Revision of the Energy Tax Directive

The European Cockpit Association (ECA) is the representative body of European pilots associations, striving for the highest levels of aviation safety and fostering social rights and quality employment for pilots in Europe. It represents 40.000 pilots from across Europe.

The Global Alliance Powerfuels welcomes the much-needed revision of the EU Energy Taxation Directive (ETD) and endorses the European Commission’s goal to support the EU's delivery of its climate targets by drafting an adequate taxation scheme that recognises the environmental performance and promotes the market integration of renewable energy carriers, including RFNBOs.

AOP is the Spanish Oil Companies Association. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050. We believe that the Oil & Gas sector has an important role to play in responding to this challenge being, thus, a relevant stakeholder to consider in the review process of the Energy Taxation Directive (hereinafter called ETD).

Europe’s airlines are fully committed to decarbonize air transport and are accelerating their efforts to make Europe the world’s first carbon-neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, and through mitigation.

Bioenergy Association of Finland supports the target to reach EU climate neutrality in a socially, economically and ecologically sustainable way prior to 2050. The Association underlines the need to agree a balanced FF55 package that supports the -55 % emissions reduction goal rather than a wide set of other goals. The ETD proposal sets taxation levels based on environmental impacts as well as based on end use.

Italgas welcomes the adoption of the Fit 4 55 package, both in spirit and in substance. We firmly believe in the EU’s climate targets and are striving to decarbonise our business by further making gas grids a key asset of the energy transition. We strongly agree with the necessity to update the levels of taxation of all fuels to update it to current needs, trends, and technologies.

Air Liquide very much welcomes the European Commission’s proposals to make the EU's climate, energy, land use, transport and taxation policies fit for reducing net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels. We firmly believe that all available emission reduction technologies need to be supported in order to reach the EU Green Deal targets.

We welcome the opportunity to comment on the Commission proposal to revise the Energy Taxation Directive. By focusing on environmental performance of energy products as well as the implementation of the polluter-pays principle, the revised ETD will effectively incentivise energy efficiency and decarbonisation efforts.

Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.

Aligning air traffic and climate protection is a common goal of society, politics and the aviation industry. The regulatory framework should pursue ambitious and binding targets for CO2 reduction and at the same time ensure that European aviation, including value creation and employment, is not discriminated in international competition.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a COUNCIL DIRECTIVE restructuring the Union framework for the taxation of energy products and electricity (recast)“. Please find detailed comments in the Attachment.

The main objective of the ETD is to support the proper functioning of the internal market by avoiding double taxation and other distortions of trade and competition between energy sources and energy consumers and suppliers. The ETD therefore provides Member States with energy tax tools while indirectly supporting the objectives of other energy and climate legislation.

ZOE Institute for Future-fit Economies welcomes the opportunity to provide feedback on the proposed revision of the Directive restructuring the Community framework for the taxation of energy products and electricity from 27 October 2003 (2003/96/EC). As part of the Fit for 55 package, this revision is a key opportunity to spark a fair and green tax reform across the EU.

In line with the current provisions of the Energy Taxation Directive (ETD), Member States may apply a level of taxation down to zero to energy products and electricity used in the agriculture, horticulture, and forest sectors/activities. Confagricoltura asks for the current derogations concerning the levels of taxation to be maintained.

IFIEC Europe, representing energy intensive industries (EIIs), welcomes the revision of the ETD that should give industry better visibility on tax framework and enable it to make long-term investment decisions. However, IFIEC is concerned by the impact on industries’ competitiveness which will be created by the general increase of the minimum taxation level and the cancellation of most of the possibilities for…

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

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The Green Deal highlights the use of wood as an effective tool for climate protection, such as the New European Construction House, the ‘Renovation wave to renovate today’s economy and create tomorrow’s green buildings’ or the Renewable Energy Directive III. The production of heat and electricity from wood by-products contributes significantly to decarbonisation through the substitution of fossil fuels.

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The UNIDEN welcome the revision of the Energy Taxation Directive (ETD), aligning the text with the 2030 55 % GHG reduction objective of the European Union. The general alignment of minimum tax rates in function of energy content is. However, any overplay with other EU legislation shall be open. In particular, CO2 emissions are ready to be regulated by the ETS Directive.

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Taxing fuels based on their environmental performance and broadening the scope of taxation: positive steps to make the ETD a key lever to establish price parity between clean and fossil fuels In the revision proposal, Hydrogen Europe welcomes: • the inclusion of hydrogen under the scope of taxation, recognising the role hydrogen can play in many end-uses, including as a heating and motor fuel; • the possible…

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation.

We support the ambitious targets of the Paris Agreement on Climate Change and strongly believes that the Fit for 55 package must become a flagship initiative for global climate solutions. However, regarding the proposed revision of the Energy Taxation Directive, we find that it would lead to significant carbon leakage, competitive distortion and therefore even a loss of connectivity of the EU and negative…

Bellona Europa welcomes the proposed revision of the Energy Tax Directive primarily because of the weight of environmental factors in defining the level of taxation has increased. Moreover, the strive to foster the use of renewable electricity across the directive is a very positive development.

The agriculture and forestry sectors are the only sectors capable of providing not only carbon sequestration but also alternatives through renewable raw materials to substitute fossil-based products. European farmers and agri-cooperatives are ready to play their part in delivering the ambitious EU climate objectives.

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

The EU Primary Food Processors Association (PFP) welcomes the Commission’s ETD revision proposal as well as the ambitious GHG emission reduction targets set by the EU Climate law. Our sectors are committed to further reducing emissions into the future. Energy costs make up a substantial share of Primary Food Processors’ manufacturing costs.

The taxation of energy products and electricity is a central tool to drive a fair, consistent and cost-efficient energy transition. It will be central to give the right signals to an energy-efficient and renewable-based electrification of Europe.

Aviation and shipping fuels do need to be taxed. The climate crisis is urgent, and the IPCC Special Report on 1.5°C makes it abundantly clear that global GHG emissions need to drop by 45% at least this decade. Fossil fuel consumption from international transport is a significant contributor to climate breakdown.

COGEN Europe supports the review of the Energy Taxation Directive (ETD) in the context of Fit for 55 and its alignment with the EU’s energy efficiency, climate and competitiveness priorities. To ensure that energy taxation can fulfill its crucial role in driving the development towards a carbon-neutral energy system in line with the EU’s climate ambitions, the revised ETD should incentivise the energy efficient…

NGVA Europe welcomes the revision of the Energy Taxation Directive, which should align with the increased GHG emission reduction targets of the EU. NGVA Europe is convinced that the only way of achieving a quick decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).

The European Business Aviation Association (EBAA) calls on Member States and the European Commission to build a fair, inclusive and non-discriminatory energy taxation framework for business aviation. Key takeaways (more details in the attached position paper): - Business Aviation is ready to play its role in the transformation of the EU into a modern, resource-efficient and competitive economy, which would lead to a…

The YESO Technical and Business Partnership, ATEDY, welcomes the “Goal 55” package for Europe to reduce its GHG emissions by at least 55 % by 2030 and strongly believes that low carbon and light construction solutions, such as plaster-based products, are key to achieving the ecological transition.

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

Teréga welcomes the "Fit for 55" package presented by the European Commission (EC), and wishes to propose several recommendations and areas for improvement to make the Fit for 55 package even more effective. The attached document shortly highlights Teréga’s main attention points in order to make sure that the net-zero objective set by the EC is reached as swiftly as possible and at the lowest-possible cost for the…

Fluxys welcomes the opportunity provided by the Commission through this feedback period for stakeholders to provide views on the Commission’s adaption regarding Energy Taxation Directive (ETD) back in the summer of 2021 with the aim of feeding into the legislative debate at the European Parliament and Council.

The current ETD has incentivised the uptake of LPG and contributed to meeting the EU climate objectives. Liquid Gas Europe recognises however that the rules are outdated and therefore welcomes the proposal on the revision of the Directive.

• Double charges on energy sources which are already subject to explicit CO2 pricing, whether national or EU, must not exist. • The objective of electrification of many processes as a necessary measure of the transformation process makes it necessary to reduce the burden on electricity as a source of energy, regardless of its technological form.

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The Swedish Gas Association – Energigas Sverige – welcomes a review of the Energy Tax Directive (ETD). The current ETD is an outdated directive from 2003 that does not reflect the EU’s climate goals. We welcome the position taken in “Fit for 55” that regulations should work better together but it is a challenge that so many directives are being changed at the same time while also referring to each other.

Statkraft supports the main framework of the revision of the Energy Taxation Directive (ETD). Energy taxation should reflect the energy value and carbon content of an energy product, so that clean energy products will be taxed the lowest. The new minimum tax rate should be decided by the link between the energy products and the environmental performance.

- Consistent with IPCC guidelines, CO2 pricing should not apply to biofuels and biomass. - Derogation for fuels used in agriculture, horticulture and forestry must be maintained. - The ETD should differentiate between sustainable biofuels and fossil fuels. Therefore, the proposal to attribute the same tax rate to fossil fuels (petrol and diesel) and sustainable crop-based biofuels in 2033 should not be accepted.

The Enel Group strongly welcomes the proposed review of the Energy Taxation Directive. Such review has been long due. There is an increasingly urgent need to align EU energy taxation with enhanced climate and environmental objectives and take into account current and projected energy technologies’ development.

— The VBO fully supports the European Commission’s choice to use energy content as the basis for the tax rather than the volume of energy carrier consumed when revising the ETD. This adjustment is in line with the objective of the Green Deal to improve energy efficiency.

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

Solvay asks to foresee a transition period before any tax increase to enable the energy decarbonation Solvay is concerned by the impact on the competitiveness and long-term investments decisions which will be created by the general increase of the minimum taxation levels and the cancellation of most of the possibilities for exemptions and tax reductions in particular for energy intensive industries (EIIs).

Abridged Version - See attached PDF General remark In Annex I of the Proposal we notice the “horizontal” character of the minimum tax rates irrespective of each MS’s economic indicators, industrial profile or GHG emissions.

Essenscia, the federation representing the Belgian chemical and life sciences industry, welcomes the update of the scope of the Energy Taxation Directive (ETD) that recognizes new energy carriers, like hydrogen, and the alignment on energy content of carriers.

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

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2…

Lantmännen welcomes and is pleased to have the opportunity to share its recommendations on the review of Directive 2003/96/EC (hereafter ETD) in the context of the European Green Deal. The ETD revision represents an opportunity to update the Directive to ensure it is harmonized with recent EU energy and transport legislations, incentivize the use of all renewables in transport - including sustainable crop-based…

E.ON welcomes the long overdue revision of the Energy Taxation Directive. To align energy taxation with the overarching requirements of the Green Deal, it is important to steer the European economy and consumer behavior patterns towards increasingly sustainable choices. Please find our response attached.

Liquid Wind welcomes the European Commission’s proposed revision of the Energy Taxation Directive as a part of the Fit-for-55 legislative package. Liquid Wind is a Swedish Power-to-Fuel Development Company committed to reducing carbon emissions.

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. In 2018, the use of waste-based biodiesel in German road transport reduced GHG emissions by 3.6 million tons.

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

For energy-intensive commodity industries such as the steel industry, taxation of energy, even if based on CO2 content, is in principle not an appropriate instrument to support the transformation towards low CO2 technologies and climate-neutral energy consumption.

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General comments The Danish Agriculture & Food Council agrees with the need to update the Energy Taxation Directive. The current rates in the Directive are not balanced according to energy or CO2 content, and in some cases the Directive affects RES more heavily than fossil fuels. It does not contribute to the green transition.

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As demonstrated by the EU decarbonisation strategy for 2050, energy storage technologies are playing a valuable role in the transition to a low-carbon energy system. This role is only set to increase with upward revision of the 2030 decarbonisation targets. In order to enable the deployment of energy storage the barriers that hamper a robust storage business case should be avoided. EA 1.

We duly welcome the proposal to harmonize energy taxation throughout the EU in order to progress on the implementation of the EU internal market also for energy. Nevertheless, any such progress needs to be well integrated into the legal framework of the EU based on transparent, holistic and reliable planning taking international competitiveness fully into account and aiming at utmost planning certainty.

With the "Fit for 55" package, the Commission has presented a comprehensive legal package aimed at reshaping the EU's climate policy. The German automotive industry supports the goal of making road transport climate-neutral by 2050 at the latest.

CEPM wishes to transmit its comments on various texts proposed in the “fit for 55” package. In general, CEPM regrets that the contribution of crop based biofuels, including corn bioethanol, is not better supported. CEPM requests that the role of these biofuels be improved, and that it is reflected systematically in the various texts. Please find attached our comments.

The Polish Electricity Association (PKEE) supports aligning taxation of energy products and electricity with the EU climate policy, to contribute to the 2030 targets and climate neutrality by 2050. However, the revision of the Energy Taxation Directive (ETD) must not result in additional increase in energy prices for consumers.

Dear Madam or Sir Please find attached GAMA’s feedback on the EU Green Deal – Revision of the Energy Taxation Directive. Please feel free to contact me, should you require any additional information or have any questions. Best regards [name removed] R. FABIAN Director, European Affairs

Enagás supports a revision of the ETD. The current directive has been in place since 2003 and is outdated. As part of the ‘Fit for 55’ package, a common EU-framework on the taxation of energy products is necessary for the smooth functioning of the energy market, to take account of the new energy mix and to deliver on the EU’s climate ambitions.

Dear Commission, We would like to fully support the comments and justification expressed by Eurofer in its position document (attached). As such we fully support the following: • The alignment of the Energy Taxation Directive with the objectives of other EU legislation, especially in climate and energy policy shall be compatible with renewable and low carbon energy needs and mitigate the risks inherent to the…

Federmetano welcomes the revision of the Energy Taxation Directive in line with the increased GHG emission reduction targets of the EU. In Federmetano’s view, the only way of achieving a quick and effective decarbonisation of road transport is to support all existing solutions, including biomethane (bioCNG and bioLNG).

The European Commission has put in public consultation a proposal for a directive restructuring the EU framework for the taxation of energy products and electricity. This project calls for comments from the Renewable Energy Union (RES), as set out in the attached document.

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ESWET – the European Suppliers of Waste to Energy Technology – represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. ESWET welcomes the European Commission’s proposal for the revision of the Energy Taxation Directive (ETD), as it accurately sets preferential tax rates for the use of renewable and low-carbon fuels and hydrogen for end-consumers, and shifts…

Waste to Energy (WtE) facilities treat household and similar waste that cannot be prevented, reused or recycled. Through the thermal treatment process, the facilities recover energy from the waste. The energy, categorised as partly renewable due to the partly biogenic feedstock, is defined as biomass under the Renewable Energy Directive. This energy can be in the form of steam, electricity or hot water.

In principle, the orientation of the ETD towards climate protection is welcomed, as it puts an end to the preferential treatment of fossil energy sources. However, there are some details to address in more clarity. 1. Definitions of categories There are no clear definitions within the Directive.

The Finnish Shipowners’ Association (FSA) welcomes the opportunity to comment on the Commission’s proposal to revise the Energy Taxation Directive. The FSA welcomes the European Commission’s Fit for 55 package and supports its ambition to deliver the European Green Deal.

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

North European Oil Trade (NEOT) contributes to this consultation from the perspective of an independent fuel procurement company in the Baltic Sea region. We supply annually roughly 7 billion liters of fuel products to transport, heating, aviation, and marine sectors in Finland, Sweden, and Norway. Our supply represents approximately 40% of the total fuel consumption in Finland, 30% in Sweden, and 35% in Norway.

The Technology Industries of Finland (TIF) is committed to the fight against climate change and sees that the EU and its Member States must make rapid progress in implementing their emission reduction commitments under the Paris Climate Agreement. We are in favor of tightening the EU's 2030 emissions reduction target to 55% and the goal of climate neutrality in the Union by 2050.

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

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

The European Carbon and Graphite Association (ECGA) acknowledges the publication of the Fit for 55 Package as the largest and probably the most significant cluster of measures the EU has ever published at the same time, towards the same goal, namely, the EU carbon neutrality by 2050.

Company Plinovodi, as a transmission system operator in Slovenia, supports the ambitions of Commision to harmonise energy tax legislation in EU. However, there shall be enough flexibility to accomodate specific situation in different Member states. Please find below two proposals in this direction.

We commend the Commission's proposal for a fundamental shift in the minimum taxation of energy. Due to the current incoherent system, which includes ambiguous definitions and national loopholes, green electricity does not receive the support it needs, despite the critical role electrification will play in Europe’s decarbonization.

Zwiazek Pracodawcow Polskie Szklo, the Polish Glass Manufacturers Federation, welcomes the opportunity to provide feedback on the Commission proposal regarding Energy Taxation Directive (ETD). To reach carbon neutrality, glass manufacturing companies are investing massively in new technologies and R&D. This investment effort will take place in a context of high CO2 prices and energy prices.

With “Fit for 55”, the Commission has presented a comprehensive package of 13 pieces of legislation with the objective of reshaping the EU's climate policy on a large scale. BMW Group is convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation.

Our sector is in favour of aligning the taxation of energy products with the EU’s energy and climate objectives. The introduction of both an energy & environment (CO2 based) tax for transport must be part of a comprehensive approach and an integrated tax mechanism. The objective is to give a credible price signal to guide citizens’ choices gradually towards “lower carbon mobility solutions”.

LanzaTech commends the European Commission’s ambition in its revision of the Energy Taxation Directive (ETD). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward.

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

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1) Energy content and environmental performance based taxation is the right way to go Neste supports the shift in the ETD proposal from a volume to an energy content-based taxation model. In addition, rewarding environmental performance is very important and is taken into account in the proposal as sustainably produced renewable fuels, both biofuels and e-fuels, are proposed to be taxed at lower rates than fossil…

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

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

Glass Alliance Europe input to the Public Consultation on the Revision of the Energy Taxation Directive (ETD). 17 November 2021 Glass Alliance Europe (GAE), the European Alliance of Glass Industries, welcomes the opportunity to provide feedback on the Commission proposal to introduce a Energy Taxation Directive (ETD). Given the 4,000 characters limitation, this input will focus on the main elements.

REPSOL is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050. We welcome the opportunity given to provide input to the Public Consultation on the proposal of Revision of the ETD.

EU airlines and their employees have already and will continue to substantially invest in decarbonisation. E4FC members, therefore, welcome the proposed measures to significantly reduce CO2 emissions and to achieve CO2-neutrality in aviation by 2050.

The European Automobile Manufacturers Association (ACEA) welcomes the Commission’s proposal to the Council on the restructuring of the Union framework for the taxation of energy products and electricity. Within the fit for 55 package, the ETD is one of the key measures for an effective policy framework that supports and enables the transition to carbon-neutrality. ACEA’s position paper on ETD is attached.

NLA welcomes the objective for more uniform taxation for EU Member States, industries and energy products, to ensure a level playing field, including across competing modes of transport in the freight transport sector. The vast majority of heavy duty vehicles involved in goods transport are diesel driven today.

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

AIRE (Airlines International Representation in Europe) shares its view on two documents which have a significant impact on the future functioning of aviation: Regulation on ensuring a level playing field for sustainable air transport (RefuelEU Aviation) and Energy Taxation Directive (Revision).

The Austrian gas and district heating industry supports the objective of net-zero greenhouse gas emissions by 2050 and sees the period up to 2030 as an important intermediate step. In this context, the EU Energy Taxation Directive (ETD) can be an effective, market-based instrument to give appropriate price signals to energy consumers and thus achieve a targeted change in consumption patterns in line with climate…

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

Please find our Position paper on EED and RED: The implementation of the results of energy audits under the Energy Efficiency Directive (EED) and the link to the ETS is critical. There is a risk that the free allocation in the ETS will be reduced by 25 % if audit measures are not implemented.

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PGNiG welcomes the possibility to comment on the ETD proposal. We believe that the revision of the ETD should take into account EU energy policy objectives as enshrined in Article 194 TFEU: security, competitiveness and sustainability. Moreover, it should contribute to the goals of the Energy Union: to give EU consumers – households and businesses – secure, sustainable, competitive and affordable energy.

Forum Ökologisch-Soziale Marktwirtschaft (FÖS) e.V. (Green Budget Germany) welcomes the opportunity to comment on this proposal. Appropriate energy taxation is necessary to create incentives for a transformation to more renewable energies and more energy efficiency. In addition, an effective energy tax directive reduces the incentive for Member States to undercut each other with low tax rates.

The Federal Association of Energy and Water Management (BDEW) supports the revision of the Energy Tax Directive to create a modern framework that contributes to the EU’s climate change objectives in the context of the European Green Deal.

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Gas Networks Ireland (GNI) welcomes the publication of the European Commissions (EC) legislative proposal for the revision of the Energy Tax Directive (ETD). The move to more simplified energy-based taxation system including the indexing of minimum rates to reflect real time value and the removal of Member State specific rates and derogations are all necessary and welcome changes to the ETD.

This paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the Fit for 55 package proposals. It provides an analysis and the first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission.

FuelsEurope response to the public consultation of the Energy Taxation Directive (ETD) proposal. FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, member states, and stakeholders, to help create the essential enabling policy framework.

Position of PGE Polska Grupa Energetyczna S.A. on the proposal for a recast of the Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity • The revision of Council Directive 2003/96/EC of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity leads to a significant increase in the…

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Achieving the ambitious climate and energy targets envisaged within the European Green Deal and the improvement of the internal market functioning require revision of the Energy Taxation Directive (ETD) which has not undergone any changes since 2003.

We welcome the European Commission’s proposal to realign the Energy Taxation Directive. The proposal makes it possible to shift the tax base to the energy content factor and, at the same time, to categorise the various energy products, with the possibility of a more realistic taxation of energy sources in the interests of an ambitious climate change policy.

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The European Commission misses the opportunity to introduce a common minimum tax rate for carbon dioxide emissions. This is remarkable given that the proposed directive is part of the Green deal. Our proposal is a minimum carbon dioxide tax of 25 €/ton CO2 for all sectors outside ETS. This would be a better incentive than the proposed ETS-system for buildings and transport.

Reforming of the Energy Taxation Directive is essential to set up a European framework conducive to the fast uptake of renewable energies by European citizens, businesses and the public sector. A successful reform will provide strong positive price signals to shift to renewable energies, especially renewable gases, such as biomethane.

The Energy Taxation Directive was approved in 2003 and has needed a revision for several years. As it deals with member states taxation it needs unanimous approval. A taxation on fossil fuel content is often a cost-effective way to achieve decreased emissions. It has been poorly used, and while many members states, as is the Commission, look at a carbon tax, we have not seen it in practise.

Business travel is fundamental to the world economy and brings many benefits in terms of international connections and wealth creation. However, climate change is a global threat and responsible governments, industries and corporations must continue to work together to reduce carbon emissions and operate in a more sustainable manner.

The new energy taxation system proposed by the Commission, applicable from 2023, considers electricity among the least taxed energy sources in view of fostering its use (i.e. 0,15 EUR/Gigajoule as for Advanced sustainable bioliquids, biogas and Renewable fuels of non-biological origin).

We reject the proposal to levy a tax on kerosene. We believe that it would not only undermine the competitiveness of European carriers on the global market, but more importantly, it would slow down the development of the aviation sector in the EU and limit sector's ability to invest in new technologies such as alternative sustainable fuels.

Climate policy must always take into account the need to ensure the supply of energy, in particular electricity, at all times and in every place. The importance of a continuous supply of electricity, but also its challenges, cannot be overestimated. Energy must also be available at costs that enable European industry to compete on global markets in a sustainable manner.

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Dear Sir/Madam, please find enclosed the feedback from the Austrian Economic Chamber. [complimentary close] From: Dr [name removed] Head of Unit Department of Finance and Taxation Policy Austrian Chamber of Commerce Wiedner Hauptstrasse 63 I 1045 Vienna T [phone removed] I F [phone removed] E [email removed] I W https://news.wko.at/fp

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

The Baltic Ports Organization (BPO) welcomes "Fit for 55" proposal. However; there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector. A revision of the Energy Taxation Directive proposes to remove tax exemption on bunker fuels sold within and for use in European Economic Area (EEA).

The Spanish magnesia industry fully supports the objectives of the European Green Deal, as well as the “Goal 55” package aimed at reducing net greenhouse gas emissions by at least 55 % by 2030, as set out in the European Climate Law.

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FinCo Fuel Group and GoodFuels welcome the revision of the European Tax Directive (ETD) as part of the Fit for 55 Package. We support the proposed adaptations which ensure excises structures will stimulate the use of sustainable low carbon energy. In order to achieve this, certain amendments to the current proposal are however needed to propel the transition from fossil fuels to sustainable renewable alternatives.

FinCo Fuel Group and GoodFuels welcome the revision of the European Tax Directive (ETD) as part of the Fit for 55 Package. We support the proposed adaptations which ensure excises structures will stimulate the use of sustainable low carbon energy. In order to achieve this, certain amendments to the current proposal are however needed to propel the transition from fossil fuels to sustainable renewable alternatives.

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

We believe that a revision of the Energy Taxation Directive can help achieve the European Union climate ambitions. Road transport, as a sector with high energy consumption, can further contribute to reducing greenhouse gas emissions if the right framework conditions are set. We therefore welcome the proposal to revise the Directive, in particular with regard to the change of taxation basis.

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy [email removed] Finnish Forest Industries’ response to the consultation on the Energy Taxation Directive (ETD) Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including ETD will provide regulatory stability which promotes the industry’s investments in climate…

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

The Energy Taxation Directive was approved in 2003 and has needed a revision for several years. As it deals with member states taxation it needs unanimous approval. A taxation on fossil fuel content is often a cost-effective way to achieve decreased emissions. It has been poorly used, and while many members states, as is the Commission, look at a carbon tax, we have not seen it in practise.

VCI opinion on the consultation on the revision of the European Energy Tax Directive (ETD) Basic principles of energy taxation With regard to the changeover of the tax base, the VCI considers it necessary to find a solution for alternative fuels. The analysis of the energy content, in particular for substitute fuels, involves a disproportionate effort and is technically impossible in many cases.

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EURACOAL is pleased to submit its attached position paper on the proposed amendments to the Energy Taxation Directive. In summary, we have seven key points to make in response to the European Commission's proposal: • EURACOAL supports the concept of energy taxation based only on the energy content of fuels. In practice, coal has been priced and sold on an energy basis for many decades.

Frances Hydrogène welcomes the recast of the Taxation Energy Directive (ETD) as presented in the “Fit for 55” legislative package. Rules on the taxation of fossil-based energies and clean energies emerging with new low-carbon technologies need to be updated, particularly to match the strengthened EU climate neutrality ambitions.

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

The European Lime Association (EuLA) is concerned about the current orientation of energy taxation at European level. EuLA recognises the convenience of an up-to-date Energy Taxation Directive (ETD) as a pillar of the new legislative setting the European Climate & Energy Policy.

Transport operators are in favour of parts of the proposal. This includes the proposal for a minimum level of energy taxation common to all Member States. It favours fair competition within the Union at company level rather than at national level. Furthermore, taxation should be based on energy content and environmental performance.

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• Given the recast of Council Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity, Czech Gas Association calls for an optional exemption (in the form of total or partial tax exemptions below the minima as in the current Art. 15h) to be maintained for all low- and middle-income households using natural gas for heating at least until 2033.

Eurofuel welcomes the Commission’s proposal and agrees to use carbon content as a reference for energy taxation. We would like to remind the importance of ensuring a level playing field and a technology openness approach for all clean solutions contributing to meeting the EU decarbonisation objectives.

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the recast ETD proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. [name removed]: [email removed]

IMA-Europe, representing the European Industrial Minerals Industry, is concerned about the current orientation of energy taxation at European level. Even if IMA-Europe recognises the need for revising an outdated ETD as a pillar of the new legislative setting the European Climate & Energy Policy, we strongly oppose the EC proposed removal of the “mineralogical processes” exemption. OUR CALLS 1.

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

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UPRIGAZ welcomes “Fit for 55” to adapt EU legislation to the objective of reducing net GHG emissions by at least 55 % by 2030 compared to 1990 levels, to achieve carbon neutrality by 2050. UPRIGAZ supports the approach proposed by the EC in its Fit for 55 package of setting new and more ambitious targets for 2030; Whether it concerns an increase in the share of renewable energy in the European energy mix, an…

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The glass industry wants to continue to support the EU on the path to climate neutrality. With its diverse products ranging from high performance glazing products to resource-saving container glass, reinforcement glass fibres in wind turbines, special glass for the semiconductor industry, the European glass industry is an essential contributor to the energy transition.

The Methanol Institute endorses the Commission’s proposal for the revision of the Energy Taxation Directive (ETD). Restructuring taxation to be based on energy content and consumption, represents an effective method to decrease the relative tax burden for low carbon and net carbon neutral fuels.

Energy taxation directive review sets new principles in the field of energy taxation and bringing unification of tax rates at the EU level. HSE Group believes that the proposed Directive Lacks a clear role of taxation policies of energy products and electricity in the process of decarbonisation and phasing-out of fossil fuels, which are produced or used in the regions that are recognised as regions in the process of…

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The German aviation industry supports the EU-goal of climate neutrality by 2050. CO2 emission pricing plays a pivotal role along with other measures such as increasing the fuel efficiency by exchanging old aircraft with new aircraft. Alone fleet renewal reduced the emissions per passenger by 44% since 1990.

Dear Colleagues, The German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Proposal for a Council Directive restructuring the Union framework for the taxation of energy products and electricity COM(2021) 563 final. Attached please find our position paper.

Iwo Austria is an association that supports the use of liquid fuel heating systems, research and development of liquid fuels and co-design of the transition process from fossil fuels to renewable liquid fuels. The IWO represents the Austrian oil industry and acts as a voice for over 600.000 oil-heater households in Austria, representing around 1,2 million consumers.

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ElaadNL is the knowledge and innovation centre in the field of Smart Charging and the charging infrastructure in the Netherlands and is an initiative of the Dutch grid operators. ElaadNL welcomes the revision of the ETD. In the revision proposal the Commission aims to prevent double taxation in case of energy storage by classifying energy storage facilities as “redistributors” of electricity.

ePURE, the association representing the European producers of renewable ethanol from sustainably grown crops, waste, and residues, appreciates the opportunity to provide feedback on the adoption of the proposal for a revised Energy Taxation Directive.

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

The European cement industry fully supports the objectives of the European Green Deal. As well as the “Goal 55” package aimed at reducing net greenhouse gas emissions by at least 55 % by 2030, as set out in the European Climate Law.

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The Swedish Society for Nature Conservation is grateful for the European Commission to propose a substantially reformed and updated Energy Taxation Directive. The current Directive dates back to 2003 and has long been outdated and outdated, as the Commission itself found in its Impact Assessment Report.

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With the current reform proposal, the European Commission is making a fresh and welcome attempt to adapt the ETD to today’s realities. In the light of the European Green Deal and the widespread recognition among Member States that only a fundamental overhaul of existing EU legislation can contribute to achieving the climate objectives, this reform is in principle to be welcomed!

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The Spanish Bus and Coach Transport Confederation (CONFEBUS) welcomes the opportunity to submit comments on the proposed revision of the Energy Taxation Directive. CONFEBUS is fully committed to the ecological transition and shares the objective of promoting the use of renewable and low carbon fuels, in order to contribute to climate goals and neutrality by 2050.

Please find the position document attached. Conclusions The revised Energy Taxation Directive represents a significant improvement relative to the current legislation. The move from a volume-based to an energy content-based taxation in particular, has the potential to drive decarbonisation in the European economy, provided it is supported by strong flanking measures.

As farmers organisation, we believe that an exception should continue to be possible for fuels used in the agricultural sector. The margins in the agricultural and horticultural sector are so low that any increase in cost weighs on the income of an individual farmer.

VAT on electricity and natural gas in Greece is only 6%, while VAT for solar thermal is 24%. This preferential treatment gives the wrong signal about energy use and it has a larger negative impact than the proposed taxation. Member states should cancel any preferential tax treatment of fossil fuels and electricity.

The coherent and effective taxation of energy products should be the centrepiece of any successful energy and climate policy. It gives a clear price signal to consumers and allocates the costs of the energy transition according to the polluter-pays principle included in article 191.2 of the TFEU.

The coherent and effective taxation of energy products should be the centrepiece of any successful energy and climate policy. It gives a clear price signal to consumers and allocates the costs of the energy transition according to the polluter-pays principle included in article 191.2 of the TFEU.

A. Eurogas welcomes the commitment of the European Commission to align where necessary the Energy Taxation Directive to the objectives of the EU Green Deal, EU’s climate commitments under the Paris Agreement and market developments. Eurogas supports increased 2030 GHG reduction targets and considers natural, renewable and decarbonised gas integral to achieving climate neutrality by 2050.

Association for District Heating of the Czech Republic welcomes opportunity to comment on inception impact assessment of revision of Directive 2003/96/EC (ETD). We fully share the opinion of the Commission that well-designed taxes play a key role in decarbonisation effort by sending the right price signals and providing the right incentives to consumers and producers of energy.

Minerals, metals and advanced materials have a central role in the green transition, e.g. in the energy and transport sector. Ensuring a sustainable supply of raw materials is crucial for Europe's industrial leadership and to achieve a climate neutral, resource efficient and competitive economy.

Contribution from Lantmännen to the Revision of the Energy Taxation Directive, April 2020 As part of the Green Deal, we welcome the Commission’s intention to revise the Energy Taxation Directive. Since its inception in 2003, the Directive has become outdated and does not reflect the EU’s emission reduction ambitions, nor supports the development and expansion of renewable energy, particularly in the transport…

To ensure a fit-for-purpose revision of the current rules, we urge for the following points to be taken into account: 1. Convergence of fiscal rules between Member States must be achieved in order to adequately contribute to the functioning of the Internal Energy Market : The 2019 ETD Evaluation demonstrated that the rates currently applied by MS differ significantly from each other and from the minimum rates…

KGHM Polska Miedź S.A. is a major copper and silver producer (both mining and processing) for more than 50 years. We welcome the Commission’s decision to review the Energy Taxation Directive (ETD) and to provide an opportunity to respond to the public consultation on the Roadmap for its revision.

The Confederation of Swedish Enterprise Welfare the Green Deal and the holistic perspective that chartered the strategy and we also support the EU ambition to be neutral by 2050. Both the Commission and the Member States (MS) need to conclude to a long-term policy framework with specific objectives, and simple and clear rules to provide the this stable environment.

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DUON Dystrybucja sp.z o.o. as a company operating on the natural gas market, LNG (Liquified Natural Gas) wants to draw the European Union's attention to the natural gas market as a fuel which, through appropriate tax stimulation, can significantly contribute to achieving Europe's climate goals.

ANODE – draft reply to the consultation regarding the revision of the energy taxation directive The association A.N.O.D.E, which gathers the main alternative suppliers of electricity and gas in France, supports the Commission’s initiative to review the Energy Taxation Directive to be consistent with the EU energy and climate objectives by 2030 and climate neutrality by 2050.

Following the publication of the EU Green Deal in December, the Commission has announced the revision of the Energy Taxation Directive (hereafter “ETD”). The 2003 Energy Taxation Directive is obsolete and needs to be reviewed so that it provides an effective framework to Member States to reach their decarbonisation targets and facilitate a smooth functioning of the internal market.

EURACOAL supports the Commission’s efforts to align the Energy Taxation Directive (ETD) with other measures such as the EU ETS, the Renewables Directive and the Energy Efficiency Directive. However, as this discussion is at a very early and preliminary stage, with no draft proposal or impact assessment presented by the European Commission, our comments can only be of a very general nature. 1.

The EEB welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment for the revision of the Energy Taxation Directive (ETD). We agree with the analysis carried out by the European Commission pointing out the lack of consistency of the current energy taxation regime with the objective set in the European Green Deal of achieving climate-neutrality by 2050 at the latest.

The following points referred to the EC Inception Impact Assessment intend to represent a first SNAM contribution to the Energy Taxation Directive revision process. • It is important that natural gas taxation regime in the different sectors is kept at the current levels (or even reduced), taking also into account the increasing percentage of low carbon and green gases (biomethane, blue and green hydrogen) in the…

The Association of the Automotive Suppliers’ industry in Europe welcomes the opportunity to provide feedback on the roadmap for the revision of the energy taxation directive. CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 25 billion euros yearly in research and development.

REF: Revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity (ETD) CIROM, Employers’ Organisation in Cement Industry and other Mineral Products for Construction in Romania welcomes the European Commission’s initiative for a revision of the ETD in light of the recently published European Green Deal.

The European cogeneration sector is committed to the creation of a resilient, decentralised and carbon neutral European energy system by 2050 with cogeneration as its backbone, empowering European citizens and industry to generate their own efficient, reliable and affordable clean heat and power locally.

• All EU policies, actions and strategies should be consistent and deliver upon both the climate objectives and the sustainable development goals across the full set of their environmental, economic and social dimensions.

We suggest to introduce a taxation of fuels for aviation. A taxation of kerosene is necessary to generate equal competition rules for all kinds of traffic and to give an incentive to save fuel used for air traffic.

Consultation on “Inception Impact Assessments” Directive on energy taxation/March 2020 Feedback on options to revise the energy taxation directive. The Association Générale des Producteurs de Maïs (AGPM) and the Association Générale des Producteurs de Blé (AGPB) agreed with the Commission’s conclusions that the current energy taxation directive did not meet the new ambitions on the decarbonisation of energy…

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The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully in the EU-internal market integrated and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the inception impact assessment for a revision of the EU energy taxation directive (ETD). I.

Consultation on “Inception Impact Assessments” Directive on energy taxation/March 2020 Feedback on options to revise the energy taxation directive. The Association Générale des Producteurs de Maïs (AGPM) and the Association Générale des Producteurs de Blé (AGPB) agreed with the Commission’s conclusions that the current energy taxation directive did not meet the new ambitions on the decarbonisation of energy…

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The planned revision of the Energy Taxation Directive is an excellent carbon pricing tool, which could help putting the transport sector back on track to achieving climate neutrality by 2050. If deployed in the right way, ETD can help influencing sustainable investment choices by sending right pricing signals. ETD should thereby reflect external costs related to C02 impact by applying the Polluter Pays Principle.

European Energy Retailers (EER - www.europeanenergyretailers.eu) agrees on the need for a revision of the energy taxation directive. Such process should be aimed at: · Guaranteeing consistency with the EU climate policy and 2030/2050 objectives · Avoiding distortions between energy products which are not related to the climate impact or to the energy density of the product · Phasing out environmentally harmful tax…

Please find attached our response to the most recent public consultation on the Energy Taxation Directive. Moving ahead, Eurometaux looks forward to the official public consultation and will provide input to the European Commission through this process.

Greenpeace welcomes the initiative by the European Commission to bring the Energy Taxation Directive and wider EU and national taxation policies in line with the EU's climate commitments. This submission spells out the key elements that Greenpeace believes the EU should take into account for the next revision of the ETD in 2021.

The Belgian Federation of Enterprises (VNO FEB) supports the stated objectives of the revision of the ETD (Directive 2003/96/EC) and calls on the Commission to ensure competitive energy prices (including taxes, surcharges, etc.) for our companies, especially those intensive in energy subject to international competition. These are both international prices (outside Europe) and prices in the European market.

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Jernkontoret, the Swedish steel producers association, welcomes the Green Deal and the holistic perspective that characterize the strategy and we also support the EU ambition to become climate neutral by 2050. Both the Commission and the Member States (MS) need to commit to a long-term policy framework with realistic objectives, and simple and clear rules to provide this stable environment.

The EU needs to maintain its commitment to “Net Zero 2050” and take on the leading role for making Europe become the first climate neutral continent – which can only succeed if clear goals, limits and criteria are set at EU level and Member State level.

European Aluminium welcomes the review of the Energy Taxation Directive (ETD) and the findings of the European Commissions’ evaluation report released last summer. Here the Commission correctly acknowledged that energy intensive industries in Europe have to pay higher energy prices than industries in most G20 countries, with a consequential negative impact on their competitiveness.

NLA and its members from the Nordic haulier associations are keen to make a positive contribution to bringing down the CO2 emissions of the transport sector. As the demand for freight transport in Europe is expected to grow substantially in the coming decades, it is essential to ensure EU policies that further incentivise the road transport sector to become a part of the solution in addressing the challenges created…

As a primary independent power producer from renewables in Europe – wind, solar and hydro – ERG Group believes that is of paramount interest filling the gaps between the current text of the Energy Taxation Directive (ETD) and the decarbonization policy stated in the European Green Deal (EGD).

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and renewable LPG in Europe.

The European Union (EU) has been at the forefront of international efforts to combat climate change. It was the first major economy to submit its intended contribution to the Paris Agreement and set ambitious targets to reduce greenhouse emissions, improve its energy efficiency, and increase the share of renewables in its final energy demand by 2030.

The Spanish Association of the Electricity Industry (aelēc) would like to present the following remarks with the aim of participating in this public consultation. 1. INTRODUCCIÓN The electricity system is affected by a series of inefficiencies that make electric energy more artificially expensive, deteriorating its competitiveness.

FEAD, the European Federation for private waste and resource management, supports the revision of the Energy Taxation Directive (ETD), as one of the instruments of the European Green Deal. A well-designed ETD should work together with the Circular Economy Action Plan and boost the circular economy in Europe.

ASFE's input to Energy Taxation Directive’s Revision roadmap ASFE (the voice of Paraffinic Fuels in Europe) welcomes the Commission’s intention to review the Energy Taxation Directive, as a more harmonised European taxation framework will support the uptake of cleaner, sustainable fuels across Europe.

In Covid-19 context, UNIDEN claims for reindustrialization of Europe in order to secure proper supply of technologies and products to European citizens. In this crisis context, the Industrial Strategy of Europe should be completely redefined.

Steel Economic Association 01.04.2020 Opinion on the Inception Impact Assessment on the European Commission’s approach to the revision of the Energy Tax Directive In principle, the Wirtschaftsvereinigung Stahl may also make sense to evaluate the Energy Tax Directive after 17 years and to adapt it to new developments and requirements.

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• Taxation of energy products should comprehensively consider all the aspects of EU energy transition ambitions and address a significant role of natural gas as a transition fuel towards a carbon neutrality. • Fiscal measures as instrument of adjustment the EU taxation legislation with the EU environmental goals should be formed in compliance with three pillars of EU energy policy equally: competitiveness, security…

Reference is being made to the Feedback required from the Commission on the Revision of the Energy Tax Directive [https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12227-Revision-of-the-Energy-Tax-Directive]. In this regard please find Malta’s replies.

Air transport is a major contributor to the socioeconomic development of European nations. A coherent regulatory and fiscal framework at EU level should support the industry’s energy transition away from fossil fuels. The aviation industry will rely on fuel-based propulsion for the foreseeable future.

FNADE, the French association for depollution and environmental activities, welcomes the revision of the Energy taxation Directive (ETD). Indeed, the revision of this directive would better align it with the climate Green Deal’s objectives especially for promotion of renewable energies. It also would harmonize the way it is implemented in the different European countries.

EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 Member States. Our members represent over 130.000 professionals engaged in energy-efficiency solutions in buildings and industry. They also operate district heating & cooling networks.

Revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity (Energy Taxation Directive or ‘ETD’ or ‘Directive’) Cefic comments 1. Managing the different global speeds.

EDF welcomes the intention of the Commission to review the Energy Taxation Directive (ETD). The current Energy Taxation Directive does not contribute to the EU’s climate and energy policy goals: there is no link between minimum tax rates and their energy content and CO2 emissions. The ETD does not provide preferential tax treatment for low-carbon energy final consumption.

Introductory Remarks ECSA together with CLIA, Interferry and EuDA (the industry) wish to submit this joint paper reiterating the shipping industry’s position with regards to the directive. We believe that the Energy Taxation Directive (ETD) can be instrumental to support the industry's use of new low- or zero carbon fuels, thereby supporting the decarbonisation of shipping.

NGVA Europe represents an industry that is fully committed to the objectives of the Green Deal. In this perspective, NGVA Europe stresses that clean fuels - such as natural and renewable gas – are essential solutions to decarbonise transports and to reach the emissions reduction targets.

Carbon Market Watch welcomes the opportunity to provide feedback on the ETD revision. Several aspects of this directive are crucial to set the EU on a pathway compatible with the Paris Agreement’s objectives. Carbon Market Watch supports the revision of the Directive, in particular with regard to the aim of “aligning taxation of energy products and electricity with EU energy and climate policies with a view to…

The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit to the feedback period on the EU Green Deal - Revision of the ETD, and wants to draw your attention to the following key points: • DCs are key to the digital economy and enable the movement, storage and computation of the world’s digital data resources.

The review of the Energy Taxation Directive must provide for a permanent and EU wide tax exemption for all clean fuels and clean sources of energy Under the current Energy Taxation Directive (2003/96/EC), a tax exemption can be provided only for OPS. Even for OPS though, a tax exemption is time-limited and Member States have to go through a burdensome administrative process at EU level before obtaining it.

EUROCITIES, the network of major cities, welcomes the proposed revision of the Energy Taxation Directive (ETD). The revision is an opportunity to align the taxation of energy products and electricity with EU energy and climate ambitions and strengthen the internalisation of external costs. Taxation of energy products and electricity produced from renewable sources should be minimised.

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

Hazardous Waste Europe (HWE) welcomes the planned revision of the ETD and its related roadmap. In the light of the problems the initiative aims to tackle, Hazardous Waste Europe (HWE) would like to emphasize the need for clarifications in ETD in order not to undermine the role of the hazardous waste sector.

Dear Sir/Madam, please find enclosed the feedback from the Austrian Economic Chamber. Yours faithfully, Dr [name removed] and Fiscal Policy Wirtschaftskammer Österreich Wiedner Hauptstraße 63 I 1045 Vienna T [phone removed] I F [phone removed] E  [email removed] I W https ://news.wko.at/fp

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The ETD, which was published in 2003, is out of date and does not reflect at all the current ambition of EU energy & climate policies. EuroACE therefore welcomes the Commission proposal to update it in line with the Green Deal objectives. Moreover, the ETD does not reflect the decreased technology costs in a lot of sectors, such as energy efficient buildings – this should also be considered.

EOA fully supports the revision of the Energy Taxation Directive, as a key instrument of the transition to cleaner fuels and cleaner transport. Biofuels are today the more effective way to decarbonize transport. ETD should be elaborated as an incentive to all biofuels as all of them will be needed if we would have a chance to meet the ambitious targets for 2030.

The EU Green Deal must become a driver for Europe’s strategy and rebuild the European economy, in the aftermath of the COVID-19 crisis, with decarbonization as the main driver. Achieving climate neutrality will require bold actions to build an ultra-efficient economy and accelerating direct electrification. Within the green deal it is the right moment to reevaluate the carbon pricing instruments.

CEWEP (Confederation of European Waste-to-Energy Plants) welcomes the European Commission’s (EC) work to revise the Energy Taxation Directive (ETD). We fully agree with the reason for the review - alignment with the European Union’s (EU’s) policy objectives inter alia: decarbonisation, energy efficiency and protection of human health and environment.

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

The AGFW, the German association on District Heating and Cooling and CHP (Combined Heat and Power) endorses the European Commission’s roadmap on the revision of the so called Energy Tax Directive (ETD). The decarbonisation of the European economy is the main objective of the policy framework of the EU and the European Green deal and an integrated approach is needed.

Methane emissions from the EU's gas supply chain, CO2 emissions from combustion of fossil fuels in non-ETS sectors and maritime fuels Environmental Defense Fund (EDF) welcomes the opportunity to comment. The fact that the ETDs minimum tax rates have lost their effect and no longer have a converging effect on national tax rates is particularly relevant for the EU’s objective of net zero GHG emissions by 2050 since…

Overlapping, cumulative effects of the Energy Taxation Directive (ETD) and the Emission Trading System (ETS) must be avoided to ensure European industries' global competitiveness. The effective steering mechanism of the ETS already comprehensively accounts for CO2 externalities by inflicting costs on energy-intensive industries in proportion to their GHG emissions.

Confederation of Finnish Industries EK represents the entire private sector and has 24 member associations and 16,000 member companies. We speak for employers of all sizes, from public limited companies to SMEs. Our member companies create jobs and welfare in Finland, and are responsible for 70% of exports, 70% of R&D expenditure, 2/3 of the GDP created by companies and 2/3 of the private sector jobs.

Reply of the Czech Gas Association to the public consultation of the European Commission on the revision of directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity The Czech Gas association would like to hereby express its opinion on the revision of the Energy Taxation Directive as currently presented by the European Commission in the Inception Impact…

Neste (http://www.neste.com/en) supports the European Green Deal (EGD) and one of its aims to revise the Energy taxation directive (2003/96/EC) originating already from 2003. Thus, the revision is well-needed to be in line with the current EU policy objectives.

Thank you for the opportunity to share our views in writing as part of the stakeholder consultation on the revision of the Energy Taxation Directive. AENA is the largest airport operator in the world by passenger numbers.

Finnish Energy (FE) thanks for the possibility to give feedback to the Inception Impact Assessment. FE supports the EU to restructure the Community framework for the taxation of energy products and electricity. The existing directive is in many ways outdated as it is from the year 2003 and does not recognize the current climate and energy policy objectives and measures.

We agree with the Commission’s initiative. A reassessment of the current Directive seems appropriate, in order to ensure that it is consistent with the changed reference scenario, with the new objectives on energy, environment, climate change, the circular economy and transport, on the one hand, for the achievement of an energy mix to lower CO2 emissions, on the other hand, on developments in technology and the…

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FORATOM welcomes the initiative of the European Commission to review the Energy Taxation Directive for a better alignment with EU’s climate neutrality goals and bring consistency between taxation and other climate policy measures (such as the Emission Trading System as well as the Renewables Directive and Energy Efficiency Directive).

UFE welcomes the intention of the Commission to review the Energy Taxation Directive (ETD). The recent evaluation of the Energy Taxation Directive highlighted that, since the adoption of the Directive in 2003, energy markets and technologies in the EU have undergone significant developments.

The Polish Electricity Association (PKEE) agrees that the achievement of objectives set out in the European Green Deal may require a broader discussion about the possible amendments to the existing energy taxation rules.

The Inception Impact Assessment points out that the ambitious EU Climate ambition requires effective carbon pricing and the removal of fossil fuel subsidies. It also specifies that well-designed taxes play a direct role by sending the right price signals and providing the right incentives for sustainable practices of producers, users and consumers.

Scania strongly welcomes the planned revision of the Energy Taxation Directive 2003/96/EC and Commission’s roadmap for it. The Revision is an integral part of the European Green Deal and should focus on aligning the taxation rules with the EU’s GHG emission reduction ambition.

The taxation of energy products and fuels is a central tool for an efficient clean transport policy, as it provides a key price signal to consumers and ensures a swift redistribution of energy transition costs. Within this context, AVERE welcomes the public consultation on the energy taxation directive.

[extract] As identified in the Inception Impact Assessment for the revision of the Energy Taxation Directive (ETD), significant developments across numerous fields (e.g. energy, technology, climate change) since the adoption of the Directive in 2003 mean that the ETD is no longer in line with EU policy objectives and should therefore be revised.

The focus of the feedback to the Inception Impact Assessment (IIA) is the revision of the Energy Taxation Directive 2003/96, which outlines the EU rules for the taxation of electricity and energy products used as heating or motor fuels.

Cepi represents the European pulp and paper industry. Our response to the inception impact assessment focusses on two main aspects: (1) industrial competitiveness and double taxation; (2) considerations on the concept of tax exemptions, as addressed in the inception impact assessment.

CEWEP Ireland welcomes the Commission’s decision to review the Energy Taxation Directive (ETD) and to provide an opportunity to respond to the public consultation on the Roadmap for its revision. This review is timely and necessary given the aims of the EU’s Green Deal. With this in mind, there is scope for the ETD to underpin the proposed measures contained within the Circular Economy Action Plan.

Aurubis is Europe’s largest copper producer, the globally largest copper recycler and producer of many other metals. As a highly energy-intensive company, we would like to use the opportunity to outline in attached paper certain impacts and opportunities within this review that could help reconciling climate change mitigation objectives and competitiveness of the energy intensive industry.

Essenscia understands the aim of updating the Energy Taxation Directive (ETD) and emphasizes the importance to avoid double taxation, to prevent competition distortion amongst EU energy consumers as well as to guarantee an international level playing field. In this sense, essenscia welcomes the EC’s intention to avoid inconsistencies with other European legislation.

We applaud the aim to address fuel subsidies. All fossil fuel subsidies must be discontinued immediately. This should be done regardless of the outcome of the proposed revision of the ETD. We must point out that climate neutrality really needs to be achieved earlier than 2050 if the European Union wants to honor its commitment to the Paris agreement.

CAN Europe welcomes the initiative of bringing the Energy Taxation Directive (ETD) and the wider EU and national taxation policies in line with the EU's climate commitments. We are strongly in favour of eliminating all subsidies and tax breaks for fossil fuels like coal, oil and gas.

The Polish Oil Organisation (POGP), a body comprising the largest distributors of liquefied petroleum gas (LPG) and equipment manufacturers for this sector, wishes to submit its position on the EU Green Deal — Revision of the Energy Taxation Directive. At the same time, we stress the interest in the work on amending the Energy Directive 2003/96/EC.

Filed in Polish · English published by the European Commission

IRU POLICY ELEMENTS FOR AN UPDATED IRU POSITION ON THE EU ENERGY TAXATION DIRECTIVE • The European commercial road transport sector is committed to decarbonisation and energy transition. If the role of the ETD in the context of the European Green Deal is to contribute to reducing the CO2 emissions of transport, its guiding principle should be to enable the uptake of efficient and affordable low-carbon fuels and…

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process leading to the necessary revision of the EU ETD. At this stage, and without having more elements to understand what are the EC’s intentions in this revision, the EBB can already say that it fully supports a revision of the ETD that bring this directive in line with EU climate & energy policy objectives…

The French Association of Large Companies (AFEP) supports the process towards a revision of the Energy Taxation Directive which should lead to more consistency with the new EU climate ambition. However, due to COVID-19 pandemic, Europe is facing a global economic collapse.

CO2 pricing as leverage A comprehensive energy system transformation cannot be financed solely from the electricity sector. A viable and coherent concept must be developed in which tax, levy and contribution systems do not represent an additional burden in the conversion of energy forms.

Attached you can find the feedback that Confcommercio - Imprese per l'Italia, the Italian General Confederation of Enterprises, Professions and Self-Employment as well as the largest employer organization in Italy, has provided on the Commission's Inception Impact assessment regarding the Revision of Directive 2003/96 / EC restructuring the Community framework for the taxation of energy products and electricity…

The purpose behind imposing excise duties (on energy products, on tobacco and alcohol) is to impose a levy on harmful behaviour, to internalise external costs and to incentivise consumers to adopt a more societally beneficial pathway. With this intervention logic in mind, we fully support the European Commission’s problem definition outlined in the Inception Impact Assessment under public consultation.

While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.

IMA-Europe acknowledges the European Commission's publication of the inception impact assessment and is notably willing to contribute to the debate for the revision of the ETD. IMA-Europe welcomes the EC initiative for a revision of the ETD as a way to harmonise the level of energy taxes at EU level.

Repsol is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050.

Spanish Magnesite Association (MAGES) supports an update of the legal framework for energy taxation in light of the recently published European Green Deal and of EU to meet its 2050 objective. But this initiative should take into account that: • The ETD must not create additional or unnecessary tax burdens. Especially for European companies highly exposed to global competition.

GRDF welcomes the inception impact assessment on the revision of Directive 2003/96/EC restructuring the Community framework for the taxation of energy products and electricity. We welcome the Commission’s objective to align energy taxation with the EU 2030 targets and climate neutrality by 2050 in the context of the European Green Deal.

Dear Sir / Madam, We thank you for the opportunity to comment on the Inception impact assessment relating to the revision of the Energy Taxation Directive (ETD). We would like to share our views on the overarching principles which, according to us, should guide the revision of the ETD: - Protect and strengthen the competitiveness of the European Business, especially the European industry in the energy sector: this…

Public transport, whether powered by conventional or alternative fuels, means sustainable mobility. By using little space and moving millions of passengers every day, it is a very energy-efficient mode of transport and the backbone of urban mobility. In European cities, public transport by rail and road is estimated to save 100 million car trips daily.

ePURE, representing the European producers of renewable ethanol, welcomes the publication of the Inception Impact Assessment ahead of the revision of the Energy Taxation Directive (ETD). This follows a public consultation in Spring 2018, a Roadmap in Jan. 2019, and the Evaluation in Sept. 2019 where the European Commission found the ETD unfit for purpose.

The 2003 Directive on Energy Taxation is obsolete and needs to be reviewed so that a) it provides an effective framework for Member States to reach their decarbonisation targets and b) facilitate a smooth functioning of the internal market.

National energy taxes are an instrument that can complement energy efficiency support schemes and regulatory actions. It can make investments in energy efficiency improvements more attractive and steer energy use behaviour in the right direction, as long as energy users are enabled to act.

Basis for EU intervention (legal basis and subsidiarity check): VCI doubts that the proposed change of legal basis will be implemented easily. It seems probable that many lawsuits will follow resulting in a reduction of legal certainty for companies.

Concerning the revision of the Energy Taxation Directive, the Spanish Bus and Coach Federation - CONFEBUS would like to stress that such a revision should favour the use of the most energy efficient modes of transport, such as buses and coaches in order to be aligned with the objectives of the European Green Deal (55% GHG emission reductions for 2030, carbon neutrality for 2050).

Eurallumina Spa owns an alumina (aluminum oxide) production plant in the municipality of Portoscuso in the Province of Southern Sardinia (Sulcis), Italy. The plant was mothballed in March 2009 due to the economic crisis and high production costs, mainly related to the cost of fuel oil used for the production of steam.

The Association of German Transport Companies (VDV) supports the Commission’s initiative to revise the Energy Taxation Directive 2003/96 (ETD), which is very timely now that climate and environmental policies are a top priority, and considering that strong efforts to stop climate change are needed.

UPEI recognises the need for an Energy Taxation Directive and welcomes the European Commission’s intention to update it. This is needed to ensure that the ETD remains relevant by taking account of technological developments in the energy sector, resulting in the emergence of new products which currently do not fall within the scope of the directive, and address current issues related to the functioning of the…

Bioenergy Europe would welcome the prompt revision of the Energy Taxation Directive (ETD). At the time of its adoption, the ETD represented a positive contribution to the EU’s legislative framework. As it has remained unchanged since 2003, it no longer reflects the evolution and progress in technologies, energy markets and the EU legislative framework in response to the climate emergency.

Considering the huge and unkown consequences of the COVID-19 crisis Europe is facing, each directive referring to the the european Green Deal, such as this Energy Taxation Directive (ETD), should reconsider its economic and social fundamentals and be focused on the carbon neutrality objective.

EBAA would like to thank the Commission for the opportunity to contribute to the review process of the Energy taxation Directive; EBAA’s statement has drastically been adapted to take into account the Coronavirus crisis and its dramatic impact on aviation including Business Aviation. Almost all aircraft are and will remain grounded for several weeks.

In order to be able to achieve one of the key objectives of the European Green Economy, which is the transition of the EU economy to renewable energy sources, the future EU fiscal policy will largely be affected.

Filed in Polish · English published by the European Commission

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The Green Deal is clearly work in progress and will require careful societal consultation and impact assessment.

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), welcomes the revision of the Energy Taxation Directive proposed by the European Commission.

The Energy Taxation Directive (ETD) can support Europe’s decarbonisation efforts as price is an element that consumers consider when they make their purchase choices. As energy taxes represent a high share of final energy prices, the ETD can help to send clear price signals to nudge consumers to use less energy and switch to renewable energy.

The Portuguese Association of High Electrical Energy Industrial Consumers (PAHEEIC) supports the decarbonisation of the economy and sees the revision of the Energy Taxation Directive as one of the tools to achieve the goal of a carbon neutral economy by 2050. PAHEEIC comprises 22 industrial sites in several industrial sectors.

OFICEMEN supports an update of the legal framework for energy taxation in light of the recently published European Green Deal and of EU to meet its 2050 objective. OFICEMEN and CEMBUREAU, the European cement association, are currently in the process of re-assessing these targets with a view to setting out the cement and concrete’s industry’s pathway to achieve carbon neutrality along the value chain in Europe by…

EGEC welcomes the European Commission’s intention to revise the Energy Taxation Directive (ETD) to remove harmful fossil fuel subsidies and align energy taxation to the net-zero climate target by 2050. To be effective, the revision will include: 1. Removing direct and indirect fossil fuel subsidies for heat: We endorse the emphasis placed on “effective carbon pricing and the removal of fossil fuel subsidies”.

Contribution to Commission’s Inception Impact Assessment related to Energy Taxation Directive (31 March 2020) Key messages ● Keep current exemptions and apply full exemption for CHP across Member States ● Promote renewable and alternative energy fuels through tax exemptions ● Set a taxation ceiling for energy intensive consumers and avoiding also double taxation for ETS activities Background European Commission…

Iberdrola shares with the Commission the views that energy taxation should be a tool for climate policy and preserving the internal EU market requires harmonised energy tax framework across the MSs as one of the keystones of the Green Deal to achieve climate neutrality in the EU by 2050. Decarbonisation is a must for the whole society involving all economic sectors.

We welcome the European Commission’s initiative to review the Energy Taxation Directive and make it consistent with the climate agenda of the Green Deal. Taxation policy can become one of the most important and effective instruments to steer the European economy and consumer behavior patterns towards increasingly sustainable choices.

Technology Industries of Finland proposes that all heating fuels should be included in the ETS and no CO2-taxes should be collected in the heating sector. Energy taxes on heating fuels shall be set by Member States within the frames of Energy Taxation Directive. District heating and cooling are already within the ETS. The enclosed document enlightens our views more in detail.

Solar Heat Europe would welcome the prompt revision of the Energy Taxation Directive (ETD). In 2003, the ETD represented a positive contribution to the EU’s legislative framework, but it remained unchanged since then. Therefore, it no longer reflects the evolution and progress in technologies, energy markets and the EU legislative framework in response to the climate emergency.

UNITI, the German federal association representing small and medium sized mineral oil traders, welcomes the European Commission’s plan to revise the EU Energy Taxation Directive and strongly supports the goal of creating incentives for the use of renewable energy sources. In this context, UNITI recommends promoting the use of climate-neutral liquid synthetic fuels produced with renewable electricity (e fuels).

APPLiA Bulgaria’s Views on the Revision of the Energy Taxation Directive APPLiA Bulgaria represents the home appliance industry in Bulgaria. We welcome the proposal of the Commission to revise the Energy Taxation Directive (ETD). Taxes in place today in Member States on energy carriers were introduced decades ago and have not been updated since.

SPANISH COGENERATION ASSOCIATION (ACOGEN) contribution to Commission’s Inception Impact Assessment related to Energy taxation Directive. ACOGEN asks the Commission to take into account the following elements: • Keep preferential treatment and attention to High Efficiency Combined Heat and Power (HE CHP) generation: to enhance the energy efficiency and GHG emission reduction UE targets as well as the competitiveness…

General comments - In recognising the challenges posed by the climate change, INTERTANKO Members are engaged as individual companies as well as Members of INTERTANKO in initiatives to find solutions for reducing and eventually for phasing out the GHG emissions from shipping. Since this is a global climate challenge, it has to be addressed at a global level.

E.ON welcomes the European Commission’s initiative to review the Energy Taxation Directive and make it consistent with the climate agenda of the Green Deal. Taxation policy can become one of the most important and effective instruments to steer the European economy and consumer behavior patterns towards increasingly sustainable choices.

Gas Networks Ireland (GNI), and its parent company Ervia, welcomes this opportunity to provide feedback on the roadmap to revising the Energy Taxation Directive. Having reviewed the impact assessment, GNI makes the following observations. Overall, GNI agrees that the Directive needs updating to actively support delivery of the European Green Deal.

Uprigaz welcomes the European Commission’s initiative to revise the 2003 Energy Taxation Directive to make it a tool for the Green Deal. Uprigaz would like this revision to be based on three key principles: • A European harmonisation in order to establish a genuine internal energy market placing on an equal footing, as far as carbon taxation is concerned, all European consumers, and in particular all economic…

Filed in French · English published by the European Commission

Aughinish Alumina Limited operates a large alumina refinery based in West Limerick, Ireland. The alumina plant is one of the most energy efficient in the world and produces 30% of EU alumina requirements. In 2003, Aughinish invested over US $130M in a 160MW High Efficiency Combined Heat and Power (HE CHP) plant to meet the power and heat needs of the refinery, thus becoming an exporter of power and no longer only a…

ENERGY TAXATION DIRECTIVE Inception impact assessment The following elements should be taken into account by the Commission (extended version of our statement is provided in the attached document): Keep current exemptions: to keep the possibility of exempted or reduced level energy consumption taxation for those energy‐intensive businesses competing globally.

ENERGY TAXATION DIRECTIVE 2003/96/EC - INCEPTION IMPACT ASSESMENT Fortum welcomes the revision of the Energy Taxation Directive (ETD) 2003/96/EC and Commission’s roadmap for it. Revision of the Energy Taxation Directive is an integral part of the European Green Deal and should therefore focus on environmental issues according to the Inception Impact Assessment.

An updated legislation on Energy Taxation should be geared towards climate change mitigation and emissions reduction for a better complementarity with the EU policy objectives. The technological evolution and the current plurality of energy products should be accounted for and better reflected in the new ETD, with a link between minimum tax rates / exemptions on one hand and energy content and polluting, harmful and…

The European Industrial Gases Association, EIGA, is pleased to share its views on the Inception Impact Assessment on the Energy Taxation Directive (ETD)*. Taxation is universally acknowledged as a key tool to move to a more sustainable and carbon neutral economy, and this Directive is an essential part of that.

Gas Distributors for Sustainability (GD4S) comprises the leading natural gas distributors in France, Italy, Ireland, Spain, Portugal and Romania. Together, we represent 27.4m customers in Europe. GD4S welcomes this opportunity to provide feedback on the roadmap to revising the Energy Taxation Directive. Overall, we support the Directive being updated to actively support delivery of the European Green Deal.

With a view to a system for the taxation of energy products in line with the environmental policy objectives which the European Union intends to achieve, it is necessary: • define the minimum rates of taxation on the basis of energy content and emissions of climate-changing substances; • introduce the uniqueness of excise duty as a tax, in addition to VAT, of energy products and electricity, in order to avoid double…

Filed in Italian · English published by the European Commission

Ervia is a commercial semi-state company with responsibility for the delivery of gas and water infrastructure and services in Ireland, through Gas Networks Ireland and Irish Water. Gas Networks Ireland develops, operates and maintains the natural gas transmission and distribution networks in Ireland and provides gas transportation services to all gas suppliers and shippers in Ireland.

The European Heating Oil Association (Eurofuel) represents organisations that promote the use of heating oil and liquid fuels for domestic heating in Europe. Our membership covers 10 European countries, including over 10,000 companies. Eurofuel is engaged in the promotion of existing and innovative techniques for liquid fuels for heating and equipment, in the domestic market.

a. Demand response One important area that the revision should take into consideration is how demand response instruments could contribute to reducing emissions of net greenhouse gases. Demand response solutions would be able to reduce the pressure on the network by better managing peak demands. To cope with temporary high energy requests, energy suppliers often make use of coal or fossil fuels.

Total welcomes the initiative of the European Commission to review the Energy Taxation Directive and bring it in line with EU climate policy. Tax rates, reductions and exemptions should be redesigned for all energy carriers and users, in order to better reflect their impact on climate and environment, based on validated life cycle assessments, and to provide a level playing field across the involved sectors.

As CER has stated before, the ETD's existing mandatory energy tax exemptions for aviation and maritime shipping (Art. 14(1) (b) and (c)) have a negative impact on the environment and on the level playing field with rail. They should be removed. The optional tax exemption in Art.

Sekab strongly supports the revision of the Energy Taxation Directive (ETD) to align it with the EU’s climate ambitions and environmental policy objectives. The current taxation model engrained in the ETD based on fuel volume has led to a situation where renewable alcohol-based fuels are more heavily taxed than fossil fuels, contrary to the EU’s climate and energy goals.

Minimum tax rates in the Energy Taxation Directive 2003/96 should be raised in order to harmonize energy taxation within the Union and to minimize tax exemptions in the energy sector. The minimum taxation level used for different tax exemptions should initially not be allowed to be lower than at least half of a normative level of full energy tax for fuel, I e the tax on unleaded petrol and on electricity for…