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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.

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

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.

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.

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.

We, FinCo Fuel Group, appreciate the EU’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of this sector, it is the right approach to address its GHG impact on EU level and thereby set an example for the international shipping sector to follow. An important aspect of reducing GHG emissions is the availability of alternative fuels.

The revision of the AFIR offers the opportunity to set an important course for a change of engines towards a sustainable transport sector. We support the rapid development of the infrastructure in order to enable a faster conversion to electric motor operation.

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.

FinCo Fuel Group position on ReFuelEU Aviation We appreciate the EU’s efforts in leading the energy transition and, besides road transport, now also tackling GHG emissions in both the maritime and aviation sector. Given the cross-border nature of those sectors, it is the right approach to address its GHG impact on EU level and thereby set an example for the international maritime and aviation industry.

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

We appreciate the European Union’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of shipping, it is the right approach to address its GHG impact on a Union level and thereby set an example for the international shipping community to follow.