Lufthansa Group

The revision of the EU Emission Trading System Directive 2003/87/EC must solve important policy design issues between EU ETS and CORSIA, including the changed world post-COVID-19. An intelligent coexistence of both systems is of utmost importance. Europe should not undermine the credibility of CORSIA. Moreover, airlines should not pay twice for the same single ton of CO2.

REVISION OF THE UNION CUSTOMS CODE November 2023 Lufthansa Group and all its affiliates, which are internationally operating companies, are affected by nearly all legal changes of international trade regulations. As part of the aviation industry, which heavily depends on internationally interconnected supply chains, we rely on a fast cross border movement of goods.

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

Please find attached Lufthansa Group's contribution to the EU Aviation Strategy Call for Evidence. In short, it is our view that a renewed Aviation Strategy must prioritize competitiveness and fair competition, guided by five principles: 1. Safeguard the EUs strategic autonomy: strong EU network airlines and hubs are essential to maintaining independent European connectivity and to reduce reliance on nonEU carriers.

The existing digital rulebook provides a common regulatory framework, yet its practical impact is limited by overly complex, interpretation-heavy legislation that at times generates more uncertainty than clarity. Key regulationsmost notably the EU AI Actare drafted in broad and abstract terms, leaving businesses without the operational guidance needed for consistent and efficient implementation.

We are convinced that the revised EU Emission Trading System (EU ETS) Directive 2003/87/EC will be a cornerstone of the environmental policy for the aviation industry that will shape the environmental legislation for European aviation for years to come. One of the key challenges for the EU will be to create a regulatory foundation that allows for the coexistence of EU ETS and ICAO’s CO2 offsetting program CORSIA.

Lufthansa Group welcomes the publication of the European Commission´s Passenger Mobility Package and the opportunity to comment on the proposals. The Package aims to facilitate passengers ability to search for, compare, and book multimodal travel options through digital platforms while also addressing long-standing barriers in rail passenger transport.

Please find attached the position of the Lufthansa Group regarding the European Slot Relief Rules. The Lufthansa Group welcomes the opportunity to provide input for an update of Council Regulation No. 95/93 (EU Slot Regulation). An updated EU Slot Regulation (e.g.

The draft raises issues of critical concern for the European aviation industry. Commercial airlines have been strictly regulated under the well-established EU ETS1 system (Annex I of the Directive) since 2012. The introduction of ETS2 for the transport sector must not - under any circumstances - result in uncoordinated carbon cost pass-through by fuel suppliers, market fragmentation, or severe administrative…

Lufthansa Group welcomes the recent publication of the Inception Impact Assessment (Ref. Ares 3635812 - 09/07/2020) on a potential review of the CRS Code of Conduct (Regulation EC 80/2009) and we appreciate the possibility offered to share comments on this Inception Impact Assessment.