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

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

CIROM welcomes the opportunity to comment on the ECs public consultation for the revision of the Annexes V and VI of the Renewable Energy Directive (RED). In view of simplicity and consistency of the legislation RED with Directive EU- ETS 2003/87/EC and Waste Framework Directive, CIROM proposes the insertion of the following recital and new points to the Annex V (bioliquids), part C (Methodology) and Annex VI…

APAG supports the Commissions review of Annexes V and VI and the reliance on the JRCs scientific expertise. At the same time, APAG calls for a clear and explicit limitation of the proposed animal fats pathway values to Category 1 and Category 2 animal fats only; and careful consideration of policy coherence and market impacts when revising GHG accounting rules.