Wacker Chemie AG

Overall: - The access to ample and cheap renewable electricity is a precondition for decarbonization, in particular for industry which will have to achieve large-scale CO2-reductions via process electrification. The accelerated deployment of renewable energy, in particular wind and solar, is welcoming and should be supported with ambitious targets of at least 40% by 2030.

Overall: - CBAMs do not offer any carbon leakage protection for European exports, as the instrument only focuses on imports within the EU single market and is therefore not fit to replace current mechanisms under the ETS. In particular export-intensive sectors such as polysilicon will suffer from a major loss of competitiveness in global markets, if free allocation and indirect cost compensation would be phased-out.

Summary of recommendations by Wacker AG: 1) The Commission should follow up on its recent commitment to strengthen existing carbon leakage instruments (free allocation and indirect cost compensation). As a minimum, current level of support must be guaranteed for the upcoming EU ETS phase 2021-2030.

Our key points have been uploaded separately. About WACKER Biotech and WACKER BioIngredients Wacker Biotech focuses on contract development and manufacturing services (CDMO) for the pharmaceutical and biotech industries. It specializes in microbial production systems for the development and production of biologics, including nucleic acids, therapeutic proteins, vaccines, and live microbial products.

Overall - Industry has achieved significant reductions in energy consumption due to efficiency improvements. Switching to low-carbon technologies such as process electrification or hydrogen will however significantly increase the industrial final energy demand.

Overall: - The ETS-proposal suggests a significant acceleration in the reduction of CO2-emissions by 2030 for industry, underpinned by a higher overall target of -61% and increased LRF of 4,2%. However, this is not followed through by an equivalent increase in protection against carbon leakage.

WACKER supports the draft proposal presented by the EU Commission and believes it strikes the right balance between increasing the ambition of the quota system on the one side, and allowing for justified exemptions where no technological options are available on the other.

WACKER is the world market leader and the only European manufacturer of high-purity polysilicon – the basic material for photovoltaic cells and semiconductor chips – and thereby holds a strategic position in the industrial value chains for enabling the green energy and digital transition in Europe.

Wacker Chemie from Germany, with its two polysilicon production sites in Germany, is Europes only manufacturer of polysilicon, and an essential player in Europes and the global semiconductor and solar supply chains.

As an industry, we welcome initiatives to minimize the unintentional loss of plastic pellets. Any approach to reduce pellet loss should be effective, but also needs to be economically feasible. Comparison of EU and UN data The proposed regulation estimates that between 52 kt and 184 kt of pellets were lost to the environment in the EU in 2019.

WACKER is a world leading and Europe’s only producer of polysilicon which is the key raw material and first step in the value chain of semiconductors (and PV). WACKER’s electronic-grade polysilicon is a hyperpure material (99,999999999%) used for the manufacturing of wafers and chips and thereby an enabler of all silicon-based semiconductor application.