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Answer from Svebio - Swedish Bioenergy Association We strongly support extension of carbon pricing to the sectors outside ETS. But we are not convinced that inclusion in ETS of the heating and transport sectors are the right way to do this. We would instead prefer introducing carbon taxes on sectors outside ETS. It is a simpler and more straightforward incentive than carbon emission trading.

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.

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.

The European Commission misses the opportunity to introduce a common minimum tax rate for carbon dioxide emissions. This is remarkable given that the proposed directive is part of the Green deal. Our proposal is a minimum carbon dioxide tax of 25 €/ton CO2 for all sectors outside ETS. This would be a better incentive than the proposed ETS-system for buildings and transport.

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.

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

The EU regulation has to change from zero tail-pipe to well-to-wheels and conventional biofuels from crops are much needed also for cars. The EU climate target for the transport sector is far too low, only 13 percent in emission reduction by 2030 compared to the Swedish target of 70 percent reduction.

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.