IFIEC-Europe

IFIEC-Europe answer to the EU consultation Industrial Accelerator Act – speeding up decarbonisation IFIEC Europe represents the interests of industrial energy users in Europe for whom energy and climate policies are significant components of production costs and a key factor of competitiveness in their activities in both Europe and throughout the world. 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

July 04, 2025 Position Paper: Creating Lead Markets for Low-Carbon Products in Europe IFIEC Europe - July 2025 IFIEC welcomes the European Commission’s initiative to establish lead markets for low-carbon products as part of the Clean Industrial Deal (CID).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Members of the European Commission, please find attached a position paper of IFIEC Europe International Federation of Industrial Energy Consumers to the EU public consultation Revision of the benchmark values for free allocation of emission allowances (2026-2030).

IFIEC Europe, representing Europes energyintensive industrial energy consumers, appreciates the opportunity to respond to the Commissions call for evidence on the future renewable energy legal framework after 2030.

IFIEC answer to the EU consultation CBAM implementing regulation carbon price paid in third countries Ensure environmental integrity and a level playing field The robustness of the CBAM depends on the strict equivalence between the carbon costs borne by EU producers and those applied to imports.

To ensure a level playing field for European producers, it is essential that a very cautious and conservative approach is adopted in recognizing the carbon price effectively paid in third countries . When crediting emissions trading in third countries, the local CO2 price is not a sufficient indicator to assess the real CO2 cost borne by the third country producers.

For the determination of embedded emissions, the scope should remain only on direct emissions, including those linked to heat generation. We recommend not extending CBAM scope to indirect emissions for industries that are already covered by the EU ETS Indirect Carbon Cost Compensation Scheme and to avoid competition distortion within the European Union adapt the indirect carbon cost compensation scheme to ensure…

IFIEC Europe represents energy-intensive industries (EII) across sectors such as chemicals, refining, food and nutrition, paper, glass, ceramics, steel and metals and fertilizers. Efficient, reliable and well-integrated energy infrastructures are essential for a competitive industry in Europe and a successful European energy- and industry transition.

CBAM does not provide the same carbon leakage protection granted by the current level of ETS free allowances and a broad eligibility for indirect carbon costs compensation. The current CBAM framework does not sufficiently prevent industries to relocate outside Europe, and therefore it is not enough to ensure EUs industry competitiveness and progress towards climate transition.

IFIEC Europe answer to the European Commissions Have Your Say on the Network Code Requirements for Generators 2.0 Please see the attached document for the position of IFIEC Europe. IFIEC Europe represents the interests of industrial energy users in Europe for whom energy and climate policies are significant components of production costs and a key factor of competitiveness in their activities in both Europe and…