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Carbon Leakage List 2021 - 2030

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Public consultation

ID: 1146

Lobbying Activity

36 responses

Chemical industry urges full carbon leakage protections for all subsectors

European Chemical Industry Council, 13 Nov 2017

Cefic requests all chemical subsectors remain on the carbon leakage list and receive free emissions allowances at benchmark levels. They argue the industry is vertically integrated and discrimination between subsectors would damage competitiveness across whole value chains.
This would shield them from direct carbon costs and electricity price increases.
EU climate goals suffer as fewer emissions allowances are auctioned for revenue.

Consultation response

The European Steel Association, 13 Nov 2017

Carbon leakage provisions are an essential element of the ETS Directive. They are meant to preserve EU industrial competitiveness and to avoid the increase of worldwide emissions as a result of EU industrial activity being replaced by production in third countries without equivalent climate…

Finnish forest industry demands robust carbon leakage cost assessments

Finnish Forest Industries Federation (Metsäteollisuus ry), 13 Nov 2017

The federation requests that electricity assessments reflect how fossil fuel plants set market prices. They also propose treating non-EU countries as a single block for trade calculations.
These measures provide stability and prevent companies from facing competitive disadvantages globally.
Trading partners with climate policies lose out if they are not considered comparable.

Consultation response

EUROMETAUX, 13 Nov 2017

Eurometaux, represents the European non-ferrous metals (NFM) sector. In the NFM industry, production processes are more electricity-intensive than those used in other sectors. Thus, indirect carbon costs from the EU ETS are often significantly higher than other energy intensive sectors. In…

Paper industry urges robust methodology for carbon leakage list

Confederation of European Paper Industries, 13 Nov 2017

The industry requests that carbon leakage assessments reflect how fossil fuel plants impact electricity prices. They also suggest treating the rest of the world as a single block for trade calculations.
This methodology would provide the regulatory stability needed to invest in low-carbon solutions.

Consultation response

CEMBUREAU - The European Cement Association, 10 Nov 2017

CEMBUREAU has read with attention the European Commission inception impact assessment for the Carbon Leakage List 2021-2030. CEMBUREAU calls for a regulatory environment which provides legal certainty and stability for long-term investments, innovation, growth and jobs. Within a competitive…

Fertilizers Europe urges targeted free carbon emission allowances

Fertilizers Europe, 9 Nov 2017

The organization requests a carbon leakage list better focused on sectors with high exposure. They specifically advocate for avoiding the cross-sectoral correction factor during the upcoming period.
Targeted allocations would protect their competitive position and reduce potential carbon costs.
Less emission-intensive industries would receive fewer free allowances under a more focused list.

Ceramic industry welcomes inclusion on EU carbon leakage list

European Ceramic Industry Association, 20 Dec 2018

Cerame-Unie supports the draft decision placing ceramic subsectors on the carbon leakage list. They emphasize that many manufacturers are small businesses facing a significant net cost burden. The association seeks to participate in future consultations on climate policy.
Remaining on the list protects the industry from rising regulatory costs and potential relocation.

Consultation response

European Ceramic Industry Association, 10 Nov 2017

Please refer to the attached letter.

Consultation response

Carbon Market Watch, 13 Nov 2017

Carbon Market Watch (CMW) is a not-for-profit organisation with a unique expertise on the functioning of carbon markets, advocating for fair and effective climate protection. Its network connects more than 800 NGOs and academics from 70 different countries from the global North and South. The…

Consultation response

European Tyre & Rubber Manufacturers' Association, 10 Nov 2017

ETRMA, the European Tyre and Rubber Manufacturers’ Association, welcomes the possibility to provide a feedback on the Inception Impact Assessment on the Carbon Leakage List 2021-2030. As a preliminary step to the publication of the Impact Assessment, this consultation is a first opportunity for…

Consultation response

Norsk Hydro, 13 Nov 2017

Norsk Hydro is a global supplier of aluminium with activities throughout the value chain, from bauxite extraction to the production of rolled and extruded products as well as recycling. With 35,000 employees globally, and operations all around Europe, Hydro has large production units exposed to…

Consultation response

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 13 Nov 2017

In the revised Directive, no alternative methodology is foreseen for (sub)sectors with no trade data available for the calculation of the trade intensity indicator, and therefore the industry could not submit a quantitative analysis to qualify that sector to be at risk of carbon leakage. Indeed,…

Consultation response

VERBUND AG, 31 Dec 2018

VERBUND appreciates the possibility to comment on the draft Commission decision determining a list of sectors and subsectors which are deemed to be at risk of carbon leakage. VERBUND is Austria’s largest electricity generator. 95% of our generation stems from renewable energy sources. In order…

Consultation response

European Insulation Manufacturers Association, 10 Nov 2017

Eurima welcomes the opportunity to comment on the Inception Roadmap concerning the carbon leakage list 2021-2030. Prior to drafting the list, as part of the methodological choices for the parameters of the assessment it is essential to have a fair and transparent framework which takes into account…

Consultation response

EUROALLIAGES, 13 Nov 2017

EUROALLIAGES is the European association of ferro-alloys and silicon producers representing more than 95% of the sector. Our products feed the steel, aluminium, chemical, electronic and solar value chains. While supporting and complying with the EU ETS, we are heavily impacted by this system both…

Consultation response

Glass for Europe, 2 Nov 2017

Glass for Europe, the association representing the European flat glass sector, welcomes the European Commission’s consultation on the Inception Impact Assessment. Some directions on the methodological approach will be determined at this stage with direct consequences on the evaluation of the…

Consultation response

Eurogypsum, 13 Nov 2017

Dear All protection from Carbon Leakage is a very important element in EU ETS to combine economic growth with climate change policies. Qualitative assessment of carbon leakage risks should be fully kept open by the possibility to provide own substantiated, complete and verified data to the EC…

Consultation response

IFIEC Europe, 11 Nov 2017

IFIEC Europe represents the interests of those industrial sectors for which energy is a significant component of production costs. IFIEC Europe's mission is to anticipate and to respond to the evolving requirements of those sectors by proposing policies that allow realistically priced energy to be…

Consultation response

Nickel Institute, 13 Nov 2017

The Nickel Institute as industry association representing the interests of European nickel producers welcomes the European Commission´s consultation on the inception impact assessment which was launched on 16th October 2017. We would like to use the opportunity to submit our comments. The…

Consultation response

European Industrial Gases Association AISBL, 7 Nov 2017

Carbon leakage list must ensure competitiveness and avoid damaging market distortions: For the Industrial gases sector and its end-user industries, it is of critical importance that hydrogen and syngas sub-sector (Prodcom) be included in the carbon leakage list. Any other outcome would reduce…

Polish Gas Giant Urges Inclusion in Carbon Leakage List

Polskie Gornictwo Naftowe i Gazownictwo SA - Polish Oil and Gas Company, 21 Dec 2018

PGNiG requests that natural gas extraction be added to the protected list. They argue the current assessment uses flawed data and methodology to calculate trade intensity.
Inclusion would grant the company free emission allowances, lowering its regulatory costs.

Consultation response

Eesti Energia Aktsiaselts, 13 Nov 2017

Dear Sirs, Estonian energy company Eesti Energia AS is engaged in production of shale oil and generation, distribution and sales of electricity. Shale oil production (classified under the manufacture of refined petroleum products) is already now identified as a sector which is exposed to a…

Consultation response

Confederation of the German Textile and Fashion Industry, 13 Nov 2017

In Bezug auf die Carbon Leakage-Liste möchten wir grundsätzlich anmerken, dass eine Qualifizierung für diese Liste auch ausschliesslich aufgrund eines qualitativen Nachweises möglich sein muss. Dieser sollte in Form von fachlich qualifizierten Gutachten oder ähnlichen Belegen erfolgen können.…

Consultation response

Fédération belge des industries chimiques et des sciences de la vie, 27 Dec 2018

Essenscia, the federation of chemistry and life sciences in Belgium, wants to thank the European Commission for this consultation. For the carbon leakage assessment, the emission intensity for each NACE4-sector was calculated. Although, in most cases, the emission data only relate to ETS…

Consultation response

Fédération belge des industries chimiques et des sciences de la vie, 10 Nov 2017

The ETS has a significant impact on the competitiveness of energy-intensive industries, due to EU-specific direct costs (purchase of ETS allowances) and indirect costs (CO² as element of electricity price). Today, energy costs in the EU are higher than in other industrialised regions relevant for…

Spanish chemical industry seeks robust data for carbon leakage

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 13 Nov 2017

The federation demands assessments based on current electricity data and detailed international policy comparisons. They advocate for updated economic figures and high-quality data to ensure sector transparency.
More precise data and rigorous policy analysis protect the industry’s access to subsidies.

Consultation response

Norsk Industri / Federation of Norwegian Industries, 13 Nov 2017

See attachment

Consultation response

Koninklijke Vereniging van de Nederlandse Chemische Industrie, 13 Nov 2017

please find attached our feedback (VNCI) to this consultation Kind regards, Reinier Gerrits Head of Energy & Climate at VNCI (The Netherlands Chemical Association)

Consultation response

European Salt Producers' Association, 12 Nov 2017

Introduction EUsalt, The European salt producers’ association, is supportive of the efforts of European policymakers to reduce emissions and preserve our environment and aims to actively participate in the decision-making process and in the implementation of measures to reduce the environmental…

Consultation response

CIRFS: European Man-made Fibres Association, 13 Nov 2017

The feedback is given in the attached file.

Consultation response

European Foundry Federation, 13 Nov 2017

Grundsätzlich: Die Teilnahme der Gießerei-Industrie am EU-Emissionshandel kann nahezu keinen klimaschützenden Effekt haben. Von 4.700 Gießereien in Europa nehmen mit 29 Unternehmen lediglich 0,6% der Branche teil. Der Anteil der Gießereien an den europaweiten CO2-Emissionen liegt deutlich unter…

Consultation response

European Expanded Clay Association, 10 Nov 2017

EXCA welcomes the Inception Impact Assessment on the Carbon Leakage List 2021 - 2030 published by the European Commission (Ref.: Ares (2017)5046070) and expresses its interest to be involved as a stakeholder during the consulting process. EXCA is the European expanded clay association and…

Consultation response

Conselho Empresarial para o Desenvolvimento Sustentável, 13 Nov 2017

Conselho Empresarial para o Desenvolvimento Sustentável (BCSD Portugal) welcomes the opportunity given to stakeholders to comment on the Inception Impact Assessment for the Carbon Leakage List 2021 – 2030. The European Union (EU) has committed to achieving a net zero economy by 2050. This is a…

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE MAGNESIA, 13 Nov 2017

MAGES (Asociación Española de Fabricantes de Magnesia) welcomes the European Commission’s publication of the Inception Impact Assessment for the Carbon Leakage List 2021 - 2030 (Ref.: Ares (2017)5046070) and wishes to express its interest in being involved as a key stakeholder during the entire…

Consultation response

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 30 Oct 2017

Dear European Commission, Thank you very much for sending me the roadmap. After reading the timetable I will give the Commission the following information. Directive 2003/87 / EC, referred to in the Roadmap, establishing a scheme for greenhouse gas emission allowance trading within the Community…