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T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.

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.

This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.

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.

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 EU urgently needs a new and robust legislative framework on zero emission infrastructure to support the 33-44 million electric cars (battery and plug-in hybrid) expected on the road in 2030 to align with transport decarbonisation goals. Consumers should have access to the EU single market for chargers.

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.

Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a regulation on the deployment of alternative fuels infrastructure. In particular the change of the legislative instrument from directive to a regulation T&E considers an important step in the right direction. (detailed feedback in attachment).

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.

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.

We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.

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.