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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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

To achieve the EU's climate targets, heavy-duty vehicles (HDVs) need to be decarbonised and the sale of most conventional trucks and buses ended by 2035. The review of the HDV CO2 standards is the once in a decade opportunity to put HDVs on a Green Deal compliant trajectory.

The European Commission's proposal to review the CO2 emission standards for new heavy-duty vehicles (HDVs) is the most important legislative initiative to regulate climate emissions from trucks and buses in Europe.