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GENERAL COMMENTS: • Extension of EU ETS should not be considered as most effective solution across all sectors. Individual approach in specific sectors should be applied in order to maximize environmental benefits. • As regards waste sector, one of the main identified sources of methane are uncontrolled emissions of landfill gas in landfill sites.

The ETS should remain a core policy instrument to establish CO2 abatement at the lowest practicable cost to society. We do not favor inclusion of other sectors such as transport and buildings as an extension of the ETS current scheme, which already has to cope with different sectors with distinct elasticities, and risks on carbon leakage in one system.

GENERAL COMMENTS: • The effects of raising the contribution of the ETS towards a higher emissions reduction target will not be felt equally across the EU. Some MS will be more affected than others. • Required investment in Polish energy sector in the years 2021-2040 (according to the Polish government), are estimated at over PLN 560 bln (about EUR 125 bln). • PGNiG is concerned whether additional resources (2,5 p.p.

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries (EIIs) are indispensable for Europe’s transition. The chemical industry provides all other sectors including efficiency solutions to multiple value chains such as the construction sector.

GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units.

General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions.

•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.

Comment provided by EFCTC: European Fluorocarbons Technical Committee. EFCTC considers the Environmental Crime Directive could further enhance these efforts through its horizontal approach across EU measures, including the F-Gas Regulation, to help develop a more coherent and effective framework that better achieves the EU’s climate action objectives.

Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) welcomes the opportunity to comment on the proposal for a directive on the protection of the environment through criminal law (COM (2021) 851 final). PGNiG recommends extending the scope of Article 9 so that it includes additional circumstances that may be regarded as mitigating circumstances.