineration sector in the EU and includes some of the world’s largest waste management companies. Eurits fully supports the ongoing actions towards climate neutrality and welcomes the opportunity to provide its input - Please find our comments in the attached document.

The Norwegian Oil and Gas Association is of the opinion that the EU EUS should continue to be the main climate policy tool in Europe. A strong ETS incentivizes substitution of coal by gas, which will contribute to reduce emissions substantially.

The EU Emissions Trading Scheme, EU ETS, aims to reduce fossil emissions in the most cost-effective way. But this is not possible for industries and energy production plants that use fossil gas as a fuel and gradually choose to switch to renewable gases such as biogas or bio-LPG. The reason is that there are shortcomings in the current EU ETS regulations.

The WVMetalle commented on a number of points mentioned in the Inception Impact Assessment on the revision of the ETS Directive. Linear reduction factor (LRF): According to the Commission, the LRF, which will increase from today’s 1,74 to 2,2 in 2021, needs to be further increased as the EU is expected to agree on a 2030 climate target of 55 % instead of 40 %.

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In general, UPEI supports the EU ETS as a market-based and cost-effective tool to reduce GHG emissions, in light with the EU carbon neutrality objective. We see the ETS and ESR as complementary measures to address climate change. In principle, the ETS applies to the organisations directly responsible for the actual CO2 emissions.

The FIA European Bureau supports the ambition of the European Union to become climate-neutral by 2050, including the greenhouse gas reduction target of 55% in 2030. To reach that goal, important adjustments are necessary in all areas of society. Road transport is part of the solution to reach the set goal.

The Spanish magnesia association (MAGES) welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment for the “Amendment of the EU Emissions Trading System” to be adopted Q2 2021. MAGES is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and support the objectives of the European Green Deal.

The Spanish Cement Association (Oficemen) welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment for the “Amendment of the EU Emissions Trading System” to be adopted Q2 2021. The Spanish cement sector is determined to contribute strongly to the EU’s vision for a carbon neutral society by 2050 and support the objectives of the European Green Deal.

The Japanese Shipowners’ Association (JSA) appreciates this opportunity to comment on ‘the Inception Impact Assessment for the proposed Amendment of the EU Emissions Trading System (EU-ETS)’, in particular the proposal to extend the EU-ETS to maritime transport. Please see the attached document.

We strongly recommend the inclusion of municipal waste (MSW) incineration in the EU ETS scheme in the upcoming review. Evidence shows that municipal waste incineration has a growing negative impact on climate, yet because they are not part of the EU ETS or any similar scheme to progressively reduce CO2 emissions, these incinerators are not compensating for the resulting climate damage.

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (Escos), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services.

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Whilst the EU ETS price has seen a significant increase over the recent years, the carbon market is not yet resilient to external factors, and so a stable and growing carbon price is not guaranteed. As the European coal phase-out accelerates, and wind and solar become the cheapest energy source across most of Europe, the gap between the ETS cap and real emissions will continue to grow.

Hellenic Lime Association considers EU-ETS as the legislation that is going to have the most profound impact on the Lime Industry in the coming years. In order to comply with the climate neutrality ambition of EU for 2050, our sector needs to invest in new expensive technologies, resulting in a huge transformation of our industry.

To meet the Paris 1.5 °C objective, the EU needs to reduce its emissions by at least 65 % by 2030. Reductions should be socially and economically fair, requiring a comprehensive approach to the whole policy architecture. ETS is only one element of a package and needs to be complemented by a significantly robust set of climate and energy policies. To this end, the ETS and ESRs need to be strengthened.

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Environmental Defense Fund (EDF) and Environmental Defense Fund Europe (EDFE) thank the European Commission for the opportunity to comment on the Commission’s update on the EU’s emissions trading system (EU ETS).

DTEK welcomes the unequivocal commitment by the leadership of the EU and Ukraine to strengthen the political association and economic integration of Ukraine with the European Union as defined in the Joint statement following the EU-Ukraine Summit on 6th October, 2020. Being the leader in the energy sector in Ukraine, DTEK reconfirms its ambition and continuing efforts to deliver real positive changes on the ground.

OUR CALLS Priority 1: inclusion of CCU into the EU ETS The EU ETS directive must equally encourage CCU, which is indispensable to liaise climate objectives and circularity. The European Court of Justice has already two times (Case C-460/15 and Case C-561/18) decided that the EC should not include CO2 that is subsequently chemically bound and not emitted to the atmosphere in the CO2 emissions reporting in the ETS.

This submission is on behalf of Drax Group Plc. Negative Emissions Through Bioenergy with CCS (BECCS) The European and indeed, the global, consensus is that achieving climate neutrality will only be possible with negative emissions, for example through the deployment of technologies such as bioenergy with CCS (BECCS).

The Coalition for Energy Savings would like to thank the Commission for the opportunity to provide feedback to the roadmap on amending the Emission Trading System. Carbon pricing is an instrument that can complement energy efficiency support schemes and regulatory actions to deliver energy savings. It can make investments in energy efficiency improvements more attractive.

E4FC supports the ambition of the EU to reduce carbon emissions. European airlines have long been working to reduce their CO2 output with investments in new aircraft and technologies, the development and use of sustainable aviation fuels, operational improvements and the participation of aviation in the EU Emissions Trading System (ETS) as well as the global carbon offsetting program, CORSIA.

The EU needs to cut emissions by at least 65% in 2030 to honor the Paris Agreement objective of keeping global temperature rise to 1.5°C. In order to deliver the necessary emission reductions in a socially fair and cost-effective manner, a holistic and comprehensive approach towards the entire policy architecture is needed.

ZWE welcomes the opportunity to provide feedback on the revision of the EU Emissions Trading Scheme (ETS). As the EC inception impact assessment states, we will need to decarbonise our industries in the coming decade in order to achieve climate neutrality by 2050. EU ETS currently covers only 38 % of total greenhouse gas emissions in the EU.

Energy Norway represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting, or trading electricity. Our members produce 130-140 TWh annually, which is around 95 percent of all power production in Norway. Our members have approximately 2.5 million grid customers, which is about 90 percent of Norway's grid customers.

Thank you for the opportunity to provide feedback on the inception impact assessment for Amendment of the EU Emissions Trading System (Directive 2003/87/EC). This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association consisting of sustainable biomass producers in the Southeast US as well as others in the bioenergy supply chain – www.theusipa.org.

BEUC is sceptical about a possible inclusion of road transport and heating within ETS. Such carbon-pricing tool must be analysed in regard to the impact on low-income consumers and their financial capacity to switch to more sustainable ways of moving around/heating their house.

We don’t agree with extension of emissions trading to emissions from building and road transport or all fossil fuels combustion. Addition building and road transport sectors to the emission trading would have little additional impact on emissions from these sectors, but would significantly increase living costs for poorer households.

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment for the EU ETS revision. We would like to highlight the following points to consider: 1. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the climate policy framework is a great opportunity to clarify incentives for CRT.

VIK welcomes the opportunity to participate in the consultation on the roadmap to update the EU Emissions Trading Scheme and supports the EU Commission's discussion on an improved emissions trading scheme. It must be ensured that the planned reform of emissions trading does not lead to a disproportional, additional cost increase for industrial installations in Europe, and thus to a decrease in competitiveness of the…

Maritime Transport as Part of Ambitious Climate Policy Confederation of Finnish Businesses EK supports 1,5 degree climate policy and Paris agreement. Reducing emission in shipping is tightly linked with the competitiveness of industrial sectors that trade in global markets. The regulation should take place at global level in IMO to provide level playing field in maritime markets.

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the Amendment of the EU Emissions Trading System (EU ETS) and the opportunity to provide feedback. The wood-based panels industry believes that this initiative will be a key element in implementing a coherent framework to allow the objectives of the European Green Deal to be achieved, to combat climate change and to achieve climate…

The SWM support the EU’s long-term decarbonisation objectives and support the strengthening of emissions trading. It has a steering effect with the CO2 prize and provides incentives for low-carbon investments. Due to its high cost efficiency, this market-based climate instrument is the most favourable option for reducing emissions. There is thus a clear signal for a rapid expansion of renewable energies.

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The Government of the Republic of Korea welcomes the opportunity to comment on the Inception Impact Assessment on the proposed Amendment of the EU Emissions Trading System (EU-ETS) (Directive 2003/87/EC), in particular on the proposal to extend the EU-ETS to maritime transport. Please find attached the document for details.

UVP Environmental Management and Engineering GmbH is an environmental consulting and process engineering company with 30 years of experience in the waste treatment and waste incineration sector, located in Vienna, Austria.

I. Introduction: The EuroChem Group (https://www.eurochemgroup.com) is a vertically integrated and leading international manufacturer of mineral fertilizers. EuroChem operates numerous fertilizer production, distribution, logistics and research facilities throughout Europe, Americas, Asia, Russia and the CIS.

CEZ Group can support an increase of the GHG target to 55 % by 2030. However, we expected that the impact of increasing the GHG target to at least 55 % by 2030 on different Member States would be analysed in the Impact Assessment that the EC presented in September. Unfortunately, it only assessed the impact on the EU as a whole.

The following aspects should be taken into account in the upcoming update of EU ETS: To assure the level playing field between EU and the rest of the world and to avoid carbon leakage, it is utmost important that the new environmental regulation is implemented simultaneously in all marine areas of the world (IMO timetable). No EU-wide ETS for maritime transport should be created.

Contribution to the Inception impact assessment (IIA) on the updating the EU emissions trading system (ETS) The CMA CGM Group Led by Rodolphe Saadé, the CMA CGM Group is a world leader in shipping and logistics. Its 489 vessels serve more than 420 ports on five continents around the world and carried nearly 22 million TEUs (twenty-foot equivalent units) in 2019.

Decarbonisation price signals and a level playing field for all the available energy supply options are essential to tackle emissions and increase efficiency, both for consumers and emitters. The price of products must internalise their total environmental cost so those with a lower carbon footprint become more competitive.

The revised Waste Directive 2008/98/EC (WFD) requires the landfilling of municipal waste to be limited to a maximum of 10 % and a significant increase in the actual recycling of municipal waste to at least 65 %. This is wrongly understood in the Czech Republic as a requirement of the Directive to increase the proportion of municipal waste incineration with energy recovery.

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A successful, cost efficient translation of Europe´s political climate ambition into action depends on a holistic and consistent mix of policy instruments. The revision of the ETS Directive should be closely tied in with the revision of the ESR, the ETD and RED, the State Aid Guidelines (EEAG) or any possible CBAM proposal.

Gas Networks Ireland (GNI), and its parent company Ervia, welcome the opportunity to provide feedback on the ‘Climate change – updating the EU emissions trading system (ETS)’ Inception Impact Assessment consultation. We fully agree that the ETS “has proven to be an effective tool in reducing greenhouse gas” and we support the aim to “provide a consistent carbon price signal across the Single Market”.

Business Finland is the Finnish innovation funding, trade, investment, and travel promotion organization, fully owned by the Finnish government. We recognize the strategic importance of the EU emission trading system. The ETS as a market-based instrument has proven effective and cost-efficient in driving down industrial and energy-sector emissions.

Glass for Europe welcomes the opportunity to comment on the roadmap leading to the review of the EU ETS Directive to align with the 2030’s new climate target. The roadmap announces that an assessment is conducted to evaluate how the increased ambition in the EU ETS and the extension of its scope may impact the risk of carbon leakage in the different industrial sectors.

We strongly recommend that municipal waste (MSW) incineration is included in the upcoming review of the EU ETS. Evidence shows that municipal waste incineration has a growing negative impact on climate, yet because they are not part of the EU-ETS or any similar scheme to progressively reduce CO2 emissions, these incinerators are not compensating for the resulting climate damage.

The German chemical industry supports the 2050 target. In addition to reducing greenhouse gas emissions through the EU emissions trading scheme, the sector also actively contributes with its products to climate protection in other sectors. The “Roadmap Chemie 2050” study (https://bit.ly/32Cizl8) shows that greenhouse gas neutral production is possible by 2050.

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If the EU unilaterally tightens up climate and energy policy targets, significantly strengthened protection measures for Industry are needed, because their pressure to shift is growing due to increasing energy and climate costs. Expanding the ETS as guidance instrument for investment in the location and the climate protection is necessary.

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment of the EU Emissions Trading System (IIA). This EU ETS revision is interlinked with simultaneous public consultation on Inception Impact Assessment to Amendment of Regulation (EU) 2018/842 on binding annual greenhouse gas reductions by Member States from 2021 to 2030…

ㅇ UNFCCC adopted the Kyoto Protocol at the 3rd General Assembly of the Parties (COP) and designated IMO as the governing body for the reduction of greenhouse gas emissions for international shipping. We are concerning that EU regional regulations may cause difficulties in establishing IMO's greenhouse gas reduction policies.

Hazardous Waste Europe (HWE) is a European wide association whose members operate all the diversity of hazardous waste treatments from recycling to final disposal including dedicated hazardous waste incineration. HWE recognizes and endorses the urgent necessity to bring more efforts for achieving the targets of the Paris agreement and specifically the EU commitment for carbon neutrality in 2050.

Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. ETE Members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply.

Fortum wants to highlight the following issues as the key in the upcoming revision of the Emissions Trading Directive and related Impact Assessment. More detailed feedback is available in the attached file. Allocation of the revised 2030 target between the ETS and non-ETS sectors Following the adoption of the new 2030 emissions reduction target, the Commission needs to prepare a holistic analysis on the most…

The Sustainable Development Goals are the guidelines for the German Confectionery Industry. Goal 13 (Climate action) is key. Therefore we support the EU’s ambition to be climate-neutral by 2050. So far the Emission Trading System (ETS) has been one of the effective instruments to reduce GHG emissions.

As a non-governmental organisation working on the topics of the circular economy and sustainable production and consumption, we call for the inclusion of waste incineration plants called thermal waste treatment facilities in the EU ETS. Studies show that waste incineration has a negative impact not only on the circular economy, emissions, but also on the climate.

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PCCDS - Palestine, welcomes the ambitious “European Green Deals” (EUGD) and Hoping to use experience exchange with Mediterranean countries as an important partner in implementing projects related to reducing carbon emissions and increasing vegetation cover through greater reliance on income-generating green projects that increase the share of the European Union in poverty eradication in the Mediterranean countries.

ESPO and European ports welcome Europe’s ambition to be the world’s first net zero emission area by 2050. Achieving the ambitions of the European Green Deal for 2030 and 2050 should be the driver of EU policy. This is especially true for the shipping sector, where finding the most effective ways to deliver on the Green Deal will require ambitious action on the European level.

The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose specialization corresponds to the focus of the CGA.

The European Network of Transmission System Operators for Gas (ENTSOG) believes the EU Emissions Trading System (ETS) can give clear price signals to support decarbonisation and to meet the more ambitious climate targets for 2030, recently laid out by the EU Commission. ENTSOG recognises the need to adapt the EU ETS to align with these targets and possibly extend the scope of the EU ETS.

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050.

Recycling is a crucial part of the Circular Economy Action Plan and the European Green Deal. Establishing a even more effective circular economy and saving emissions also depends on the benefits of recycling. These emission saving benefits have to be considered within a EU ETS that is discussed to cover the waste sector as well.

SEA Europe welcomes the ambition of the European Commission’s “European Green Deal” (EUGD) which is in line with that of the European “Waterborne” Technology Platform (https://www.waterborne.eu/), which aims at providing solutions by 2030, applicable for all main ship types and services, in order to achieve zero-emission waterborne transport by 2050.

I would like to comment on a necessary adaptation of the ETS system with regards to future CBAM for cement (clinker) import in Europe. In our opinion, Europe should not create a situation where Europe cement companies are given free CO2 allowances, basically letting them pollute, and on the other hand enforce taxes on the same goods that are imported because they are polluting.

As we are in unprecedented times regarding climate change and biodiversity loss, we should take adequate measures to counter these challenges. An expansion of a success case - EU emissions trading system (ETS) would be a very timely and welcoming move. First, by removing exceptions that are applied to MSW and hazardous waste incineration facilities.

“The European Emissions Trading Scheme (ETS) is an important tool to reduce greenhouse gas emissions in a market-based environment. The greenhouse gas reduction of the ETS was around 36 % in 2019 compared to 2005. This is close to meeting the ETS reduction target of — 43 % by 2030. The ETS therefore works very effectively.

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