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Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

Climate action

In the framework of the 'Fit for 55' package, the EU ETS Directive has been revised with the EU target set out in the European Climate Law to reduce net greenhouse gas (GHG) emissions by 55% by 2030, compared to 1990 levels. Following this revision, the European Commission needs to update several regulatory acts for the implementation of the EU ETS. This initiative updates the rules for the Monitoring and Reporting of emissions.

Links

Public consultation

ID: 14217

Lobbying Activity

90 responses

T&E urges full reporting of aviation non-CO2 climate impacts

Transport and Environment (European Federation for Transport and Environment), 18 Jul 2024

T&E requests the monitoring framework cover all flights departing from and arriving in Europe. They argue the current proposal illegally excludes long-haul flights that cause significant warming.
Full data collection will enable the development of more effective future climate policies.
Long-haul airlines would face immediate reporting requirements for their most polluting routes.

Airbus urges phased reporting for aviation non-CO2 climate effects

Airbus, 29 Jul 2024

Airbus proposes a phased approach where reporting initially concentrates on emissions data rather than carbon equivalents. They also advocate for formal industry involvement in developing the technical methodologies for emissions computation.
This strategy prevents the company from being measured against inaccurate or immature climate models.
Climate advocacy groups lose immediate, comparable data on the full warming impact of flights.

Chemical Industry Seeks Broader Carbon Utilisation Recognition in EU ETS

European Chemical Industry Council, 29 Jul 2024

The organization requests recognition of all forms of carbon capture and utilisation (CCU), not just permanent CCU. They want to maintain existing exemptions for CO₂ bound in products like precipitated calcium carbonate and soda ash. They also seek clarity on biomass certification requirements to avoid disincentivizing energy recovery.
This would avoid double counting of captured emissions and prevent additional compliance complexity.
Environmental integrity may suffer if emissions are not fully accounted for.

Finnish Forest Industries Federation opposes new carbon reporting rules

Finnish Forest Industries Federation (Metsäteollisuus ry), 29 Jul 2024

The federation opposes rules differentiating between end applications of precipitated calcium carbonate. They request to subtract carbon chemically bound in products from installation emissions.
This would allow paper producers to avoid higher carbon compliance costs.
Waste incinerators lose by being responsible for reporting eventual carbon releases.

EDF calls for biomass zero-rating in outermost regions

ELECTRICITE DE FRANCE, 29 Jul 2024

EDF requests regulatory coherence to ensure biomass used in installations in outermost regions is zero-rated under the EU ETS. They also seek explicit clarification that biomass combusted below specific capacity thresholds is considered zero-rated.
This allows EDF to decarbonize isolated systems using bioliquids without incurring unnecessary fossil fuel costs.
Local biomass industries and energy sovereignty are harmed by misaligned sustainability criteria.

Fuel industry urges alignment of low-carbon fuel definitions across EU regulations

FuelsEurope, 26 Jul 2024

FuelsEurope requests revising the definition of synthetic low-carbon fuels to align with terminology in other EU regulations. They want the MRR definition replaced with the low-carbon fuels definition from the Gas Directive. They also seek greater flexibility in reporting timelines and evidence requirements for sustainable aviation fuels.
This would simplify compliance by creating consistent definitions across multiple EU regulations.

Eni urges more flexibility for reporting sustainable aviation fuel

Eni S.p.A., 29 Jul 2024

Eni proposes removing the "physical constraint" that limits aircraft operators to claiming sustainable fuels only at specific departure airports. They also suggest using a central database to generate digital proof, avoiding redundant paperwork across different regulations.
These revisions would lower administrative costs and simplify compliance across multiple maritime and aviation fuel mandates.
Regional airports with less infrastructure could lose out as fuel blending concentrates at major aviation hubs.

Austrian Industry Urges EU to Slash Emissions Reporting Bureaucracy

Wirtschaftskammer Österreich, 26 Jul 2024

The group wants to simplify reporting for installations that do not use biomass. They propose raising the emissions threshold for small consumers to 1,000 tons. They also demand better legal recognition for carbon capture and storage technologies.
This would lower administrative compliance costs and provide clarity for long-term industrial investment projects.
Environmental regulators lose granular data on emissions if thousands of small consumers are exempt.

ENGIE urges stable rules for renewable fuel carbon accounting

ENGIE, 19 Jul 2024

ENGIE requests simpler compliance through self-declarations and mandatory recognition of database evidence. They demand grandfathering of current CO2 accounting rules to ensure long-term regulatory stability.
These changes would lower administrative costs and protect the profitability of existing projects.
Climate groups lose if grandfathering prevents timely updates to inaccurate carbon accounting rules.

Paper Industry Opposes Stricter Carbon Accounting for Captured CO2

Confederation of European Paper Industries, 29 Jul 2024

The organization opposes new rules that would stop deducting chemically bound CO2 in calcium carbonate from emissions calculations. They argue this creates double-counting risks when paper is later incinerated, and penalizes investments in carbon capture.
This would preserve their ability to deduct captured carbon from emissions calculations, protecting previous investments in CO2 capture infrastructure.
Climate accounting accuracy suffers as actual carbon release during incineration may not be properly tracked.

Airlines for Europe demands realistic non-CO2 emission monitoring standards

Airlines for Europe, 27 Jul 2024

A4E requests a monitoring framework based on robust scientific data and realistic default values. They suggest using existing EU databases to automate reporting and reduce the administrative burden. The group calls for a stakeholder consultation process to ensure the tracking software is practical.
Using existing data sources would simplify compliance and reduce operational costs for aircraft operators.
Public transparency is reduced as the industry seeks to keep flight-level fuel data confidential.

Ryanair demands non-CO2 emissions monitoring include all EU flights

Ryanair Holdings, 29 Jul 2024

Ryanair requests the regulation be amended so monitoring applies to all flights involving EU airports, not just intra-EEA routes. They want default values used to compute non-CO2 effects when operators don't submit data, and clearer fuel reporting requirements.
This would prevent their intra-EEA operations appearing disproportionately harmful compared to competitors' extra-EEA flights.
Non-EU carriers lose exemption from monitoring requirements for flights departing EU airports.

Lufthansa Group demands refinement of EU aviation emissions tracking

Lufthansa Group, 29 Jul 2024

The group requests alternatives to default fuel values, greater transparency in the Non-CO2 Aviation Effects Tracking System, and resolution of parallel SAF claiming issues. They argue default values overestimate climate impact and create systematic distortions.
This would reduce compliance burden and allow more flexible SAF allocation across routes.
Environmental accuracy suffers if conservative defaults are replaced without rigorous validation.

Eurogas urges simpler monitoring rules for gas sector decarbonisation

EUROGAS, 29 Jul 2024

The organization requests simpler proof for zero-rating fuels and alignment with the Union Database. They also want recognition of cross-border certificates and inclusion of solid carbon products.
Proposed clarifications would reduce administrative burdens and provide much-needed long-term legal certainty.
National authorities lose discretion to refuse fuel sustainability evidence from other EU Member States.

CEMBUREAU urges more flexible rules for carbon accounting

CEMBUREAU - The European Cement Association, 26 Jul 2024

The association requests flexibility in accounting for carbon capture and negative emissions. They propose adjusting rules to avoid mandatory production of negative greenhouse gases.
Greater flexibility would help companies avoid extreme investment and operating costs.

Consultation response

Germanwatch, 18 Jul 2024

Dear ladies and gentlemen, thank you for the opportunity to comment on this technical, but important implementing regulation. Please find our comments attached. As we are engaged in the issue, including technical aspects, within processes and networks at national level, in Germany, we would very…

Safran urges phased monitoring of non-CO2 aviation climate impacts

SAFRAN, 29 Jul 2024

Safran requests a phased approach excluding CO2-equivalent calculations during the initial period. They argue current scientific models are too uncertain for precise climate reporting. They also call for industry involvement in developing performance and emissions methodologies.
This prevents immediate regulatory costs and potential financial penalties from inaccurate climate models.
Environmental advocates lose rapid implementation of comprehensive measures to address aviation's total climate impact.

European Ceramic Industry Seeks Credit for CO2 Absorption in Products

European Ceramic Industry Association, 16 Jul 2024

The industry requests broader recognition of CO2 reduction through re-carbonation of ceramic products. They want credit for CO2 absorption from ambient air by ceramic bricks and tiles, not just carbonated products.
This would allow their 1200 EU installations to claim emission reductions for natural CO2 absorption.

Biogas industry urges clearer rules for zero-rating and subsidies

European Biogas Association, 26 Jul 2024

EBA requests defining the same gas grid as the interconnected European network. It demands an end to restrictions on using subsidized biomethane within the ETS. The group also calls for the recognition of negative emissions from non-fossil sources.
Harmonized rules would eliminate market distortions and provide regulatory certainty for biogas operators.
Member States lose control over domestic subsidy schemes and carbon accounting across different regulations.

VCI urges better carbon capture recognition in EU emissio n s rules

Verband der Chemischen Industrie e.V., 28 Jul 2024

The VCI requests broader recognition of Carbon Capture and Utilizatio n technologies to prevent double counting. They advocate for regulatory coherence across directives to ensure an orderly implementatio n.
The se changes woul d reduce administrative burde n s and grant financial recognitio n for carbon-capturing.
Waste inci n e ratio n operator s may face higher cost s if incl u d e d in the syste m.

IATA warns of unscientific "black box" emissions monitoring rules

International Air Transport Association, 29 Jul 2024

IATA demands more time for compliance and a clearer methodology for non-CO2 effects tracking. They argue that using "black box" models without scientific validation is unreasonable for operators.
Airlines would avoid administrative burdens and inflated impact estimates from unrealistic default values.
Climate researchers lose access to data needed to understand aviation's full warming effects.

Air Liquide urges EU to recognize international carbon storage

AIR LIQUIDE, 29 Jul 2024

Air Liquide requests that carbon storage outside the EU be eligible for emissions exemptions. They support broadening carbon transport definitions and recognizing specialized low-carbon fuels.
These changes would lower costs and provide more options for their carbon capture services.

Air France-KLM urges scientific standards for non-CO2 aviation reporting

Air France-KLM, 29 Jul 2024

Air France-KLM requests the 100-year time frame to ensure international alignment and clarity. They oppose conservative default values for fuel properties which bias impact estimates. They also advocate for transparency across tools and including navigation provider performance.
Standardized metrics and automated data would reduce administrative burdens and ensure competitive fairness.
Air navigation service providers would face new accountability and performance indicators for flight trajectories.

EU aerospace industry urges phased approach to non-CO2 reporting

Aerospace, Security and Defence Industries Association of Europe, 29 Jul 2024

ASD recommends a phased implementation where reporting focuses on emissions data before calculating climate impacts in CO2 equivalents. They request that the NEATS tool be publicly available and developed through regular, transparent peer reviews involving industry and academia.
This prevents premature regulation based on uncertain models and secures funding for industry research.
Climate advocates lose immediate transparency on the full global warming impact of flights.

Carbon Market Watch urges immediate non-CO2 aviation reporting

Carbon Market Watch, 29 Jul 2024

Carbon Market Watch demands mandatory reporting for extra-EU flights starting January 2025. They argue the proposed delay for long-haul routes is an unacceptable step back.
Faster data collection enables earlier introduction of measures to reduce aviation's climate impact.
Climate protection efforts suffer as warming effects from long-haul flights remain unmonitored.

Euroheat & Power calls for gradual fuel switching in heating rules

Euroheat and Power, 29 Jul 2024

The association advocates for gradual fuel switching for large facilities with multiple boilers. They also request clearer biomass criteria and revised definitions to avoid regulatory mismatches.
A gradual approach ensures larger facilities can transition to biomass without facing impossible technical constraints.
Environmental transparency might decrease if monthly flue gas sampling is removed for incinerators.

Honeywell urges technology-neutral approach to EU carbon reporting

Honeywell Europe NV, 29 Jul 2024

Honeywell proposes a technology-neutral approach that rewards fuels based on actual carbon reduction. They suggest providing partial credit for fuels achieving significant savings below the 70% threshold. They also recommend recognizing international carbon pricing to support global aviation fuel supplies.
This would increase demand for Honeywell's proprietary carbon capture and fuel conversion technologies.
Environmental groups lose if lower performance fuels receive credits, potentially weakening decarbonization targets.

Snam urges zero-emission recognition for hydrogen and synthetic fuels

Snam S.p.A., 29 Jul 2024

Snam requests a zero-emission factor for hydrogen regardless of its production method or origin. They propose using purchase records to determine hydrogen fractions in gas blends and suggest aligning grid definitions with interconnected infrastructure concepts.
These changes would reduce carbon costs and facilitate hydrogen transport in existing gas grids.
Environmental groups lose the ability to penalize high-carbon hydrogen production methods.

Bioenergy Europe seeks transition period for biomass sustainability rules

Bioenergy Europe, 29 Jul 2024

The group requests including specific exemptions for remote regions and a certification transition period. They also want guidelines on how to prove these criteria are not applicable.
A transition period would prevent regulatory disruption and ensure continuous energy access for remote regions.
Environmental groups lose from the delayed application of updated sustainability and greenhouse gas criteria.

Cruise industry demands maritime sector provisions in emissions reporting rules

Cruise Lines International Association, 28 Jul 2024

The organization requests adequate provisions for the maritime sector and alignment with FUEL EU certification. They argue the regulation's focus on other sectors creates gaps for shipping and seek equal treatment with aviation in ETS implementing acts.
This would reduce regulatory uncertainty and avoid conflicting requirements across multiple EU legislations.

IAG urges simpler rules for monitoring aviation non-CO2 emissions

International Consolidated Airlines Group, 28 Jul 2024

IAG requests flexible deadlines and reduced administrative burdens through digital solutions. They advocate for data aggregation at the state pair level to protect sensitive information.
This would reduce technical investment costs and avoid complex labor negotiations.
Scientific researchers lose the granular data necessary for improving climate impact models.

Bellona Europa urges stricter monitoring for carbon transport and aviation

Bellona Europa, 29 Jul 2024

The organization calls for CO2 transport for utilization to be on the same footing as geological storage. They also request implementing monitoring schemes for all flights departing from the EEA.
Enhanced data collection would help the NGO advocate for penalising all emissions that reach the atmosphere.
Aviation and carbon utilization companies would face higher compliance costs and new reporting requirements.

easyJet Opposes Long-Haul Exemption in EU Non-CO2 Monitoring Rules

easyJet, 29 Jul 2024

easyJet demands including long-haul flights in the new non-CO2 monitoring system. They propose mandatory default value estimates to ensure a fair representation of effects. The airline warns of potential legal action against the current proposal.
Mandatory reporting ensures low-cost airlines are not unfairly targeted by climate policies.
Long-haul network carriers would lose their exemption from disclosing their environmental impact.

European waste industry urges flexible biomass monitoring over monthly mandates

FEAD, 29 Jul 2024

FEAD opposes mandatory monthly biomass fraction measurements in waste-to-energy plant flue gases. They want Member States to maintain flexibility in monitoring approaches, such as France's fossil factor method or Germany's thermal capacity ratio, arguing these are sufficient and cost-effective.
This would save the sector millions in compliance costs and avoid fiscal pressure on households.
Climate accountability loses precision as less frequent monitoring may underreport fossil carbon emissions from waste incineration.

Galp calls for equal treatment of low-carbon fuels in EU ETS

GALP ENERGIA SGPS, SA, 29 Jul 2024

Galp requests equal treatment between renewable fuels and low-carbon fuels in ETS reporting. The company also seeks more flexibility in reporting non-physically delivered fuels and wants separate compliance certificates allowed for different reporting obligations.
This would simplify compliance and reduce administrative burden for alternative fuel reporting.

European Express Association Urges Delay in Aviation Emissions Reporting

European Express Association, 29 Jul 2024

The association requests a more realistic implementation timescale, arguing the current 2025 start date is impossible to meet. They also suggest reviewing high default fuel values and providing monitoring plan templates to simplify the process.
A revised schedule would reduce the immediate administrative burden and risk of non-compliance for delivery operators.

Consultation response

COMITE EUROPEEN des FABRICANTS de SUCRE, 29 Jul 2024

SUMMARY. FULL POSITION IN ATTACHMENT CEFS members operate lime kilns to produce quicklime and CO2 by decomposition of limestones (CaCO3) with heat into Calcium Oxide (CaO) and CO2. In water suspended CaO and the CO2 are injected into sugar diffusion juice to re-carbonate the CaO to CaCO3 and…

CONCITO urges full monitoring for all aviation climate impacts

CONCITO, Denmarks Green Think Tank, 29 Jul 2024

CONCITO argues it is crucial to maintain the full geographic scope for monitoring non-CO2 aviation effects. Excluding long-haul flights would miss approximately 66 % of contrail impact, the biggest contributor to climate effects. This data is essential to guide future legislative proposals.
Reliable data would strengthen the case for their proposed climate policy actions.
Airlines operating long-haul routes would lose exemptions from mandatory climate impact reporting.

CCSA seeks biogenic CO2 recognition and cross-border transport

Carbon Capture & Storage Association, 29 Jul 2024

The CCSA requests that regulations allow CO2 transport to third countries like the UK. They advocate for zero-rating biogenic CO2 and exempting operators from liability for biogenic leaks. They also call for recognizing permanent carbon removals within the compliance market.
These changes would reduce administrative hurdles and financial liabilities for carbon storage operators.

Rolls-Royce calls for phased approach to non-CO2 monitoring

Rolls-Royce, 29 Jul 2024

Rolls-Royce requests a phased implementation that prioritizes reporting flight data over calculating carbon equivalents. They recommend making this data available to scientists and involving industry experts in tool development.
A phased approach avoids the risks of using inaccurate climate models for regulatory reporting.

GAMA urges scientific caution on EU non-CO2 aviation reporting

General Aviation Manufacturers Association, 29 Jul 2024

GAMA requests that the MRV focus purely on data reporting rather than converting impacts into CO2 equivalents. They propose a standard yearly review and formal roles for stakeholders in the process.
This approach prevents business aviation operators from facing burdensome requirements and inflated climate impact measurements.
Environmental advocates lose a potential regulatory basis for pricing non-CO2 aviation climate impacts.

Energy Traders Europe urges harmonized EU biomethane trade rules

Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe), 29 Jul 2024

The federation requests consistent use of the Union Database to remove trade barriers. They seek to include bio-LNG and non-EU carbon storage within the regulation.
Universal certification would lower administrative costs and increase market liquidity for energy traders.
National registries would lose the ability to impose unique domestic requirements on biomethane imports.

Global Business Travel Association seeks clarity on aviation emissions reporting

Global Business Travel Association, 19 Jul 2024

The organization supports reporting non-CO2 effects but insists on more research before extending regulations. They argue that current quantification methods have a low degree of confidence.
This ensures travel buyers can provide accurate environmental data to their sustainability teams.
Climate campaigners lose the immediate inclusion of all aviation emissions in the market.

Consultation response

International Council on Clean Transportation, 26 Jul 2024

The International Council on Clean Transportation (ICCT) appreciates the opportunity to provide feedback on this implementing act. Please find our feedback attached as a PDF file.

Solvay urges EU to scrap new soda ash emission rules

Solvay SA, 26 Jul 2024

Solvay requests the Commission maintain current reporting rules for soda ash production. They urge removing a paragraph that classifies process carbon as emitted by the producer.
This would avoid a 20% cost increase and preserve global market competitiveness.
Climate regulators lose the ability to track residual emissions from downstream users.

Business group urges voluntary aviation non-CO2 emission reporting

Związek Pracodawców Business & Science Poland, 29 Jul 2024

The organization argues that reporting for non-CO2 effects should be voluntary rather than mandatory. They claim current calculation methods rely on unreliable scientific estimates instead of accurate, available data. They also suggest limiting the reporting scope strictly to flights within the European Economic Area.
Airlines would avoid high administrative costs and potentially volatile financial compliance requirements.
Climate groups lose the data necessary to effectively mitigate aviation's total warming impact.

Tree Energy Solutions urges swift adoption of fuel zero-rating

Tree Energy Solutions BV, 29 Jul 2024

TES supports zero-rating for renewable fuels and using mass balance for gas distribution. They request the rules apply retroactively from January 2024 to help secure project funding. They also seek uniform EU-wide application to prevent countries from creating trade barriers.
This would lower carbon costs for their customers and help secure major industrial investments.
National governments would lose the flexibility to set custom rules for their decarbonization policies.

Drax Group urges clear timelines for biomass emission reporting

Drax Group plc, 26 Jul 2024

Drax asks to clarify timelines taking account of transposition deadlines and certification processes. They want the regulation to ensure biomass under existing subsidies can continue using previous criteria until 2030.
Clearer timelines would prevent Drax from facing unnecessary compliance costs and reporting hurdles.
Consumers could face higher energy prices if sustainable biomass use is discouraged.

Waste-to-energy plants demand flexible EU emissions monitoring rules

Confederation of European Waste-to-Energy Plants, 25 Jul 2024

CEWEP requests removing monthly analysis requirements and clarifying emission factors for municipal waste. They urge for greater flexibility on uncertainty tiers due to the complex nature of waste.
Flexible rules would prevent the overestimation of emissions and reduce complex compliance costs.

Vantaa Energy urges mass-balance accounting for waste-to-energy CCS

Vantaan Energia, 9 Jul 2024

Vantaa Energy proposes allowing Waste-to-Energy plants to use mass-balance accounting for carbon capture. They claim current proportional accounting forces operators to overcompensate for fossil-based emissions. This is essential for plants to meet future district heating efficiency standards.
This would reduce costs by preventing double payments and supporting carbon capture investments.

France Chimie urges maintenance of current carbonate accounting rules

France Chimie, 29 Jul 2024

France Chimie requests maintaining current rules for carbon accounting during carbonate production. They propose recognizing all forms of CO2 capture to reach climate neutrality.
Avoiding double-counting would lower regulatory costs and support investments in green chemistry.
Environmental integrity could be at risk if definitions of permanent carbon storage are expanded.

Consultation response

Finnair, 29 Jul 2024

Finnair fully subscribes to response by Airlines for Europe (A4E). Finnair welcomes the suggested geographical scope of monitoring and reporting of non-CO2 emissions. The draft Articles 53a on SAF reporting and Article 54a on claiming SAF allowances include provision on situations where eligible…

Consultation response

Future Cleantech Architects, 26 Jul 2024

See the file attached, thank you.

Consultation response

CEMEX, S.A.B. de C.V., 26 Jul 2024

Dear Sir or Madam, thank you for giving us the opportunity to submit our comments regarding this intitiative. You can find our comments in the document attached. Cemex EMEA Public Affairs

Fluxys urges flexible monitoring rules for CO2 transport networks

Fluxys SA, 25 Jul 2024

Fluxys advocates for flexible measurement methods and an alternative definition for CO2 in transit. They also emphasize including carbon transfers to non-EU countries to support emerging markets.
This provides operators with technical flexibility and prevents costs from rigid reporting deadlines.

Czech Chamber of Commerce urges flexible biomass monitoring rules

Hospodářská komora České republiky, 29 Jul 2024

The organization requests that biomass sustainability criteria apply only to specific units using biomass. They also advocate for long-term sampling to ensure representative data.
This allows large facilities to modernize gradually, avoiding the logistical impossibility of immediate conversion.

German aviation industry warns against overestimating non-CO2 flight impacts

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 29 Jul 2024

The association demands more transparent modeling and opposes using uncertain data for pricing. They argue against public data disclosure due to current scientific inaccuracies.
Preventing data publication and pricing avoids financial penalties based on overestimated emission reports.
Environmental groups lose access to public data needed to monitor airline climate impacts.

Consultation response

Natuur Milieu, 26 Jul 2024

Truly effective climate policy for aviation requires addressing worldwide non-CO2 climate effects. Aviation contributes to the warming of our planet. This is because greenhouse gases are released during flying. But that's not all. There is increasing understanding that the so-called non-CO2-related…

US pellet association urges better biomass carbon accounting rules

US Industrial Pellet Association, 29 Jul 2024

USIPA requests that reporting rules align with renewable energy laws to keep biomass zero-rated for emissions. They specifically seek the inclusion of legal protections for existing projects and remote regions.
This allows their members to maintain market share by keeping wood pellets tax-exempt.
Energy consumers would face higher prices if biomass is treated like fossil fuel.

Consultation response

Wizz Air Group, 29 Jul 2024

The MRV is the principal tool at the EUs disposal to advance the science of non-CO2 effects. While other industry initiatives are to be supported, the MRV currently represents the only legislative option guaranteed to gather data from the entire sector. To advance our understanding, the MRV must…

European wood-panel industry urges flexible biomass monitoring rules

European Panel Federation, 29 Jul 2024

EPF argues that the 'disproportioned costs' of expensive measurement systems for carbon emissions must be addressed. They claim their specific manufacturing processes make it 'impossible to develop' a standard carbon balance. They also request a 'homogenous application' of green standards across all EU countries.
This would protect manufacturers from excessive costs and unworkable reporting requirements.
National governments would lose the flexibility to set their own specific sustainability criteria.

CO2 Value Europe demands legal certainty for carbon capture

CO2 Value Europe AISBL, 29 Jul 2024

The group calls for clearer definitions to avoid conflicting interpretations of EU laws. They also seek long-term stability to protect industrial investments from future changes.
Consistent regulations would allow businesses to finalize plans and secure investments.

EBAA Urges Simplified Rules for Non-CO2 Emission Reporting

EUROPEAN BUSINESS AVIATION ASSOCIATION, 29 Jul 2024

EBAA requests simplified reporting for small operators and a delay in using climate impact metrics. They also advocate for an EU-wide system to track and claim cleaner aviation fuels.
This would reduce administrative burdens and prevent potentially inflated calculations of the sector's climate impact.
Environmental groups lose precise data if climate metrics are omitted from the initial reporting phase.

German cement industry warns of barriers to carbon capture

Verein Deutscher Zementwerke e.V., 26 Jul 2024

VDZ requests removing proportionality requirements that hinder reaching installation-level carbon neutrality. They also seek realistic measurement standards and broader recognition of carbon reuse.
Flexible rules would lower compliance costs and encourage investments in decarbonisation.
Climate targets could be compromised if measurement accuracy requirements are lowered.

Consultation response

Albioma, 29 Jul 2024

Albioma is an independent renewable energy company with most of its operations in the French overseas territories, including Reunion Island, Mayotte, Guadeloupe, Martinique, French Guiana, and Mauritius. Our power plants currently provide up to 50% of the electricity needs of the territories in…

ZERO group slams proposal for excluding long-haul flight monitoring

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 24 Jul 2024

ZERO demands that monitoring covers all flights arriving at or departing from European airports. They argue that excluding long-haul flights ignores the biggest contributors to climate-warming contrails.
Comprehensive data would help the group advocate for more effective aviation climate policies.
Long-haul airlines would face new reporting burdens and potential future climate-related costs.

EIGA urges EU to recognize non-EU carbon storage solutions

European Industrial Gases Association AISBL, 29 Jul 2024

EIGA requests that transport and storage of CO2 outside the EU be eligible for ETS exemptions. They advocate for removing barriers to diverse transport solutions and clarifying liability for capture emissions.
This flexibility would reduce compliance costs by allowing access to more affordable storage sites.

Airlines Demand Realistic Timelines for Non-CO2 Emission Reporting

Airlines International Representation in Europe, 29 Jul 2024

AIRE requests more time for monitoring plans and a simplified reporting template. They propose aligning the non-CO2 scope with existing EU ETS rules. This alignment aims to streamline management and reduce administrative burdens.
This would reduce administrative complexity and prevent inflated costs from overestimated emissions.
Environmental groups lose data accuracy if conservative estimates are replaced by average values.

European lime industry demands emissions accountability at point of release

European Lime Association, 29 Jul 2024

EuLA wants emissions accounted for at the point of atmospheric release. They also seek a link between the carbon market and removal certifications.
The industry would avoid financial penalties for carbon that is captured, purified, and transported.
End-users would lose because they must cover the costs of managing their generated pollution.

Consultation response

Global CCS Institute Ltd, 29 Jul 2024

The European Union (EU) has taken a leadership role in establishing a roadmap to achieve climate neutrality by 2050. Central to this ambition, as underscored in the European Commission's proposed 2040 climate target and EU industrial carbon management strategy, is the development of carbon capture…

Consultation response

European Network Airlines' Association, 26 Jul 2024

The European Network Airlines Association (ENAA) welcomes the European Commissions approach that requires airlines to monitor and report on the non-CO2 impacts of their intra-EEA flights for the years 2025 and 2026. This will allow a smoother ramp-up of the non-CO2 MRV implementation for aircraft…

Consultation response

Polskie Linie Lotnicze "LOT" S.A., 19 Jul 2024

LOT Polish Airlines appreciates the opportunity to provide feedback on the draft of Commission Implementing Regulation amending Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European…

Consultation response

Condor Flugdienst GmbH, 29 Jul 2024

Condor Airlines appreciates the opportunity to provide feedback on the EU Commission's open consultation regarding the draft Implementing Regulation (EU) 2018/2066, referred to as the Monitoring and Reporting Regulation (MRR) of greenhouse gas emissions pursuant to Directive 2003/87/EC of the…

Spanish cement industry seeks flexible carbon accounting rules

Agrupación de fabricantes de cemento de España, 29 Jul 2024

The industry requests accounting rules that support carbon capture and alternative fuels. They seek flexibility to avoid creating barriers to mitigation technology deployment.
This would lower investment risks and help maintain competitiveness during industrial decarbonization.

Belgian chemical industry demands better recognition for carbon capture

Fédération belge des industries chimiques et des sciences de la vie, 28 Jul 2024

Essenscia urges the Commission to recognize CO2 avoidance from all sources, including zero-rated fuels. They request broader definitions for carbon-capture products and the removal of gas grid connection requirements.
The industry would benefit from reduced carbon costs and greater flexibility in fuel sourcing.

Spanish chemical industry warns against double counting in carbon rules

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 27 Jul 2024

FEIQUE urges recognition of all carbon capture technologies to prevent double counting. They request maintaining current soda ash rules to avoid tracking complex customer data. They also seek clearer certification requirements for biomass used as raw materials.
These changes would prevent increased costs from surrendering allowances and reduce administrative reporting burdens.
Environmental groups lose if carbon capture is recognized without strict permanent storage requirements.

Consultation response

Bundesverband Bioenergie e.V., 29 Jul 2024

Der Bundesverband Bioenergie e.V. (BBE) ist der Dachverband der deutschen Bioenergiebranche und vertritt Unternehmen und Verbände aus den Bereichen feste, flüssige und gasförmige Biomasse. Der BBE begrüßt, dass gemäß der Richtlinie 2003/87/EG der Emissionsfaktor für Biomasse Null ist, wenn die in…

Consultation response

Bundesverband der Deutschen Kalkindustrie e.V., 29 Jul 2024

BVK welcomes the possibility to comment on the Commission´s proposal for the imple-menting regulation on MRR. As a highly effected industry in the middle of the transfor-mation process we urge the Commission for changes and clarification before adopting the implementing regulation. Please find our…

Waste technology suppliers urge flexibility in emissions reporting

European Suppliers of Waste-to-Energy Technology, 26 Jul 2024

ESWET calls for a flexible approach to emissions monitoring and opposes mandatory monthly sampling. They argue that changing rules so quickly creates significant administrative hurdles for operators.
Maintaining flexibility would prevent high costs and delays caused by insufficient laboratory capacity.
Environmental oversight could be weakened by less frequent or less rigorous carbon monitoring standards.

Consultation response

France Ciment, 29 Jul 2024

Vous trouverez ci-joint l'avis de France Ciment sur ce projet de règlement modifié.

Consultation response

Stockholm Exergi, 24 Jul 2024

Amendment 25(c) concerning Article 49 proposes that: "An operator of a CO2 transport infrastructure or a storage site shall monitor emissions from leakage events, fugitive emissions and vented emissions from any CO2 mentioned in the first sub-paragraph, including from CO2 stemming from entities not…

Consultation response

Elengy, 29 Jul 2024

ELENGY feedback on the review of the EU ETS Monitoring and Reporting Regulation ELENGY is promoting two CCS projects, GO CO2 in our Montoir-de-Bretagne terminal, and Rhône CO2 in our Fos terminal. ELENGY welcomes the opportunity to comment on the Commissions draft proposal to update the EU ETS…

Polish chemical lobby rejects new carbon reporting for sodium carbonate

Polska Izba Przemysłu Chemicznego, 29 Jul 2024

PIPC requests keeping current reporting rules and removing the clause treating intermediary CO2 as emitted. They argue sodium carbonate does not always release gaseous CO2 during use, especially in detergents. The group claims the draft violates the "polluter pays" principle by creating virtual emissions.
This would prevent a 20% increase in production costs and preserve industry competitiveness.
European glass and detergent manufacturers face higher costs compared to non-EU competitors.

Consultation response

Polskie Towarzystwo Energetyki Cieplnej, 29 Jul 2024

Uwagi PTEZ ws. zmiany rozporządzenia dot. monitorowania i raportowania.

FEDENE Urges Flexible Waste Emission Monitoring and Biomass Rules

Fédération des services énergie environnement, 29 Jul 2024

FEDENE requests that small biomass installations be zero-rated directly to reduce the administrative burden. They argue for allowing Member States to follow their own approach for waste-to-energy installations. They also seek clarity on justifying zero emissions using Biomethane Guarantees of Origin.
This would lower compliance costs and avoid technical requirements that are currently unachievable.
Environmental groups and regulators lose precise data if monitoring frequency and accuracy are reduced.

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE MAGNESIA, 29 Jul 2024

En el archivo adjunto se pueden consultar los comentarios de la industria española de la magnesia a la modificación del Reglamento sobre seguimiento y notificación del RCDE UE del régimen de comercio de derechos de emisión (RCDE) que ha propuesto la Comisión Europea.

Consultation response

RDF Industry Group, 25 Jul 2024

We write to you on behalf of the Refuse Derived Fuel (RDF) Industry Group with regards to the public consultation on the EUs Emissions Trading Scheme (ETS). Our Group represents 38 organisations across the European waste derived fuel (WDF) supply chain, including WDF production companies who…

Consultation response

Inter-Environnement Wallonie, 19 Jul 2024

Long-haul flights have a disproportionate non-CO2 climate impact. Excluding them from the non-CO2 monitoring scheme would: Ignore their outsized non-CO2 climate effects, including 67% of contrail warming of EEA flights; Go against the EU ETS agreement by co-legislators; Weaken the ability of the…

Consultation response

The International Association of Independent Tanker Owners, 9 Jul 2024

INTERTANKO wants to respond to the invitation for feedback on the European Commissions draft revision of the Implementing Regulation (EU) 2018/2066 as regards updating the monitoring and reporting of greenhouse gas emissions (Monitoring and Reporting Regulation, MRR), in particular to make comments…

Consultation response

Swedish Gas Association / Energigas Sverige, 9 Jul 2024

The Swedish Gas Association welcomes the fact that the EU is taking an ambitious holistic approach to climate policy. The legislation package "Fit for 55" is an important step in reducing emissions by at least 55 percent by 2030, and achieving climate neutrality by 2050 two important goals that we…