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

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

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

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

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”.

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.

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

The revision of the tailpipe CO2 standards for cars misses the opportunity to stimulate the deployment of different innovative low-carbon technologies complementing each other to enable the effective and efficient decarbonisation of the transport sector.

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

We welcome the introduction of the REFuel Aviation regulation, which will create a market for SAF by setting an obligation to airlines, airport operators as well as to fuel suppliers. Together with the REDII revision, this will provide an adequate incentive to fuels based on their well-to-wing (WTWg) carbon footprint.