UNIDEN

UNIDEN welcomes the possibility of giving its feedback on the draft Commission implementing regulation on the EU ETS benchmark values for the period 2026-2030. The draft values of the product-specific benchmarks seem, in most but not all of the cases, consistent with the expectations of the sectors covered by EU ETS.

1. The contribution of renewable and low-carbon energy sources with a latted EU 2040 climate target for 2040 must first and foremost be based on an effective and measurable reduction in greenhouse gas emissions. The European framework should therefore be based on all decarbonised, renewable and low-carbon energy sources, which make a tangible contribution to reducing emissions.

Filed in French · English published by the European Commission

The robustness of CBAM depends on the strict equivalence between the carbon costs borne by EU producers and those applied to imports. The implementing rules on the recognition of carbon price paid in third countries must therefore ensure consistency, transparency and comparability across jurisdictions in order to preserve both environmental integrity and fair competition.

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

For the determination of the embedded emissions, the scope should remain only on direct emissions, including those linked to the 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. Due to the marginal pricing system of power in Europe, power prices are affected by the price of CO2 allowances.

1. Energy efficiency must help decarbonise Europe’s latent climate target economy by 2040, and above all it must be based on an effective and measurable reduction in greenhouse gas emissions, in line with the pathway towards carbon neutrality.

Filed in French · English published by the European Commission

Specifically on the methodology, the CBAM product benchmarks shall be defined by using a similar methodology to the one used for determining the EU ETS product benchmarks. The benchmark scope shall take into account process emissions, direct emissions linked to energy consumption and, where relevant, indirect emissions linked to purchased heat.

Monitoring and Reporting Complexity The new rules defined in article 5 and annex I add considerable complexity in terms of monitoring and reporting. For installations with heat BM and/or fuel BM sub-installation with several products (under the same PRODCOM code or not), but with differing energy intensities per product the changes proposed could lead to significant administrative burden and substantial additional…