Revision of the benchmark values for free allocation of emission allowances (2026-2030)

Carbon Management Europe (previously known as Zero Emissions Platform) welcomes the opportunity to provide feedback on the proposed revision of the benchmark values for the free allocation of emission allowances under the EU ETS between 2026-2030.

Fertilizers Europe thanks the Commission for the opportunity to comment on the proposed EC implementing regulation determining revised benchmark values for free allocation of emission allowances for the period 2026 to 2030. Our comments are in the attached document.

**Opinion on the update of the EU ETS benchmarks** Medium-sized energy-intensive industry in Germany is facing a historically unprecedented crisis. High energy costs, additional CO costs, regulatory burdens and persistent uncertainties threaten Europe’s competitiveness, investment capacity, employment and industrial value creation.

Filed in German · English published by the European Commission

The European Lime Association (EuLA) appreciates the opportunity to provide feedback on the draft Commission Implementing Regulation determining revised benchmark values for free allocation for the period 20262030 pursuant to Article 10a(2) of Directive 2003/87/EC. EuLA acknowledges that the Commission has applied the benchmark methodology established under Article 10a ETS Directive as currently legislated.

Confindustria Emilia-Romagna expresses strong concern regarding the European Commissions proposal to update ETS benchmarks for the 20262030 period, which risks significantly increasing costs for European industry at a time already characterised by high energy prices, growing international competitive pressures, and the limited availability of mature technologies for the decarbonisation of hard-to-abate sectors.

Vidrala welcomes the opportunity to comment on the draft Implementing Regulation (Ref. Ares(2026)4752349) revising EU ETS benchmark values for 2026-2030. As a principal European container glass producer, we have a material interest in their calibration. A full position paper is attached. The draft treats container glass more stringently than any comparable hard-to-abate sector.

Lopes d’Granó has made an active commitment to reducing greenhouse gas emissions and has made relevant investments in modernising production processes and gradually replacing fossil fuels with renewable energy sources. Today, more than 95 % of the thermal energy used in the installation originates from sustainable biomass, which is the result of a decarbonisation strategy developed over several years.

Filed in Portuguese · English published by the European Commission

The Ministry of Environment and Energy (Maen) argues that any substantial change to the methodology for defining benchmarks should be discussed as part of the revision of the Directive, on the basis of a comprehensive impact assessment that takes into account the specificities of the different sectors and ensures regulatory consistency and predictability.

Filed in Portuguese · English published by the European Commission

The Confederation of Swedish Enterprise supports the EU ETS as the cornerstone of European climate policy. A well-functioning ETS must provide an effective and predictable investment signal for industrial decarbonization, while ensuring effective protection against carbon leakage for sectors exposed to global competition.

The Bulgarian Industrial Association (BIA), representing more than 130 sectoral industrial organisations, welcomes the opportunity to provide input on the draft Implementing Regulation revising EU ETS benchmark values for free allocation for 2026-2030. BIA supports the EU's climate objectives and the ETS's role as a key decarbonisation instrument.

Concerning: Contribution to the public consultation on the revision of the benchmarks for free allocation of emission allowances (2026-2030) A.MERATI & C. Italian paper company with plant in Laveno M wishes to contribute to the consultation by expressing strong concerns about the proposed revision of the ETS benchmarks.

Filed in Italian · English published by the European Commission

Cetipal supports the climate objectives of the European Union and recognises the key role of the EU ETS in promoting the transition to a low-carbon economy. Our company has been making significant investments in decarbonising its production processes.

Filed in Portuguese · English published by the European Commission

CIRFS is the association for Europes 12 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2023 of ca.

Review of ETS Benchmarks 2026-2030: Ensuring a climate transition that is compatible with the competitiveness of the European glass industry Aive supports the European Emissions Trading System (ETS) as the European Union’s main instrument to promote efficient and economically sustainable decarbonisation.

Filed in Portuguese · English published by the European Commission

The Finnish chemical industry is committed to achieving climate neutrality by 2045 and supports the EU Emissions Trading System as a key, long-term and cost-efficient instrument for driving emission reductions. At the same time, it is essential to ensure that industrial competitiveness is preserved and that effective carbon leakage protection remains in place throughout the transition.

Polish Confederation Lewiatan is a national business federation which brings together over 4,100 companies employing over a million employees. We welcome the European Commissions initiative to review the benchmark values for free allocation of emission allowances (2026-2030) but we feel obliged to submit our critical position below.

K+S welcomes the opportunity to provide feedback on the Revision of benchmark values for free allocation under the EU ETS. K+S raises concerns and strongly recommends to change the proposal and to freeze the benchmarks at the 2025 level as the proposed reduction of the heat and fuel benchmarks is technically not achievable with best available technologies in the potash sector.

ARCH SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Feedback to the European Commission Revision of benchmark values for free allocation of emission allowances (20262030) As a French TiO producer, we wish to express our concerns regarding the proposed revision of the fuel and heat benchmarks.

Although Porcelanas da Costa Verde is not directly covered by the EU ETS regime, it follows ongoing developments with great concern, as it is part of the European ceramic industry's value chain and shares the structural and competitive challenges affecting the entire sector.

CAN Europe welcomes the opportunity to contribute to the public consultation process on the draft implementing act revising the benchmark values for the period 2026-2030. These values will determine the quantity of allowances that will keep on being allocated for free to industries, which between 2021 and 2024 were still covering on average 97% of industrial emissions.

VKS Verband der Kali- und Salzindustrie e.V. (German Potash and Salt Industry Association) submits the attached position paper on the revision of benchmark values for the free allocation of ETS allowances (20262030). Our member companies are directly affected by both fallback benchmarks heat and fuel.

APICER (Cristalaria) expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

France Industrie fully supports the EU objective of achieving climate neutrality by 2050 and recognises the key role of the EU Emissions Trading System (EU ETS) in driving industrial decarbonisation. However, the effectiveness of the ETS depends on its ability to balance climate ambition with industrial competitiveness, particularly for sectors exposed to international competition and carbon leakage risks.

Lenzing AG welcomes the opportunity to contribute to this consultation. The full position, including detailed technical input and recommendations regarding ETS I benchmark adjustments for 20262030, is provided in the attached document. We kindly ask the European Commission to consider the arguments and evidence outlined therein.

ARTÍSTICAS Faiiras Bordalo PINHEIRO, SA expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Sandbag welcomes the opportunity to contribute to the public consultation on the European Commissions proposed revision of the benchmark values of free allocation of emission allowances (2026-2030). This response to the Commissions public consultation outlines a sector-by-sector analysis of the Commissions proposal.

FEDENE brings together six professional associations that work to improve energy efficiency and building services, decarbonize heat and cold production using renewable and waste heat, in cities, housing, the tertiary sector, and industry. Its 1,500 local companies, covering the entire value chain and spreading across the country, employ 50,000 people in France. Please find attached FEDENE's feedback.

Moeve welcomes the European consultation of stakeholders on the Implementing Regulation determining revised EU ETS benchmark values for the 2026-2030 period, welcoming the Commissions proposed approach to implement the removal of exchangeability as a driver of electrification, but reflecting it in the review of the BM coherently, yielding consistent improvement speeds.

WWF European Policy Office (EPO) welcomes the opportunity to contribute to the European Commissions public consultation on the proposed revision of the EU ETS Benchmarks Regulation for the 20262030 period, as foreseen under the 2022 revision of the EU Emissions Trading System (EU ETS).

The Ceramic and Glass Technology Centre (CTCV) is concerned about the proposed revision of the benchmarks for free allocation under the EU Emissions Trading System (EU ETS) for the 20262030 period. The ceramic and glass industries have made continuous efforts and significant investments in energy efficiency, greenhouse gas emission reductions, and the development of decarbonisation technologies.

Assofond (Associazione Italiana Fonderie) represents the Italian foundry industry, which consists of around 870 companies, 23.300 employees and an annual turnover of around EUR 6.6 billion. The association is also a member of the European Federation of Foundries (EFF). Assofond expressed strong concern about the proposed reduction of the ETS benchmark for cast iron foundries.

Filed in Italian · English published by the European Commission

UNIDEN welcomes the possibility of giving its feedback on the draft Commission implementing regulation on the EU ETS benchmark values for the period 2026-2030. The draft values of the product-specific benchmarks seem, in most but not all of the cases, consistent with the expectations of the sectors covered by EU ETS.

FEAF is a business federation that brings together 200 companies in the foundry sector in Spain, which employ 16,000 workers directly and 72,000 indirectly. Its members are key suppliers to sectors such as the automotive industry, infrastructure, energy, and machinery. 1. The proposed benchmark reduction is not based on a statistically representative population.

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

The revision of EU ETS benchmark values for 20262030 should strengthen carbon leakage protection for energy-intensive industries facing high energy and carbon costs, geopolitical uncertainty and global competition. The current proposal fails to do so. 1.

The Association of Chemical Industries of Slovenia recognises the importance of decarbonisation and the objectives of the EU ETS. At the same time, achieving these objectives in practice requires climate measures that take into account the industrys actual technological and economic capacities, as this is essential for the long-term competitiveness of the European economy and should therefore be reflected in a…

Cabot Corporation (Cabot) supports the position of the International Carbon Black Association (ICBA) that the proposed revised EU ETS benchmark for carbon black is not representative of sector conditions, and does not reflect the limited near-term decarbonization potential of this hard-to-abate sector.

The proposal for the revision of the ETS benchmarks for the period 20262030 presents significant problems for the construction sector, with the risk of producing economic and industrial effects that are not proportionate to the concrete possibilities for reducing emissions currently available.

Filed in Italian · English published by the European Commission

EXCA underlines the importance of transparency in the benchmark update exercise and encourages the publication of additional information supporting the benchmark calculations, including the number of installations covered, the benchmark distribution and the methodology used to identify the 10% most efficient installations.

The ETS 2 should be revised as appropriate. This penalises certain sectors that are already inherently sustainable, such as passenger transport by bus and coach. Travelling by bus is one of the most sustainable modes of transport, even if the vehicle is powered by traditional fuels, as it has significantly lower average emission levels per passenger transported than a private car.

Filed in Italian · English published by the European Commission

The IREN Group is currently involved in the ETS mainly through its thermoelectric generation and district heating activities. While reaffirming our support for the Unions climate objectives, we believe that the current revision raises significant concerns in terms of industrial sustainability, proportionality, and the overall coherence of the regulatory framework.

The Business for CBAM Coalition calls for immediate publication of the 2026-2030 EU ETS product benchmarks. Companies across energy-intensive sectors must finalise investment decisions now to achieve 2030 climate goals, and prolonged uncertainty risks undermining the ETS's ability to provide the investment certainty needed. The Coalition advances three substantive positions: 1.

District heating and cooling (DHC) supplies around 13% of Europe's heat demand and serves more than 80 million EU citizens. As a flexible, locally anchored solution, it can rapidly integrate renewable energy, waste heat, and clean technologies. Over 44% of the heat in DHC systems is already decarbonised. Euroheat & Power fully supports the EU's climate objectives and a well-functioning ETS.

L'Afep, together with MEDEF and France Industrie, shares the European decarbonisation ambition and recognises the central role of the European Union Emissions Trading System (EU ETS) in the European climate strategy to steer industrial investments towards decarbonisation. This transition cannot take place at the cost of weakening European and French industrial competitiveness.

Perpetua, Pereira and Almeida, Lda expressed deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Confindustria is deeply concerned about the Commissions proposal to update ETS benchmarks for the 2026-2030 period, which risks significantly increasing costs for European industry at a time of high energy prices, growing international competitive pressure and limited availability of mature and scalable decarbonisation technologies, especially for hard-to-abate sectors.

The regular update of the benchmarks values for free allowances under the EU ETS is a necessary step to ensure that the last years of the free allocation system are fully coherent with the aim of a full phase-out by 2034 for all sectors, and provide the investment signals necessary to funnel funding into industrial decarbonisation.

MEDEF, together with AFEP and France industrie, shares the European decarbonisation ambition and recognises the central role of the European Union Emissions Trading System (EU ETS) in the European climate strategy to steer industrial investments towards decarbonisation. This transition cannot take place at the cost of weakening European and French industrial competitiveness.

Dear Members of the European Commission, please find attached a position paper of IFIEC Europe International Federation of Industrial Energy Consumers to the EU public consultation Revision of the benchmark values for free allocation of emission allowances (2026-2030).

SUMMARY: Bellona welcomes the opportunity to provide feedback on the revision of EU ETS benchmark values for free allocation in the 20262030 period. Bellona has consistently advocated for benchmark reforms that reward genuinely low-carbon production pathways based on actual carbon performance rather than production process.

Solvay welcomes the possibility of giving its feedback on the draft Commission implementing regulation on the EU ETS benchmark values for the period 2026-2030. Product-specific benchmarks: We have no remark on the draft values of the product-specific benchmarks itself but on the process applied for updating the values. This process is not transparent enough.

The Spanish fired clay brick and roof tile manufacturing industry, represented by HISPALYT, expresses its deep concern regarding the Commission's proposed Implementing Regulation for determining benchmark values for the free allocation of emission allowances for the 20262030 period and, in particular, regarding the reduction of the benchmark values for fuel and heat under the alternative methodologies.

The European Foundry Federation (EFF) represents the national foundry associations of 22 European countries, covering approximately 4,000 foundries and nearly 200,000 employees. Although only 22 iron foundries are currently covered by EU ETS1, these installations account for around 40% of European iron casting production and are therefore highly significant for the sector. 1.

This submission addresses a structural flaw in the EU Emissions Trading System that creates a concrete risk of double allocation within the synthetic soda ash/glass value chain. This risk, if left unaddressed, would undermine the environmental integrity of the system and distort competition across the value chain.

The SOCILÉGUA PROMOÇÃO IMOBILIÁRIA LDA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

We propose that, as part of finalising the implementing regulation, the Commission should include a methodological verification of the representativeness of the 20212022 reference period used for updating the heat and fuel benchmarks for the 20262030 period.

Dear Mr/Ms, With regard to the public consultation on the revision of the ETS benchmarks for the period 2026-2030, Marazzi Iberia SLU, Spain ceramic tiles sector, would like to express the following considerations. The published benchmarks show a level of ambition that currently does not correspond to the operational conditions and the current energy context at European level.

Filed in Spanish · English published by the European Commission

IGBCE Opinion on EU Benchmark Adjustments 20262030 IGBCE supports the EU’s climate objectives and the transition to net-zero industry. Energy-intensive industries are key drivers of industrial value creation and indispensable for the decarbonisation of other sectors. This requires a realistic regulatory framework that enables investment and ensures competitiveness.

Filed in German · English published by the European Commission

The upcoming EU ETS benchmark reductions and the introduction of CBAM place significant cost and competitiveness pressures on Europes energyintensive industries. The 34% heat benchmark cut and the 50% fallback reduction do not reflect realistic technological improvement potential. Delays in sectorspecific benchmarks create further uncertainty. High natural gas and CO allowance prices distort markets.

The paper in attachment contains essenscias position on the draft implementing regulation on Benchmark updates for the period 2026-2030, published on the 11th of May by the commission. The update of EU-ETS benchmarks for the 2026-2030 period will play a key role in ensuring that Europe can maintain a strong industrial base while delivering on its climate ambitions, thereby avoiding further deindustrialisation.

The Association of Industrial Unions and Transport (APZD) provides feedback on the draft Commission Implementing Regulation determining revised benchmark values for free allocation of emission allowances under the EU ETS for the period 2026-2030. We attach the full opinion of the APZD as an annex. The APZD supports the EU’s climate objectives and the need to progressively decarbonise industry.

Filed in Slovak · English published by the European Commission

On Behalf of Marazzi Poland, we express our concern for the revised benchmarks related to the Ceramic sector. The Fuel and Spray-dried Powder benchmarks are indeed too low, these emission levels are not presently achievable by most installations.

Lucart fully shares Assocarta’s concerns regarding the proposed revision of the ETS benchmarks and believes that the lines of action identified by Assocarta go in the right direction. (A) Benchmarks and fallback parameters: In particular, it stresses the importance of: — maintain a uniform approach between product benchmarks and fallback benchmarks, avoiding differentiated interventions that could generate…

Filed in Italian · English published by the European Commission

Please find enclosed FEIQUEs (Federación Empresarial de la Industria Química Española) response to the ETS benchmark update for 20262030. While reaffirming its support for the EUs climate objectives, FEIQUE raises concerns about the proposed reduction of fallback benchmarks, calls for the development of sector-specific fallback benchmarks where decarbonisation alternatives are not yet available at scale, and…

Metsä Group has serious concerns regarding the Commissions proposal to update the benchmark values and the recent decision to exclude installations based on the 95% threshold from the European Union Emissions Trading System (EU ETS) for the period 2026-2030.

The proposed 50% reduction to the heat and fuel fallback benchmarks would lead to levels that are unsustainable for European copper smelters, refiners, and semi-fabricators. This would weaken the EU's capacity to maintain and increase copper production, invest in decarbonisation, and strengthen its value chains.

The position of the SP ČR on the proposal to revise the benchmarks for calculating the free allocation of emission allowances The Confederation of Industry appreciates the opportunity to comment on the proposal for a Regulation establishing revised benchmarks for the free allocation of emission allowances for the period from 2026 to 2030 pursuant to Article 10a(2) of Directive 2003/87/EC of the European Parliament…

Filed in Czech · English published by the European Commission

Contribution of UNESID Spanish Steelmaking and Steel Transforming Association UNESID welcomes the opportunity to comment on the draft Commission Implementing Regulation revising the ETS benchmark values for free allocation in 2026-2030. The full UNESID position is attached as an annex. This summary focuses on one issue: the proposed fuel fallback benchmark.

Dear colleagues. Below please find attached our feedback. On one hand, we do not support the 2026-2030 benchmarks (BMs) as proposed by the COM, especially due to the fall-back BMs values. There is an extreme variability of installations using such BMs, both from the size and processes side, that one common BM value is totally irrelevant and can significantly and unjustifiably harm many installations.

The inclusion of biomass, cogeneration, and heat from exothermal processes within the benchmark conflicts with ETS principles of technological neutrality and equal treatment. The sites considered as benchmark-setters are statistical outliers that do not represent the availability and technical viability of these low carbon heat sources for the majority of sites.

The ceramics industry in Bulgaria is highly dependent on the allocation of free emission allowances and, accordingly, on the methodology used within the EU Emissions Trading System (EU ETS). In this context, we have been closely monitoring the proposed updates with growing concern.

AURA AERO and VÆRIDION welcome the European Commissions initiative to consult industry stakeholders and citizens for the revision of the allowances for European Union Emissions Trading System (EU ETS). This initiative coincides with a unique and time-sensitive window for European aviation policy.

The ceramics industry in the Republic of Bulgaria is directly dependent on free carbon allowances and, consequently, on the methodology for their determination within the EU Emissions Trading System (EU ETS). In this regard, KHAN ASPARUH AD closely monitors with concern the ongoing discussions regarding the proposed ETS benchmark for the ceramics industry for the period 20262030.

LEIPA is directly affected by the continuous reduction of free allocation under the EU Emissions Trading System ('EU ETS'). The adjustments currently envisaged as part of the benchmark update for the 20262030 period would further and significantly impair the competitiveness of the European paper industry.

The heating and cooling sector represents significant decarbonization potential in Europe, accounting for 50% of energy consumption and 27% of CO emissions. District heating and cooling (DHC) networks currently serve over 7 million Europeans, with 42.6% of energy sourced from renewables and waste heat.

Aluminium France support the European Aluminium federation position and asks to the commission : A freeze of the Primary Aluminium and Pre-bake anode product benchmarks to 2021-2025 levels. Meanwhile, in the upcoming ETS Revision, Primary aluminium via electrolysis and the Precursor Pre-Bake anodes should continue to have their own product Benchmarks according to the product benchmark methodology currently in force…

VASICOL DE barro VERMELHO, LDA. expresses its deep concern about the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Germany’s medium-sized energy-intensive industry is facing a historically unprecedented crisis, leading not only to the outward movement of production, but also to plant closures and job losses. Energy-intensive small and medium-sized enterprises are committed to the European Union’s climate goals and want to follow this path by 2050.

Filed in German · English published by the European Commission

Cosentino, as an undertaking linked to the production of ultra-conventional sintered surfaces, wishes to express its concerns about the draft implementing regulation on updating the ETS benchmarks for the period 2026-2030 and, in particular, about the proposed reduction for the fuel benchmark.

Filed in Spanish · English published by the European Commission

VILLACER PORTUGAL Stoneware LDA expresses its deep concern regarding the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

European Metals represents European producers of non-ferrous metals (NFM), such as aluminium, copper, lithium, nickel, zinc, silicon, as well as ferroalloys and other metals that are essential to the green and digital transitions. Amid high energy and carbon costs, the need for a framework that enables the European industry to survive and continue growing has become even more urgent.

The European Dairy Association (EDA) welcomes the opportunity to contribute to the European Commission consultation on the revision of the benchmark values for free allocation of emission allowances for the 20262030 period. The EU dairy sector remains committed to contributing to the EUs climate objectives and to continuing its decarbonisation efforts.

Confindustria Umbria is deeply concerned about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time when energy prices are already high, international competitive pressure is growing and the availability of mature and scalable technologies for decarbonising hard-to-abate sectors is limited.

Filed in Italian · English published by the European Commission

DI fully supports the EU ETS as a common, market-based European climate regulatory tool. Later this Summer, the EU-Commissions proposal to a post-2030 ETS1 revision will be followed by intensive - sometimes emotional - debates. Already, in recent months, the EU ETS has received significant attention in European media.

EIGA welcomes the opportunity to provide input on the revision of benchmark values for free allocation under the EU Emissions Trading System (EU ETS). EIGA supports a robust and predictable EU ETS that drives industrial decarbonisation while maintaining competitiveness and preventing carbon leakage.

Laakirchen Papier AG is committed to the European Union’s climate objectives and to the transformation towards climate neutrality. However, in the context of this consultation, Laakirchen Papier AG would like to make some important comments on the present draft ETS benchmark values for the trading period 20262030.

Filed in German · English published by the European Commission

The proposed benchmarks reduction particularly the 50% cut to fallback heat and fuel benchmarks is unrealistic, disproportionate, and disconnected from current technological, infrastructure, and investment realities. These changes would significantly increase carbon costs for an already struggling chemical sector, worsen carbon leakage risks, and reduce the capacity of companies to invest in the climate transition.

The Union of Municipalities of the Ceramico District, which represents over 119.000 citizens in Europe’s main pole of ceramics, is deeply concerned about the revision of the ETS benchmarks 2026-2030. Reductions that are not consistent with the technologies currently available risk undermining investment, employment and social cohesion in an area where the ceramics sector supports around 40.000 jobs.

Filed in Italian · English published by the European Commission

The International Carbon Black Association (ICBA) has reviewed the proposed revision of the EU ETS product benchmark for carbon black and has serious concerns regarding its technical robustness, practical feasibility, and economic implications.

Our industrial site is currently equipped with a blast furnace, which is gradually being replaced by electric furnaces. In this context, the free allowances, currently calculated on the basis of the ‘Hot Metal’ benchmark (1,248 allowances/t), are set to change to the ‘Iron Casting’ benchmark (0,164 allowances/t). This shift and reduction in allocations is a drag on investments to decarbonise fusion processes.

Filed in French · English published by the European Commission

As a result of the planned ETS1 benchmark update for the period 20262030, Eisenwerk Brühl GmbH will suffer mainly economic disadvantages as a result of a possible reduction in the free allocation of allowances, as the new benchmarks will be based on the emission levels of the most efficient installations (top 10 %). In particular, Eisenwerk Brühl GmbH may be exposed to the following risks: 1.

Filed in German · English published by the European Commission

AICE welcomes the consultation of stakeholders on the Implementing Regulation determining revised benchmark values for the 2026-2030 period, welcoming the Commissions approach to implement the removal of exchangeability.

Ceramirupe Ceramicas SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

AGFW e. V. is the independent, impartial German association promoting energy efficiency, (district) heating, cooling and CHP (Combined Heat and Power) at national and international levels. AGFW comprises more than 700 regional und municipal energy suppliers, consultants, experts manufacturing companies including component and system manufacturers, assembling companies and testing institutes within Germany and…

Syensqo thanks the European Commission for the opportunity to contribute to the public consultation on the revision of the EU ETS benchmark values for the 20262030 period. Syensqo reiterates its support for the European Commissions climate strategy and the 2050 carbon neutrality objectives set out in the European Green Deal announced in 2019.

France Chimie welcomes the opportunity to provide feedback on the European Commissions draft Implementing Act on the revision of the benchmark values for free allocation of emissions allowances under the EU ETS in the period 2026-2030.

The ceramic sector, characterized by high energy intensity and a strong export orientation, operates within a technological and production context that does not appear to be adequately reflected in the new proposed benchmarks. This results in a misalignment between regulatory ambitions and the actual operating conditions of companies, with potentially significant economic and competitive consequences.

PFP, the Primary Food Processors association, represents the interests of the European primary food processing industry to the European institutions and international organisations. PFP herewith responds to consultation on the revision of the ETS benchmarks for the period 2026 - 2030.

Confindustria Varese is deeply concerned about the Commissions proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for the European industry at a time already marked by high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the decarbonisation of hard-to-abate sectors.

Lenzing Papier is committed to the European Union’s climate objectives and to the transformation towards climate neutrality. However, in the context of this consultation, Lenzing Papier would like to make some key comments on the present draft ETS benchmark values for the trading period 20262030.

Filed in German · English published by the European Commission

FEDIOL, the EU vegetable oil and proteinmeal industry association, represents the interests of the European oilseed crushers, vegetable oil refiners and bottlers. Vegetable oil and protein meal manufacturing (NACE 10.41) is considered a carbon leakage sector.

The Finnish Forest Industries Association represents Finnish forest-based industries. As an important sector of the bioeconomy, we offer solutions that can replace fossil-intensive products, store and utilise captured biocarbon, and meet the needs of consumers, industry and society. Finnish forest-based industries are already well advanced in the transition away from fossil fuels.

Filed in Finnish · English published by the European Commission

For the European glass fibre industry, the proposed 2026-2030 product benchmark for continuous filament glass fibre products (t CO2/melted t of glass) would have damaging and counterproductive effects. It significantly diverges from the industrys actual GHG intensity, thereby further exacerbating already negative profitability and de facto reducing the sectors capacity to invest.

The Association of Metalworking Engineers and Technicians in Poland (SITPH), representing the technical environment of the steel industry and related industries, is concerned about the proposed update of benchmark values for free allocation of emission allowances for 2026-2030. SITPH supports efforts to reduce greenhouse gas emissions and the development of innovative low-carbon technologies.

Filed in Polish · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Decarbonising the district heating network is an essential building block for the Wiener Stadtwerke Group to achieve the overarching goal of climate neutrality by 2040. We therefore welcome the opportunity to provide feedback on the Commission’s proposal to revise the benchmark values for free allocation of emission allowances (2026-2030).

Filed in German · English published by the European Commission

Umbelino Monteiro expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Ceramico de Pegões, J. G. Silva, S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Polish Glass Manufacturers Federation is seriously concerned by the proposed revision of the fuel fallback benchmark and some other benchmarks for 2026 - 2030. The proposed update would lead to a very sharp reduction in the fallback benchmarks, with a drop of around 34% between 2025 and 2026. For companies relying on the heat and fuel benchmarks, this could mean that carbon costs broadly double in only one year.

Although Vista Alegre Unite of Taboeira is not directly covered by the EU ETS, it follows with great concern ongoing developments as it integrates the European ceramics value chain and shares the structural and competitive challenges affecting the whole sector.

Filed in Portuguese · English published by the European Commission

The text below is designed to be entered directly into the feedback field of the European Commission’s Have Your Say portal, respecting the standard character limit. It is accompanied by Part II to be attached to the same consultation. AIRU represents Italian operators of district heating and cooling (DH) networks.

Filed in Italian · English published by the European Commission

Colorobbia España, S.A. wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector.

Filed in Spanish · English published by the European Commission

The Association of Polish Papermakers is deeply concerned about the draft implementing regulation, pointing out that the drastic reduction in the value of product benchmarks for the pulp and paper sector by more than 30 % does not reflect the real pace of technological progress.

Filed in Polish · English published by the European Commission

CERTECA – Ceramic INDÚSTRIAS SA expresses its deep concern regarding the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The EU beet sugar sector uses the heat and fuel fallback benchmarks and, since 2025, process emissions have also been included under the EU ETS framework. The proposed values for the fallback benchmarks for 20262030 are highly concerning for the European beet sugar sector given the severe market difficulties currently facing the industry.

The Municipality of Casalgrande (RE), an area with a strong ceramic vocation, wishes to express the strong concern of our communities with regard to the proposed revision of the ETS benchmarks for the period 2026-2030. Ceramics are not just an industrial sector. it is an integral part of the identity and social cohesion of our territories.

Filed in Italian · English published by the European Commission

Sofia Med SA, situated in Sofia, Bulgaria, on an area of 250,000 m2, is a large metallurgical producer of a wide range of rolled and extruded Copper and Copper alloy products that are used in a wide variety of building, industrial, electrical and automotive applications. Sofia Med is a subsidiary of ElvalHalcor, Greece, which is part of the holding company Viohalco.

The proposed tightening of benchmark values would have significant negative impacts on the chemical industry in the EU, which may outweigh the expected environmental benefits. We therefore consider it essential that any adjustments to free allocation respect technological, economic, and especially competitive conditions.

The Carbon Capture and Storage Association (CCSA) is the leading trade association advocating for the commercial deployment of CCUS, both in Brussels and London. The CCSA represents the entire, end-to-end CCUS value chain, bringing together the heavy industrial emitters, the transporting partners, the geological store operators, but also the supporting industries - the technology providers, the EPC, the legal, and…

We thank the European Commission for the opportunity to comment on the update of the Implementing Regulation on benchmark values for the free allocation of allowances under the EU ETS for the period 20262030. The new benchmark values lead to a reduction in free allocation in many sectors, thereby increasing the cost burden for EU ETS installations.

Filed in German · English published by the European Commission

In view of the published proposals to amend the values of benchmarks forming the basis for allocation of free CO emission allowances under the EU ETS, we hereby present the position of Koksownia Częstochowa Nowa Sp. z o.o. concerning the proposed value of benchmark for coke production.

FuelsEurope welcomes the consultation of stakeholders on the Implementing Regulation determining revised benchmark values for the 2026-2030 period, welcoming the Commissions approach to implement the removal of exchangeability.

VERNÍS wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector. The sector is committed to decarbonisation, but currently has no technically and economically feasible alternatives on an industrial scale, either through electrification or through other energy carriers such as biomass.

Filed in Spanish · English published by the European Commission

SMALTICERAM ESPAÑA wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the frits and ceramic enamels sector. The sector is committed to decarbonisation, but currently has no technically and economically feasible alternatives on an industrial scale, either through electrification or through other energy carriers such…

Filed in Spanish · English published by the European Commission

As the National Section of Metallurgy, Foundry and Coking - Trade Union of Engineers and Technicians in Poland, representing the steel, foundry and coking industries, we are concerned about such a significant reduction in benchmarks for many important industrial sectors in the draft regulation published by the European Commission on May 11, 2026, specifying revised emission factor values for the purposes of…

In response to the public consultation process on the proposed reference values for the period 2026-2030, ASPAPEL proposes: Maintain the current reference values freeze the reference values for the period 2021-2025 and apply them unchanged for the period 2026-2030 to avoid reductions based on outdated assumptions and preserve investment predictability.

Filed in Spanish · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Embora a Vista Alegre Unidade de Ilhavo não esteja diretamente abrangida pelo CELE, acompanha com grande preocupação os desenvolvimentos em curso, na medida em que integra a cadeia de valor da indústria cerâmica europeia e partilha os desafios estruturais e competitivos que afetam todo o setor.

Dominó, Industrias Ceramic S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The EC draft benchmark for heat and fuel aggregates is an important indicator for metallurgical industries. A large part of the metallurgical installations covered by the EU ETS receive free allowances based on the quantities thus allocated according to an adopted indicator (benchmark) for the existing installations and facilities.

The ČPS generally disagrees with the increased reduction in the values for free allocation of emission allowances for industry and energy. We call for the current legislation in this area to be left intact and for the revision to be rejected in its entirety.

Filed in Czech · English published by the European Commission

Executive Summary ECIA Position on the EU ETS Benchmark Update for 20262030 The Estonian Chemical Industry Association (ECIA) is concerned that the proposed tightening of EU ETS benchmarks, particularly the 50% reduction of fallback benchmarks, comes at a time when European industry is already facing unprecedented competitive pressures, high energy costs, geopolitical uncertainty, and declining investment…

The Classen Group comments on the consultation on the revision of the benchmark values for free allocation of emission allowances for the period 2026-2030. The Classen Group is a German industrial producer of wood-based products. It produces in Germany and operates energy-intensive production facilities that are part of European value chains, regional employment and the circular bioeconomy.

Filed in German · English published by the European Commission

The revision of the EU ETS emission limits should take into account the current context of economic and geopolitical uncertainty, as well as the technological reality of the European ceramics industry. While the sector is strongly committed to decarbonisation and has made significant investments in energy efficiency, there are still no mature and economically viable technical solutions to replace, on an industrial…

Filed in Portuguese · English published by the European Commission

Starch Europe contribution ETS heat and fuel fallback benchmarks: improving comparability (20262030 and Phase 5) Starch Europe supports the EU ETS as a central instrument for industrial decarbonisation and recognises the role of benchmarks in incentivising efficiency while preserving protection against carbon leakage.

The European ceramic industry, including our associations, is concerned about the draft implementing regulation revising the ETS benchmarks for the period 20262030, in particular with regard to the planned new reduced fuel benchmarks.

Filed in Hungarian · English published by the European Commission

Consorzio Energia Lombardia Nord, Energy Consortium of Confindustria Como and Confindustria Lecco e Sondrio, expresses strong concern about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time already marked by high energy prices, increasing international competitive pressure and limited availability of mature…

Filed in Italian · English published by the European Commission

From our perspective as a mainstream refinery, the proposed reduction of the product benchmark Refinery products by 21% compared to 2013-2020 does not sufficiently consider the negative impact of ETS-related costs on competitiveness. The disadvantage towards international competitors who are not subject to carbon pricing remains on a high level. In the result, carbon leakage occurs rather than emission abatement.

The European ceramic industry raises its concerns regarding the proposed Draft Implementing Regulation on the ETS benchmarks review for the period 2026-2030 and in particular the new reduced values for the fuel fallback benchmarking approach.

Riastone welcomes the opportunity to comment on the draft European Commission Implementing Regulation on updating benchmarks for free allocation of EU ETS allowances for the period 2026-2030. Our company shares the European Union’s decarbonisation objectives and has been making significant investments in energy efficiency, optimisation of production processes and reduction of greenhouse gas emissions.

Filed in Portuguese · English published by the European Commission

Železiarne Podbrezová group is among the leading European producers of steel seamless tubes, with its own steel mill and modern production technologies for manufacturing of hot rolled and cold drawn seamless steel tubes.

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Koninklijke Nederlandse Bouwkeramiek (KNB) the Dutch Ceramic Industry Association represents the Dutch manufacturers of durable and affordable construction products such as bricks, roof tiles, wall and floor tiles within the EU ETS system.

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Tata Steel Nederland (TSN) welcomes the opportunity to respond to the draft act on the 2026-2030 ETS benchmarks. In order to ensure visibility and predictability, we call for a swift adoption of the act so that free allowances can be granted as quickly as possible before the next compliance deadline.

This submission presents the comments of Hyundai Steel Company, established in the Republic of Korea (South Korea), Hyundai Steel Slovakia s.r.o., and Hyundai Steel Czech Republic s.r.o. (collectively referred to as the Hyundai Steel Group or HSG). We welcome the Commissions efforts to update the EU ETS benchmarks for 20262030.

The ETS is the cornerstone of the EUs climate policy, on which companies rely when planning and implementing capital-intensive investments. A well-functioning ETS must provide an effective and predictable investment signal for industrial decarbonization, while ensuring effective protection against carbon leakage for sectors exposed to global competition.

Major Comment On heat and fuel benchmarks We propose that, as part of finalising the implementing regulation, the Commission should include a methodological verification of the representativeness of the 20212022 reference period used for updating the heat and fuel benchmarks for the 20262030 period.

We ask the Commission to revise the draft so that the 2026-2030 heat and fuel fallback benchmarks are not set at the maximum legal reduction, but at a realistic and achievable level. Improved fallback benchmarks methodologies are welcome, but a sound new methodology will most likely not be ready in time for the 2026 allocation year or the years immediately after.

As part of the EU’s ‘Fit for 55 %’ legislative package, the Emissions Trading System (ETS) Directive has been revised to align it with the EU’s target set by the European Climate Law to reduce net greenhouse gas emissions by 55 % by 2030 compared to 1990 levels. Following this revision, the Commission needs to update several acts for the implementation of the ETS.

Filed in Italian · English published by the European Commission

The French dairy industry is determined to contribute to national climate targets and to continue its decarbonisation efforts. At the same time, it is important to ensure that the regulatory framework remains predictable, transparent and economically viable so as not to undermine the competitiveness of the agri-food sector and price accessibility.

Filed in French · English published by the European Commission

For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. According to our association DIE Papierindustrie, a competitive level of allocation last existed in 2020. While international competition has since continued to show no relevant additional CO2 costs, the cost pressure from declining allocation in the EU is rapidly increasing.

Filed in German · English published by the European Commission

Dear Sirs, I am attaching detailed comments to the draft Implementing Regulation of the European Commission. Please find attached the position of the Trade Union Alliance "KADRA" (PZZ KADRA) regarding the draft Commission Implementing Regulation amending the benchmark values for the free allocation of emission allowances for the period 20262030.

The European Council of Vinyl Manufacturers and VinylPlus, the sustainability commitment of the European PVC Value Chain, strongly support the Commissions proposed 2026-2030 product benchmark values for VCM, S-PVC and E-PVC. They are technically justified, important for carbon leakage protection, and should be maintained unchanged in the final Regulation.

The benchmarks proposed by the European Commission for the period 2026 to 2030 are overly ambitious and do not reflect technical reality. The fallback benchmark for fuels cannot be achieved in the area of high-temperature processes, which are currently carried out predominantly using natural gas.

The European Association of Potash Producers (APEP), representing EU potash producers, welcomes the opportunity to contribute to the Call for Evidence on the revision of benchmark values for the free allocation of emission allowances (20262030). For the potash sector, which relies primarily on heat and fuel fallback benchmarks, this revision is of particular importance.

MOL Group welcomes the Commissions proposed approach to the removal of exchangeability. By continuing to account for indirect emissions in the calculation of the average GHG emissions of the 10% most efficient installations, as was done in previous allocation periods, the approach avoids the need to extrapolate between datasets that are not comparable, thereby ensuring methodological consistency for the affected…

Unem welcomes the approach taken by the European Commission for the revision of the Implementing Regulation determining the updated benchmark values for the period 2026-2030 following the removal of the ExchangeAbility mechanism.

Filed in Italian · English published by the European Commission

The proposal is expected to have limited direct implications for Malta, given the relatively small size and structure of its EU ETS industrial base. Malta's ETS-covered activities are primarily concentrated in: electricity generation and limited manufacturing activities, which are generally not significantly affected under ETS1 or ETS2.

Consultation contribution on the benchmark update 2026-2030 by Albert Friedrich KG. For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

MOTALOG, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

MOTA Ceramic pastes, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

MOTAMINERAL MINERAIS INDUSTRIAIS, SA expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The INDUSTRIAIS MINERAIS FELMICA, SA expresses its deep concern about the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Motion II Ceramic SOLUTIONS, SA expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Adelino DUARTE DA MOTA, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Legnica, 5th June 2026 ZPPM / 27S / III / 2026 European Commission Secretariat-General Rue de la Loi 200/ Wetstraat 200 B - 1049 Brussels Belgium Position of the Polish Copper Employers Association on draft of COMMISSION IMPLEMENTING REGULATION (EU) determining revised benchmark values for free allocation of emission allowances for the period from 2026 to 2030 pursuant to Article 10a(2) of Directive 2003/87/EC of…

Gres Panaria Portugal SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The Emilia Romagna Region wishes to express the strong concern of our community with regard to the proposed revision of the ETS benchmarks for the period 2026-2030. Ceramics are not just an industrial sector. it is an integral part of the identity and social cohesion of our territories. Skilled work, technical skills, innovation, businesses, services and local communities have developed around this sector.

Filed in Italian · English published by the European Commission

CRISAL expresses its deep concern about the proposed reduction of the fallback benchmarks (BK fuel and BK heat), as they form the basis of the free allocation applicable to our installation, and there is no specific product benchmark for the crystalline sector.

Filed in Portuguese · English published by the European Commission

Laminam SPA, a leading company in the design, production and marketing of large ceramic plates, expresses serious concern about the European Commission’s proposal to update the ETS benchmarks for the period 2026-2030.

Filed in Italian · English published by the European Commission

Polska Ceramika Ogniotrwała S.A. (PCO) is the largest producer of aluminosilicate refractories in Poland, with more than 185 years of manufacturing behind it. We make fireclay, high-alumina and mullite products, refractory castables and mortars. These materials are indispensable to high-temperature processes across the iron and steel industry, non-ferrous metals, cement, lime, glass, chemicals and energy.

Cepi expresses its profound concern regarding the Commissions proposal to update the benchmark values under the European Union Emissions Trading System (EU ETS) for the period 2026-2030. 10 out of 11 product benchmarks of the pulp and paper industry are said to be reduced by the highest update rate (50% compared to the 2013-2020 values).

Grestel, Produtos Ceramic S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

SACMI IBÉRICA, SA. Branch in Portugal expresses its deep concern regarding the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

ECOGRES Ceramic Ecológica, Lda., expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Kem One is a French manufacturer of basic chemicals and chemical intermediates. A significant share of our free allocation under the EU ETS is determined by the heat fallback benchmark, making the proposed revision directly and materially damaging for our operations.

Pavigrés Ceramic, a Portuguese producer of ceramic floors and cladding, is deeply concerned about the European Commission’s draft implementing act on the revision of the benchmarks for free allocation of allowances under the EU ETS for the period 2026-2030.

Filed in Portuguese · English published by the European Commission

First of all, it is important to point out that the allocation of free allowances to European companies exposed to the risk of relocation is not an industrial support measure but is an environmental protection measure in that it avoids carbon leakage, i.e.

Filed in Italian · English published by the European Commission

A Ceramica DE Quintas lda manifesta a sua profunda preocupação relativamente ao projeto de regulamento de execução proposto sobre a revisão dos benchmarks ETS UE para o período de 2026 a 2030 e, em particular, aos novos benchmarks reduzidos para a abordagem de referência do combustível de recurso (fuel fallback benchmarking).

Oliveira do Bairro, June 05, 2026, Reply from SOLCER- Empresa Cerâmica SA to the Public Consultation for the revision of ETS benchmark values for the calculation of free emission allowances (2026-2030) The (name of company) welcomes the opportunity to comment on the European Commission’s draft implementing act on the revision of the benchmarks for free allocation of emission allowances under the ETS-EU for the…

Filed in Portuguese · English published by the European Commission

Confindustria Lombardia does not agree with the proposal to update the ETS benchmarks for the five-year period 2026-2030, as it risks seriously affecting the manufacturing system, which has already been weakened by energy costs and global competition, in the face of a lack of technological maturity for the decarbonisation of hard-to-abate sectors.

Filed in Italian · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Confindustria Brescia expresses strong concern regarding the proposed update to the EU ETS benchmarks for the 2026-2030 period. The drastic proposed reduction, such as the 34% cut for the fuel benchmark compared to 2025, risks imposing unsustainable costs on hard-to-abate industries like ceramics, paper, aluminum, cement, and glass during a phase of high energy prices and fierce foreign competition, combined with…

Cerutil Ceramic utilitarias SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

On behalf of Sappi Maastricht BV, we express our serious concerns about the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the period 2026-2030. The product benchmarks of the pulp and paper industry are reduced by the maximum adjustment rate (50 % compared to 2013-2020 values).

Filed in Dutch · English published by the European Commission

Arkema underlines the significant methodological issues of comparability and replicability for the setting of the fallback "heat" benchmark, leading to a maximum reduction of -50% compared to the initial benchmark value of phase III and -34% compared to to the benchmark value of phase IV.1.

On behalf of Smart Packaging Solution BV, part of VPK, we express our serious concerns about the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the period 2026-2030. The product benchmarks of the pulp and paper industry are reduced by the maximum adjustment rate (50 % compared to 2013-2020 values).

Filed in Dutch · English published by the European Commission

The European ceramic industry raises its strongest concerns regarding the proposed Draft Implementing Regulation on the ETS benchmark review for the period 20262030, and in particular the new reduced values for the fuel fallback benchmark.

The Seixo Outeiro Ceramic, S.A., expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and, in particular, about the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

We support the ETS benchmarks that accurately reflect the technical decarbonisation potential of industrial sectors while preserving their international competitiveness. The proposed benchmark reductions for product-benchmarked sectors broadly achieve this balance, however, the proposed -50% reduction of the heat and fuel fallback benchmarks do not.

EUsalt welcomes the opportunity to contribute to the consultation on the revision of ETS benchmark values for the period 20262030. Based on input from our member companies, the current methodology and resulting benchmark levels raise serious concerns regarding realism, representativeness, and feasibility. In particular, the significantly lower heat and fuel benchmark values are of particular concern.

SANITANA Fábrica de Sanitários de Anadia, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

As an association representing the chemical industry in Slovakia, we fully support the decarbonisation and the transformation of European industry. The EU ETS revision comes at a time when European industry is already facing extremely difficult conditions. Our industry has been losing competitiveness due to high carbon related costs and high energy costs.

We welcome the opportunity provided by the European Commission to give feedback on the public consultation on the Revision of the benchmark values for free allocation of emission allowances (2026-2030). As ECOS, we strongly believe in the added value of a solid EU ETS to contribute to a clean, competitive and climate neutral European industrial basis.

Assolombarda, representing over 7.000 companies from the Metropolitan City of Milan and the provinces of Lodi, Monza and Brianza, Pavia, expresses strong concern about the following Commission proposal, which risks significantly increasing the costs of European industry at a stage already marked by high energy prices, international competitive pressure and limited availability of mature technologies for the…

Filed in Italian · English published by the European Commission

The Green transition is a key development priority for Europe. Thus, according to the latest guidelines, emissions are to be reduced by 90% by 2040 and climate neutrality is to be achieved by 2050 compared to 1990 levels. The fact is that the starting points for decarbonisation were set under fundamentally different circumstances than those we are witnessing today, six years later and after three crises.

VNCI supports a strong and effective EU ETS as a central instrument for cost-effective decarbonization. However, the current benchmark revision risks undermining both industrial competitiveness and the effectiveness of the ETS if not properly calibrated. The proposed 50% reduction of the fallback benchmarks undermines carbon leakage protection.

For VNO-NCW, it is important that the Commission fully reflects the message of the Draghi report: a strong industrial base is indispensable to Europes competitiveness, strategic autonomy and ability to deliver the climate transition within Europe itself. Three main positions 1. The 50% cut of the heat and fuel fallback benchmarks weakens the protection against carbon leakage.

Legnica, 5 June 2026. ZPPM/27S/III/2026 European Commission Secretariat-General of the European Commission Rue de la Loi 200/Wetstraat 200 B – 1049 Brussels/Brussel/Brussels Belgium/Belgium Position of the Employers’ Union Polska Miedź on the draft Implementing Regulation determining revised reference values for free allocation of emission allowances for the period from 2026 to 2030 pursuant to Article 10a(2) 2 of…

Filed in Polish · English published by the European Commission

Federbeton the Italian federation representing the cement and concrete industries and their associated supply chain supports the role of the EU ETS in industrial decarbonization. However, it is concerned about the Commissions proposal to update ETS benchmarks for 2026-2030, which could significantly increase costs for European industry in a phase already marked by high energy prices, stronger competition and limited…

The PKEE, representing leading companies in the Polish power and heat sector, emphasizes that district heating (DH) is a SOCIALLY SENSITIVE SECTOR providing an essential public service. I. CONCERNS REGARDING THE HEAT BENCHMARK The proposed heat benchmark of 31.2 allowances/TJ (a 34.1% reduction) is considered structurally flawed because: FALLBACK NATURE: As a cross-sectoral fallback, its reference sample is "pulled…

Mr LAPREN reiterated his commitment to the European policy of reducing CO2 emissions and considered that the EU should stay the course on its carbon market and on the carbon border tax (CBAM), while helping industries to decarbonise by providing them, in particular, with the anticipated revenue from LETS.

Filed in French · English published by the European Commission

Recer Industria de Revestimentos Ceramic, S.A. expresses its deep concern about the European Commission’s draft implementing regulation on the revision of the EU-ITS benchmarks for the period 2026 to 2030 and, in particular, the proposed new values for the fuel fallback benchmark.

Filed in Portuguese · English published by the European Commission

Revigres welcomes the opportunity to comment on the draft European Commission Implementing Regulation on updating benchmarks for free allocation of EU ETS allowances for the period 2026-2030. Our company shares the European Union’s decarbonisation objectives and has been making significant investments in energy efficiency, optimisation of production processes and reduction of greenhouse gas emissions.

Filed in Portuguese · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

The Provincial Council of Castellón wishes to inform the European Commission of its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030, and in particular about the proposed reduction in the fuel benchmark. The province of Castellón is the leading European ceramics manufacturing cluster.

Filed in Spanish · English published by the European Commission

Through all its activities, Tereos, an agricultural cooperative, makes a significant contribution to European agricultural and industrial sovereignty, as well as to the economic and social vitality of rural areas. As a processor of agricultural raw materials (sugar beet, wheat, corn, sugarcane, and alfalfa), our biorefineries represent a critical link between upstream farming and downstream industries.

COPACEL, the professional organisation serving the French paper industry, expresses serious concerns about the revision of the benchmark values of the quota trading system (ETS) for the period 2026-2030. According to the Commission proposal, 10 of the 11 product benchmarks applicable to the paper industry would be reduced with the maximum reduction rate, a decrease of 50 % compared to the 2013-2020 values.

Filed in French · English published by the European Commission

On behalf of Crown van Gelder International BV, we express our serious concerns about the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the period 2026-2030. The product benchmarks of the pulp and paper industry are reduced by the maximum adjustment rate (50 % compared to 2013-2020 values).

Filed in Dutch · English published by the European Commission

KCM AD is a leading manufacturer of zinc, lead, and their alloys, as well as cadmium, in the metallurgical sector of Southeast Europe. The Company also produces smaller quantities of precious metals and their alloys, sulfuric acid, and other intermediate products.

The European ceramic industry raises its concerns regarding the proposed Draft Implementing Regulation on the ETS benchmarks review for the period 2026-2030 and in particular the new reduced values for the fuel fallback benchmarking approach.

The European ceramic industry raises its concerns regarding the proposed Draft Implementing Regulation on the ETS benchmarks review for the period 2026-2030 and in particular the new reduced values for the fuel fallback benchmarking approach.

Roca S.A expresses its deep concern regarding the proposed draft implementing regulation on the review of the EU ETS benchmarks for the period 2026-2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Matceramica, Fabrico de Loiça SA, expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

We ask the Commission to revise the draft so that the 2026-2030 heat and fuel fallback benchmarks are not set at the maximum legal reduction, but at a realistic and achievable level. Improved fallback benchmarks methodologies are welcome, but a sound new methodology will most likely not be ready in time for the 2026 allocation year or the years immediately after.

Federchimica reiterates its commitment to the 2050 climate neutrality goal, recognizing the EU Emissions Trading System (ETS) as a primary tool for achieving these climate targets. However, fulfilling this ambition requires a robust framework of enabling conditions, such as lead markets for green products, access to affordable low-carbon energy and feedstocks, and a comprehensive carbon infrastructure.

ANFFECC wishes to express its concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector. The sector is committed to decarbonisation, but currently has no technically and economically feasible alternatives on an industrial scale, either through electrification or through other energy carriers such as biomass.

Filed in Spanish · English published by the European Commission

In view of the current political and economic environment and future prospects, The Navigator Company considers that freezing the 2021-2025 benchmarks and correcting the most distortive elements of the EU ETS design are necessary conditions for the pulp, paper and board industry to be able to continue investing in the climate transition without losing competitive capacity vis-à-vis competing regions.

Filed in Portuguese · English published by the European Commission

A Aleluia Cerâmicas SA manifesta a sua profunda preocupação relativamente ao projeto de regulamento de execução proposto sobre a revisão dos benchmarks ETS UE para o período de 2026 a 2030 e, em particular, aos novos benchmarks reduzidos para a abordagem de referência do combustível de recurso (fuel fallback benchmarking).

Evropský keramický průmysl vyjadřuje své obavy ohledně předloženého návrhu Prováděcího nařízení k revizi referenčních hodnot ETS pro období 2026-2030, a zejména ohledně přístupu ke sníženým hodnotám záložních referenčních hodnot pro palivo.

COGEN Europe welcomes the European Commission's consultation on revising EU ETS benchmark values for free allocation (20262030), but calls for urgent corrective action to protect industrial competitiveness and the district heating sector without compromising Europe's climate ambitions. Combined Heat and Power (CHP) is one of Europe's most cost-effective decarbonisation technologies.

Confindustria Veneto, a regional association of Confindustria, has serious doubts about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, as it risks significantly increasing costs for European industry, which is already in a situation characterised by high energy costs, growing international competitive pressure and limited availability of mature and scalable technologies for the…

Filed in Italian · English published by the European Commission

Paper mill Adolf Jass Schwarza GmbH’s contribution to the consultation on the draft benchmark update 2026-2030 of 11 May 2026. The negative economic conditions in recent years, combined with a multiannual recession in Germany, have left considerable traces. Compared to the 2016-2020 five-year average, German paper production decreased by over 16 % in 2025.

Filed in German · English published by the European Commission

Paper mill Adolf Jass GmbH & Co. KG’s contribution to the consultation on the draft benchmark update 2026-2030 of 11 May 2026. The negative economic conditions in recent years, combined with a multi-year recession in Germany, have left considerable traces. Compared to the 2016-2020 five-year average, German paper production decreased by over 16 % in 2025.

Filed in German · English published by the European Commission

Confindustria Piemonte is deeply concerned about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time of already high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the decarbonisation of hard-to-abate sectors.

Filed in Italian · English published by the European Commission

Sanindusa – Industria de Sanitários, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Aviretta GmbH – Contribution to the consultation on the 2026-2030 benchmark update Dear Sir/Madam, the proposed benchmark update will further significantly weaken the competitiveness of the European pulp and paper industry. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

Confindustria Piacenza, the association representing industrial companies in the Province of Piacenza, Emilia-Romagna, and part of the leading national employers association Confindustria, is deeply concerned about the Commissions proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time of already high energy prices, increasing…

Magnezytowy ROPCZYCE S.A. is a producer of refractory materials used in key sectors of European industry. In the Company’s view, the proposed benchmark values for 2026-2030 exceed the emission reduction potentials achievable using technologies currently available for industrial use. Refractory materials are an essential part of the strategic value chains of European industry.

Filed in Polish · English published by the European Commission

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the initiative Revision of the benchmark values for free allocation of emission allowances (2026-2030). Please find detailed comments in the Attachment.

Carl Macher GmbH & Co. KG [address removed] Consultation contribution on the benchmark update 2026-2030 For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

Soladrilho – Sociedade Cerânica de Ladrilhos, S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Please find the submission of Aughinish Alumina Limited (AAL) on the European Commissions proposed EU ETS draft Implementing Regulation determining the benchmark values for free allocation in the period 2026-2030. AAL produces smelter grade alumina which is supplied to downstream smelters for the production of aluminium.

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Gres Panaria Portugal, with 3 plants in Portugal covered by the EU ETS, welcomes the opportunity to comment on the draft European Commission Implementing Regulation on updating benchmarks for free allocation of EU ETS allowances for the period 2026-2030.

Filed in Portuguese · English published by the European Commission

The European Commission’s proposal to update the ETS benchmarks for the period 20262030 would lead to drastic reductions in the benchmarks for the ceramics sector: the fuel benchmark would decrease by 50 % compared to 20132020, while the relevant product benchmarks for the different ceramic sectors would be reduced by around 40 % over the same period.

Filed in Italian · English published by the European Commission

Primus Ceramics, S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

The European ceramic industry raises its concerns regarding the proposed Draft Implementing Regulation on the ETS benchmarks review for the period 2026-2030 and in particular the new reduced values for the fuel fallback benchmarking approach.

In agreement with Confindustria Nazionale, Confindustria Ceramica, the Emilia-Romagna Region, the municipalities of the ceramic district and ACIMAC, the Ceramiche Gresmalt Group confirms its full support for the points set out in the document drawn up by Confindustria Ceramica in response to this consultation.

Filed in Italian · English published by the European Commission

Keraben GRUPO would like to express its concerns about the draft Implementing Regulation on the update of the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Confindustria Genova is deeply concerned about the Commissions proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for the European industry at a time already marked by high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the decarbonisation of hard-to-abate sectors.

The Municipality of Castellarano (RE), an area with a strong ceramic vocation, wishes to express the strong concern of our communities with regard to the proposed revision of the ETS benchmarks for the period 2026-2030. Ceramics are not just an industrial sector. it is an integral part of the identity and social cohesion of our territories.

Filed in Italian · English published by the European Commission

We ask the Commission to revise the draft so that the 2026-2030 heat and fuel fallback benchmarks are not set at the maximum legal reduction, but at a realistic and achievable level. Improved fallback benchmarks methodologies are welcome, but a sound new methodology will most likely not be ready in time for the 2026 allocation year or the years immediately after.

Moravia Steel a.s. submits this feedback on behalf of the MS-TŽ Group, the last remaining integrated producer of long steel products in the Czech Republic. Our operations cover the full primary steelmaking route, including coke production, sintering and hot metal production.

The Unione Parmense degli Industriali, the regional association of the Confindustria system, is deeply concerned about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing costs for industry. The proposed update would have significant impacts on both product benchmarks and fall-back benchmarks.

Filed in Italian · English published by the European Commission

We present the opinion of WZK VICTORIA S.A. on the draft regulation published by the European Commission on May 11, 2026, which specifies revised emission factor values ​​for the allocation of free emission allowances for the period 2026-2030 in accordance with Article 10a(2) of Directive 2003/87/EC of the European Parliament and of the Council.

Position Paper Assovetro Review of ETS benchmarks for free allocation of allowances (20262030) Assovetro, the national association of Confindustria representing the Italian glass industry, reiterates its support for the EU ETS as a key instrument for efficient decarbonisation. However, the reduction of free allowances must reflect realistically sustainable technical and economic conditions.

Filed in Italian · English published by the European Commission

The Ceramic Brick & Tile Association of Cyprus considers the ongoing revision of the EU ETS benchmarks for the 20262030 period to be of critical importance for the sector. The process should be concluded without delay to provide businesses with the certainty necessary for operational planning, investment decisions, and the successful management of the transition to a lower-carbon economy.

Desde TORRECID SA queremos trasladar nuestra preocupación por el benchmark general de combustible propuesto para 2026-2030, al considerar que no refleja la realidad tecnológica del sector de fritas y esmaltes cerámicos, representado por la asociación ANFFECC.

Dear Mr/Ms, In relation to the public consultation on the revision of the ETS benchmarks for the period 20262030, Emilceramica S.R.L, Italy – ceramic tiles sector, would like to express the following considerations. The published benchmarks show a level of ambition which, at present, is not consistent with the operating conditions and the existing energy context at European level.

Filed in Italian · English published by the European Commission

On behalf of Papierfabriek Schut BV, we wish to express our serious concern regarding the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the 20262030 period. The product benchmarks for the pulp and paper industry are set to be reduced by the maximum adjustment rate (50% compared to the 20132020 benchmark values).

Lovochemie, a.s. strongly opposes the radical reduction of the product benchmark for nitric acid production proposed by the European Commission for the period 20262030. We see this as an unrealistic regulatory requirement that completely ignores the technological and economic reality of industrial sites.

Filed in Czech · English published by the European Commission

Please find below the feedback from the Lithuanian glass industry on the revision of Article 10a(2) of the Emissions Trading System (ETS) Directive 2003/87/EC in light of the EU’s target of reducing net greenhouse gas emissions by 55 % by 2030 compared to 1990 levels, as set out in the European Climate Law: The Directive proposes benchmark values for bottles and jars of colourless glass in the glass manufacturing…

Filed in Lithuanian · English published by the European Commission

TAURON Ciepło welcomes the opportunity to contribute to the European Commission consultation on the revision of benchmark values under the EU ETS. In the context of ongoing discussions on benchmark reductions affecting industrial sectors, it should be highlighted that district heating already covers the vast majority of its ETS compliance costs, receiving only a limited share of free allocation.

The Belgian brick industry raises its concerns regarding the proposed Draft Implementing Regulation on the ETS benchmarks review for the period 2026-2030 and in particular the new reduced values for the fuel fallback benchmarking approach together with the update of the values for facing bricks and pavers.

Dear Sir or Madam, JSW KOKS S.A., the largest independent coke producer in Europe and exporter to European Union countries and beyond, is enclosing an opinion on the proposed revised benchmark values for the free allocation of emission allowances for the period 2026-2030.

Unione Industriali Torino, as the area covered by the Confindustria system, is deeply concerned about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time when energy prices are already high, international competitive pressure is growing and the availability of mature and scalable technologies for decarbonising…

Filed in Italian · English published by the European Commission

We ask the Commission to revise the draft so that the 2026-2030 heat and fuel fallback benchmarks are not set at the maximum legal reduction, but at a realistic and achievable level. Improved fallback benchmarks methodologies are welcome, but a sound new methodology will most likely not be ready in time for the 2026 allocation year or the years immediately after.

The newly proposed benchmarks for the Ceramic Sector (spray-dried powder and fuel) are not realistic and cannot be achieved under current technical and economic conditions. The core issue lies in the methodology used to define them. We therefore formally request that this approach be reconsidered and not adopted, even on a temporary basis.

Younexa, S.L.U. wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector (represented by the ANFFECC association).

Filed in Spanish · English published by the European Commission

Fritta, S.L.U., wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector (represented by the association ANFFECC).

Filed in Spanish · English published by the European Commission

Esmalglass, S.A.U., wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the ceramic frits and enamels sector (represented by the ANFFECC association).

Filed in Spanish · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

On behalf of Papierfabriek Doetinchem BV, we express our serious concerns about the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the period 2026-2030. The product benchmarks of the pulp and paper industry are reduced by the maximum adjustment rate (50 % compared to 2013-2020 values).

Filed in Dutch · English published by the European Commission

IKEM (Innovation and Chemical Industries in Sweden) welcomes the opportunity to provide comments on the draft implementing regulation determining revised benchmark values for free allocation under the EU ETS for the period 20262030. IKEM has submitted a more detailed position paper as an attachment to this response. IKEM represents the chemical, plastics, pharmaceutical and refinery industries in Sweden.

Confindustria Moda, the Italian Textile and Fashion Federation, is deeply concerned about the Commissions proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for the European industry at a time already marked by high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the…

On behalf of the Dutch paper industry, we express our serious concerns about the proposal to update the benchmark values within the European Union Emissions Trading System (EU ETS) for the period 2026-2030. The product benchmarks of the pulp and paper industry are reduced by the maximum adjustment rate: 50 % compared to 2013-2020 values.

Filed in Dutch · English published by the European Commission

LUSIPA represents the industrial manufacturers damidon & derivative products in France: 4 enterprises, 9 production sites making it the leading producer of the sector in the EU. The energy intensive sector, French laminery, generates 25 % of its turnover outside the EU, which poses a particular risk of carbon leakage. Our profession does not question the need to decarbonise and supports the ETS system.

Filed in French · English published by the European Commission

Confindustria Cuneo, as the area covered by the Confindustria system, is deeply concerned about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time when energy prices are already high, international competitive pressure is growing and the availability of mature and scalable technologies for decarbonising…

Filed in Italian · English published by the European Commission

Styrenics, a Product Group within Plastics Europe, welcomes the opportunity to contribute to the public consultation on the revision of benchmark values for the free allocation of emission allowances for the 2026-2030 period.

The Bulgarian Federation of Industrial Energy Consumers (BFIEC) supports the European Unions climate objectives and recognises the EU Emissions Trading System (EU ETS) as a key market-based instrument for driving industrial decarbonisation.

Czech Energy Association (CEA) generally opposes the proposed tightening of benchmarks, which further undermines the competitiveness of EU industry. Increasing emission costs contradicts the objective of supporting European industry and raises the risk of carbon leakage.

Benchmark values must not be reduced below 2021-2025 levels. 2. The freezing of benchmarks should cover both product and fallback benchmarks in the same way and to the same extent. 3. The conditions attached to free allocation should be removed. 4. The market stability reserve should help to make the price of CO2 comparable with the values on other global markets.

Filed in Italian · English published by the European Commission

ATC COLORES CERAMICOS wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the frits and ceramic enamels sector.

Filed in Spanish · English published by the European Commission

Unindustria, the regional association of the Confindustria system, expresses serious concern about the proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time when energy prices are already high, international competitive pressure is growing and the availability of mature and scalable technologies for the decarbonisation of…

Filed in Italian · English published by the European Commission

Dear Members of the European Commission, please find attached the Position Paper of the German Association of Industrial Energy Consumers to the Consultation on the revision of the ETS Benchmark values. Compared with the baseline value for the 20132020 period, most benchmarks are being reduced.

Model Sachsen Papier GmbH Consultation Response to the Benchmark Update 20262030 For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the sectors competitiveness. A competitive allocation level last existed in 2020.

In the context of geopolitical and economic pressures, the cost structure of companies must not be further worsened by a shortage of emission allowances. An ambitious reduction in free allocations necessarily requires a fully functioning CBAM. The increasingly granular recording of partial emission factors (e.g.

Filed in German · English published by the European Commission

Mr Adisseo took part with interest in the European Commission’s consultation on the draft regulation on free EU ETS emission allowances for 2026-2030. Adisseo is a major industrial player in animal nutrition in Europe. Its products contribute to value chains that are essential for European food sovereignty, livestock farming and animal health.

Filed in French · English published by the European Commission

Biond is deeply concerned about the European Commission’s proposal to update the EU Emissions Trading System (EU ETS) benchmarks for the period 20262030. According to the proposal, 10 out of 11 product benchmarks from the pulp and paper industry will be reduced to the maximum discount rate (50 % compared to 20132020 values).

Filed in Portuguese · English published by the European Commission

VIDRES, a partner company in ANFFECC, wishes to express our concern about the general fuel benchmark proposed for 2026-2030, considering that it does not reflect the technological reality of the frits and ceramic enamels sector.

Filed in Spanish · English published by the European Commission

CS-COELHO DA SILVA, SA expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Fallback Benchmarks reduction is excessive : We express our strongest opposition to the proposed values. It is legally possible to change the methodology under the current legal framework (the application of the 10% approach in the revision of the fallback benchmarks is contained in a text that will itself be replaced by the new act defining the updated benchmark values).

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Outokumpu welcomes the opportunity to provide feedback on the draft revision of benchmark values for free allocation under the EU ETS for the 20262030 period. As a global leader in lowcarbon stainless steel, Outokumpu supports the principle of regularly updating EU ETS benchmarks based on real performance data, in line with technological progress and with the overarching goal of meeting the EUs climate goals.

ASSOMET expresses strong concern about the Commission’s proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for European industry at a time of already high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the decarbonisation of hard-to-abate sectors.

Filed in Italian · English published by the European Commission

Eesti Energia AS is one of the largest producers of electricity, heat for district heating, and refined oil products in the Baltic region. We hereby provide feedback on the Commissions proposal regarding the revision of the benchmark values for the free allocation of emission allowances for the period 20262030.

Climate Catalyst welcomes the update of the chemicals product benchmarks and supports the principle that benchmark values should continue to evolve in line with improvements in emissions performance. While some product benchmarks, including steam cracking, hydrogen and phenol/acetone, remain relatively closely aligned with the performance of the most efficient installations, others - including soda ash, aromatics…

CT – blant Telhas, S.A. expresses its deep concern regarding the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

ORLEN Termika S.A. welcomes the opportunity to address the draft Commission Implementing Regulation pursuant to Article 10a(2) of Directive 2003/87/EC, which updates heat benchmarks for free allocation of emission allowances in the period 20262030.

Porcelanosa would like to express its concerns about the draft Implementing Regulation on the update of the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

Please find attached our response to the consultation on the benchmark update (20262030): The WEPA Group reaffirms the importance of the EU Emissions Trading System (EU ETS) as a key instrument of European climate policy, supports a high level of ambition without any watering down, calls for industry-friendly regulation to safeguard its SBTi Net Zero 2040 target, emphasises the need for electrification through lower…

Feedback concerns the EU ETS new heat benchmark. The proposed reduction of the heat benchmark is contrary to the objectives of the European Unions climate and energy policy. District heating is recognised within EU climate policy as an important instrument for achieving climate targets, as reflected, among others, in the Renewable Energy Directive, the Energy Efficiency Directive and the Energy Performance of…

Filed in Estonian · English published by the European Commission

APICER, the Portuguese Association of Ceramics and Cristalaria Industries, expresses its deep concern about the proposed draft implementing regulation on the revision of the EU ETS benchmarks for the period 2026 to 2030 and in particular the new reduced benchmarks for the fuel fallback benchmarking approach.

Filed in Portuguese · English published by the European Commission

Confindustria Emilia esprime forte preoccupazione per la proposta della Commissione di aggiornamento dei benchmark ETS per il periodo 2026-2030, che rischia di aggravare in modo significativo i costi a carico dellindustria europea in una fase già caratterizzata da elevati prezzi dellenergia, crescente pressione competitiva internazionale e limitata disponibilità di tecnologie mature e scalabili per la…

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

As the leading EU producer of recycled aluminium alloys subject to the EU ETS, with an annual production capacity of 350,000 tonnes, Raffmetal is among the operators most significantly affected by the ongoing revision of ETS benchmarks. Over the past years, we have invested extensively in improving energy efficiency and reducing greenhouse gas emissions.

Please find attached our comments on the consultation on the benchmark update (2026-2030), including the legal opinion referred to therein on the possible inclusion of biomass installations in the benchmark calculation. We invite the European Commission to take these documents into account in the ongoing consultation process.

Filed in German · English published by the European Commission

Confindustria Abruzzo Medio Adriatico, principale Associazione di Categoria delle imprese Abruzzesi di Chieti Pescara e Teramo, esprime forte preoccupazione per la proposta della Commissione di aggiornamento dei benchmark ETS per il periodo 2026-2030, che rischia di aggravare in modo significativo i costi a carico dellindustria europea in una fase già caratterizzata da elevati prezzi dellenergia, crescente pressione…

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

On behalf of the Polish steel sector, I hereby submit our contribution in response to the European Commissions public consultation on the revision of benchmark values for the allocation of free emission allowances under the EU Emissions Trading System (EU ETS) for the period 20262030.

ANPIT welcomes the initiatives undertaken by the European Union aimed at strengthening the Single Market and ensuring an increasingly uniform and predictable regulatory framework for businesses operating within the European economic area.

The European ceramics industry is concerned about the proposed draft implementing regulation on the review of the Emission Trading System (ETS) benchmarks for 20262030 and in particular about the new reduced values under the benchmark approach for substitute fuels.

Filed in Polish · English published by the European Commission

Valmet is a globally leading developer and supplier of process technologies, automation and services for the pulp, paper and bioenergy industries. A significant share of global paper production relies on Valmet technologies.

The application of these new benchmarks will be immediate (period 2026 2030) and therefore too rapid. The 34 % reduction in the heat benchmark will have a major impact on the competitiveness of the dairy industry and, in particular, on drying activities.

Filed in French · English published by the European Commission

The Spanish ceramic tiles industry would like to express its concerns about the draft Implementing Regulation on updating the ETS benchmarks for the period 2026-2030 and in particular about the proposed reduction for the fuel benchmark. The methodology used to determine this benchmark groups together very heterogeneous industrial sectors, with very different technological realities and decarbonisation potentials.

Filed in Spanish · English published by the European Commission

The Association of Refractory Producers in Poland is an organisation that brings together industrial, commercial and scientific research institutes, universities and other organisational units active in the refractory industry.

Filed in Polish · English published by the European Commission

The Association of the Chemical Industry of the Czech Republic strongly disagrees with the lowering of benchmark values proposed by the European Commission. Limiting the volume of free allocation at a time when European industry is facing extremely difficult economic conditions will not primarily lead to technological transformation and emission reductions while maintaining production in Europe, but rather to the…

Filed in Czech · English published by the European Commission

In connection with the ongoing work on updating benchmarks under the EU ETS for the years 20262030, we present our position regarding the heat benchmark, with particular emphasis on heat from industrial combined heat and power plants. 1.

From the point of view of the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020. While international competition has since continued to show no relevant additional CO2 costs, the cost pressure from declining allocation in the EU is rapidly increasing.

Filed in German · English published by the European Commission

The German Sawmill and Wood Industry Federation (Deutscher Säge- und Holzindustrie Bundesverband) welcomes the EU’s objective of consistently aligning emissions trading with climate neutrality by 2030. It is precisely for this reason that benchmarks must not only reflect the technical efficiency of individual installations.

Filed in German · English published by the European Commission

On behalf of OM NSZZ Solidarność-80 at JSW coke S.A., we express our categorical opposition to the planned reduction of the benchmark for the production of coke to 0.143 Mg CO2/t coke. The current CO2 emission factor of 0,217 Mg CO2/t coke was achievable only for coke ovens with orderly coke oven gas management and no longer took into account gas combustion in CHP plants and on-site heat plants.

Filed in Polish · English published by the European Commission

Norske Skog Bruck GmbH’s comments on the European Commission’s public consultation ETS I Adjustment of benchmark values for 20262030 Dear Sir/Madam, Norske Skog Bruck GmbH supports the European Union’s climate objectives and the transition to a climate-neutral industry. As an energy-intensive location for the paper industry, we are constantly contributing to emission reductions and investing in efficiency gains.

Filed in German · English published by the European Commission

FOR SPECIAL GLASS & DOMESTIC GLASS SECTORS At the core of EU policy : competitiveness and decarbonisation From Renaissance Europe to reverse the decline of the manufacturing Industry to the Clean Industrial Deal , a plan for EU competitiveness and decarbonisation, the EU Commission engaged since 2011 to enhance prosperity and competitiveness, boost innovation and decarbonization, reinforce resilience, ensure…

OPEC Grudziądz Sp. z o.o. supports the EU’s climate policy objectives and measures to decarbonise the energy and heating sector. At the same time, we would point out that the proposed revision of the heat benchmark for the free allocation of emission allowances in 20262030 may not reflect the actual operating conditions of the district heating sector.

Filed in Polish · English published by the European Commission

The current technologies for reducing emissions in the aluminium sector are at their limits of what is feasibly possible: this is well illustrated by the proposed two aluminium product benchmarks, which are obtained by comparing peer performance.

Consultation contribution on the benchmark update 2026-2030 (consultation deadline of 8 June 2026) by Papierfabrik Palm GmbH & Co.KG. For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

Ladies and gentlemen, the proposed benchmark update, in its current form, jeopardises the existence of the industrial base of energy-intensive businesses in Europe and thus our location in Germany. For us, as companies in the German pulp and paper industry, the proposed adjustment does not mean a mere deterioration in competitiveness, but a structural disadvantage compared to global, especially Asian competitors…

Filed in German · English published by the European Commission

Consultation contribution to the 2026-2030 benchmark update (consultation deadline of 8 June 2026) Dear Sir/Madam, for the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

As part of the public consultation process, we are submitting the position of Grupa Azoty S.A. regarding the revision of product benchmarks for the years 20262030. We would like to emphasize that the proposed regulation is not adapted to the current economic situation in which the EU industry operates.

In particular, we consider the Heat Benchmark proposal to be a major problem. In our view, the proposed value does not correspond to the technological and economic reality of industrial sites in the period 20262030.

Filed in Czech · English published by the European Commission

The Polish Association of Heat Energy (PTEC) welcomes the opportunity to contribute to the European Commission consultation on the revision of benchmark values under the EU ETS. In the context of ongoing discussions on benchmark reductions affecting industrial sectors, it should be highlighted that district heating already covers the vast majority of its ETS compliance costs, receiving only a limited share of free…

Seqens response EU ETS benchmark revision (20262030) Seqens welcomes the opportunity to provide input on the revision of EU ETS benchmark values for the 20262030 period. As an energy-intensive chemical company, Seqens supports the objectives of the EU ETS as a key instrument to drive decarbonization.

In connection with the ongoing work on updating benchmarks under the EU ETS for the years 20262030, we present our position regarding the heat benchmark, with particular emphasis on heat from industrial combined heat and power plants. 1.

The position of the Polish Ceramic Union on the European Commission’s position setting the values of the EU ETS benchmarks for 20262030 is concerned about the position of the European Commission, which, despite numerous reservations and widespread opposition from the Member States and various institutions representing the ceramic industry in Europe, remains steadfast in its approach and does not envisage significant…

Filed in Polish · English published by the European Commission

Confindustria Veneto Est is deeply concerned about the Commissions proposal to update the ETS benchmarks for the period 2026-2030, which risks significantly increasing the costs for the European industry at a time already marked by high energy prices, increasing international competitive pressure and limited availability of mature and scalable technologies for the decarbonisation of hard-to-abate sectors.

for many years, the ETS has pushed this company to invest in low carbon emissions. For several years, there have been no other technologies available that could further support the reduction of the co2 emitted. The system becomes a sterile burden on the economic accounts without any further environmental improvement effect.

Filed in Italian · English published by the European Commission

Please find attached our submission to the consultation on the Benchmark Update 20262030 including the legal opinion referenced therein concerning the potential treatment of biomass installations within the benchmark calculation. We encourage the European Commission to consider these documents as part of the ongoing consultation process.

Evonik supports the objective of the European Emissions Trading System (EU ETS1) to put a price on CO emissions. However, the associated industrial transformation towards climate neutrality must not lead to industry being deprived of its economic basis in Europe. This would result in far reaching deindustrialisation and a shift of emissions to other world regions.

Schoellershammer GmbH consultation contribution to the 2026-2030 benchmark update (consultation deadline of 8 June 2026). For the German pulp and paper industry, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

Given that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

With regard to plans to reduce the benchmark to 31.1 kg/GJ, which represents 75 % of the benchmark for heat, which is 41.6 kg CO/GJ, and bearing in mind that, under the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

Given that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

Given that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

The proposal of the Board of Directors of EC Zagłębie Dąbrowskie sp. z o.o., bearing in mind that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

Roquette supports the EU ETS as a central instrument for industrial decarbonisation and recognises the role of benchmarks in incentivising efficiency while preserving protection against carbon leakage. The current heat and fuel fallback benchmarks bring together activities with different industrial processes, energy configurations, decarbonisation pathways and exposure to international competition.

BASF welcomes the opportunity to provide feedback to the Commissions Draft Proposal on the Revision of the benchmark values for free allocation of emission allowances (2026 - 2030). BASF is committed to achieving climate neutrality by 2050 across its global operations.

Given that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined.

Filed in Polish · English published by the European Commission

Given that, according to the ETS Directive, benchmark values for products are determined on the basis of the average emissions of the 10 % most efficient (least carbon-intensive) installations in a given sector in the EU, it is necessary to clarify how they are determined. 1.

Filed in Polish · English published by the European Commission

Please find attached (i) our consultation contribution on the Benchmark Update 20262030 and (ii) the legal opinion referenced therein on the possible treatment of biomass installations in the benchmark calculation. We kindly ask the European Commission to take these documents into account in the ongoing consultation process.

Summary of PGEs Position The heat benchmark is of particular importance for district heating, as it directly determines the level of free allocation for heat production. In the published Annex, the heat benchmark value for 20262030 is set at 31.2 allowances/TJ (equivalent to 31.2 kg CO/GJ), which corresponds to a 34.1% reduction compared to 20212025 and reaches the maximum reduction level under the current benchmark…

In view of the fact that, under the ETS Directive, benchmark values are determined based on the average emissions from the top 10% of the most efficient (lowest-emitting) installations in a given sector within the EU, the method for determining these values should be clarified. 1.

The Czech Republic wishes to underline the critical importance of the benchmark revision for the period 20262030. Timely finalization of the revised benchmarks is essential to ensure legal certainty and the smooth allocation of free allowances already for 2026.

Consultation contribution to the benchmark update 2026-2030 by Verband Bayerischer Papierfabriken e.V. (consultation period until 8 June 2026). For the German and Bavarian pulp and paper industries, the proposed benchmark update will further significantly weaken the competitiveness of the sector. A competitive level of allotment last existed in 2020.

Filed in German · English published by the European Commission

As an operator of a styrene production facility, we do not agree with the change in the benchmark a tightening of the benchmark by a maximum of 50% compared to the benchmark value set in Regulation 2011/278/EU (resp. 2019/331).

As a TiO2 producer, we operate in a specific sector, which is subject to EU ETS fuel and heat Benchmarks. The TiO2 market requires to produce more competitive products every year, which requires to make extraordinary efforts to retain our customers.

In the WVMetalle’s view, the considerable tightening of the fallback benchmarks provided for in the draft leads to a massive increase in the risk of carbon leakage. The envisaged reduction of up to 50 % would de facto lead to a drastic reduction in the free allocation of emission allowances and would threaten the very existence of a number of companies in the non-ferrous metals industry.

Filed in German · English published by the European Commission

The revision of EU ETS benchmark values for 2026-2030 is a key element to ensure that the EU ETS continues supporting both industrial competitiveness and the objectives of the European Climate Law and the Fit for 55 package. H2SITE welcomes the Commissions efforts to update benchmark values based on recent emissions performance data and technological developments.

Please find enclosed the position of the Polish lime industry. The proposed benchmark values for 20262030 for the lime sector are technically unattainable, disconnected from the sector’s carbon reality and contrary to the objectives of carbon leakage protection as expressed in Directive 2003/87/EC.

Filed in Polish · English published by the European Commission

SaveClimate.Earth welcomes the European Commissions efforts to update the benchmark values for free allocation in line with technological progress and newly available data. This revision is an important step to maintain the effectiveness of the EU Emissions Trading System. However, several structural issues remain unresolved and in some cases are even reinforced by the proposed adjustments. 1.