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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.

France Hydrogène considers that the reform of the EU ETS carbon market is going in the right direction to strengthen the carbon price signal and encourage the transition to low-carbon technologies provided that adequate carbon leakage protection is guaranteed to trade intensive sectors.

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.

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.

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.

France Hydrogène welcomes the revision of the Gas Directive and Regulation in order to prepare the design of a competitive hydrogen market by 2030, as promoted in the EU Strategy on Hydrogen. Renewable and low-carbon hydrogen are efficient solutions to decarbonize hard-to-abate sectors such as chemicals, heavy industries, heavy-duty road transport, railway, aviation and shipping.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. This legislation is essential in leveling the playing field between natural gas, hydrogen, other gases and renewable electricity. Natural gas currently enjoys significant regulatory advantages. While green hydrogen, renewable electricity etc.

Deutsche Umwelthilfe / Environmental Action Germany (DUH) welcomes the opportunity to consult on the gas market directive and regulation. In general, we are not pleased with the roles that low-carbon gases and green hydrogen are given with this reform. The broad allocation of hydrogen across many sectors is critical.

France Hydrogène welcomes the new ambitions from the EU with the Alternative Fuels Infrastructure Regulation. The new Regulation will support the uptake of hydrogen refuelling stations (HRS), whose deployment will now become mandatory for Member States, instead of being optional as it was with the AFID.

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.

The ReFuel Aviation Regulation will directly constrain airline companies to gradually switch to sustainable aviation fuels (SAF) to reduce their GHG emissions. Hydrogen technologies can play a future role for the decarbonation of the aviation sector, with two main applications.

France Hydrogène welcomes the initiative Refuel Aviation whose goal is to support the uptake of renewable fuels in the air transport. Either with fuel cells or H2 turbines, hydrogen-powered aircraft are not directly targeted by the Regulation as they are considered insufficiently mature technological options within the next 10 years.

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.

France Hydrogène welcomes the initiative to support the uptake of renewable and low-carbon fuels in maritime transport. France Hydrogène particularly supports the agnostic and technologically neutral approach of the Regulation, offering a wide range of renewable and low-carbon fuel solutions to decarbonise the sector, such as hydrogen (gas or liquid), synthetic fuels (e-fuels), ammonia, or methanol.

France Hydrogène considers that the revision of the regulation (EU)2019/1242 represents a major potential lever for decarbonization of new heavy-duty vehicles. Some points of the revision must be given particular attention.

Deutsche Umwelthilfe welcomes the opportunity to comment on the revision of the emission standards for heavy duty vehicles. Summary of our key recommendations: 1. 100 % CO2 reduction target for new registrations of trucks and buses from 2030 2. Stringent intermediate targets before 2030 3. Zero emissions target for new city buses in 2027 4. Application of the standards to 100 % of fleet 5.

Filed in German · English published by the European Commission