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)

IFIEC believes the revision of RED II could help industry decarbonise provided access to abundant, competitive secure and low carbon energy and hydrogen (H2) is assured. Alongside, the revision should further contribute to create the necessary legal certainty for investment in low-carbon and breakthrough technological solutions according to the principle of technology neutrality.

[please see attached document for full response] RED needs to supply clean, affordable and secure renewable energy IFIEC contribution Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of renewable energy.

IFIEC Europe represents 13 national European associations that comprise - on a cross-sectoral level - those industrial sectors for which energy is a significant component of production costs. IFIEC welcomes the possibility to contribute its view on the Commission proposal for a regulation establishing the framework for achieving climate neutrality (European climate law).

1. IFIEC Europe welcomes the EU Commission’s intent to safeguard the competitiveness of EU industries The European Union wants to become the first carbon neutral continent in 2050 which involves massive investment in all sectors of the EU economy.

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.

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)

The CBAM proposal raises a number of concerns. • Need for integration with the EU ETS revision: the carbon border adjustment mechanism that is intended to protect industry sectors from carbon leakage regarding imports will start after 2025, but the measures envisioned under the EU ETS revision will come into effect by 2023, or even earlier if implemented retroactively.

[see attached file for full response] IFIEC Europe’s response to the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM) Improving carbon leakage protection of the European Union Executive summary In December 2019, the European Commission adopted the European Green Deal.

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 energy intensive industries (EIIs), welcomes the opportunity to provide feedback on the proposal related to the revision of the Energy Efficiency Directive (EED). IFIEC is concerned by the potential impact of the revision of the EED on industry competitiveness. 1.

[Please see attached document for full response] EED needs to avoid capping energy usage and should focus on energy efficiency IFIEC contribution Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of energy.

Please see the attached file for IFIEC's full response, from which the following selected comments are extracted: IFIEC welcomes the opportunity to participate in the consultation on the roadmap to update the EU Emissions Trading Scheme and supports the EU Commission's discussion on an improved emissions trading scheme.

IFIEC Europe, representing energy intensive industries (EIIs), welcomes the revision of the ETD that should give industry better visibility on tax framework and enable it to make long-term investment decisions. However, IFIEC is concerned by the impact on industries’ competitiveness which will be created by the general increase of the minimum taxation level and the cancellation of most of the possibilities for…

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 Europe, calls for a realistic and innovation-aligned 2040 climate target that supports industrial transformation without compromising Europes competitiveness. The target must be conditional on enabling factors and designed to avoid irreversible deindustrialisation. See our position in attachment.

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 appreciates the Commissions efforts in supporting the technologies which will be necessary for the decarbonisation. In our view, the proposal focuses primarily on "net-zero technologies manufacturing". It fails to recognize that energy-intensive sectors provide essential primary products and raw materials for the manufacturing of the addressed strategic climate-neutral technologies.

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for a Hydrogen and Gas Decarbonisation Package. We agree that renewable and low-carbon gases, including hydrogen, have an important role to play as we move towards a carbon neutral society.

IFIEC position COMBINED EVALUATION ROADMAP/INCEPTION IMPACT ASSESSMENT HYDROGEN AND GAS MARKETS DECARBONISATION PACKAGE IFIEC supports the aim of the Green Deal Strategy to transform the energy markets in a non-disruptive and cost-effective manner.

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…

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for a Hydrogen and Gas Decarbonisation Package. We agree that renewable and low-carbon gases, including hydrogen, have an important role to play as we move towards a carbon neutral society.

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for securing the EU’s winter gas supply. Gas storages are essential in the gas supply chain for several reasons, namely security of supply, seasonal flexibility, price level (liquidity) and price stability (volatility).