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Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

Climate action

To prepare the transition to economy-wide climate neutrality by 2050, the Commission proposed to scale up greenhouse gas emission reductions for 2030 to at least 55% compared with 1990 levels. To deliver this ambition, the Commission will review all relevant policies. This includes the Regulation on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 (Effort Sharing Regulation).

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Public consultation

ID: 12656

Lobbying Activity

103 responses

Consultation response

Transport and Environment (European Federation for Transport and Environment), 25 Nov 2020

The missing “Option zero”, maintaining the existing climate architecture, strengthening the ESR T&E regrets that the EC did not include the option of maintaining the current architecture by raising both the ambition of the ETS and the ESR. The ESR has proved to be an efficient tool to…

Consultation response

WWF European Policy Programme, 26 Nov 2020

The missing “Option zero”: keeping the existing climate architecture and strengthening the ESR WWF does not support any of the options described by the Commission and instead calls for the current scope of the ESR (including transport, buildings and agriculture) to be maintained and national…

Consultation response

Climate Action Network Europe, 8 Nov 2021

CAN Europe welcomes the Commission’s proposal to keep national emission reduction targets and scope of the Effort Sharing Regulation (ESR). We acknowledge the Fit for 55 package is a massive piece of work attempting to tackle dangerous climate change. Yet, the overall level of ambition needs to be…

Consultation response

Climate Action Network Europe, 26 Nov 2020

Keep ESR and retain nationally binding targets for the majority of GHG emissions Member States will take no responsibility for achieving emission reductions in current non-ETS sectors if they are removed from national obligations under the ESR, undermining the adoption and strengthening of…

German industry federation BDI urges flexible climate target rules

Bundesverband der Deutschen Industrie e.V., 8 Nov 2021

BDI supports flexible rules that allow countries to trade or save emission credits. They also call for better alignment between national targets and new carbon pricing.
This approach would protect the global market position of European industrial companies.

German industry group BDI backs separate emissions trading for transport

Bundesverband der Deutschen Industrie e.V., 24 Nov 2020

The BDI advocates for a separate upstream trading system for the buildings and transport sectors to ensure the system remains manageable. They also call for the voluntary crediting of renewable synthetic fuels in transport fleet regulations to create a level playing field.
A separate, upstream system would reduce administrative complexity for industrial companies while creating markets for their low-carbon products.
Poorer member states may suffer if richer nations simply purchase certificates rather than making domestic climate efforts.

Chemical Industry Warns Climate Rules Shift Burden from States to Business

European Chemical Industry Council, 26 Oct 2021

The organization argues national emission targets are insufficient, leaving industry to shoulder disproportionate effort. They demand stronger carbon leakage protections, guaranteed free allocation volumes under ETS, and supporting measures for renewable hydrogen until cost-competitive. They oppose using ETS allowances for effort-sharing compliance.
This would protect their global competitiveness and avoid additional climate compliance costs.
Member states face less pressure to tackle emissions from buildings and transport sectors.

Consultation response

European Chemical Industry Council, 25 Nov 2020

Cefic supports Europe’s ambition to become climate-neutral by 2050. We acknowledge the EU’s desire to significantly accelerate the transition, in order to increase our chances to reach climate-neutrality by 2050. Increasing the 2030 EU GHG target should provide a balanced reduction pathway towards…

Consultation response

Finnish Forest Industries Federation (Metsäteollisuus ry), 8 Nov 2021

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ response to the consultation on the Effort Sharing Regulation (ESR) Finnish Forest Industry Federation…

Consultation response

Finnish Forest Industries Federation (Metsäteollisuus ry), 26 Nov 2020

Finnish Forest Industries Federation Contact: ahti.fagerblom@forestindustries.fi Finnish Forest Industries’ viewpoints on public consultation on EU Effort Sharing (ESR) Wood-based products and sustainable forest management will play an important role when achieving climate neutrality for 2050 as…

Consultation response

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 7 Nov 2021

EU climate policy can only be brought into line with the Paris Climate Agreement if each Member State fulfills its responsibilities. This means that no Member State will have its emissions credited to the other Member States, in another words Each Member state needs to fulfill no-debit-rule on its…

Consultation response

Maa- ja metsätaloustuottajain Keskusliitto – Central Union of Agricultural Producers and Forest Owners, 26 Nov 2020

MTK supports the overall ambition to act on climate change and find it essential that the agricultural and forestry sector contributes to the debate on climate action. Finnish farmers and forest owners have been successful in reducing green-house gas emissions significantly in past three decades…

Swedish Enterprise calls for cost-effective national climate targets

Confederation of Swedish Enterprise, 26 Nov 2020

The organization advocates for national targets based on cost-effectiveness rather than GDP per capita and proposes a minimum carbon tax across all member states. They also stress avoiding double regulation and double pricing of emissions.
Swedish companies would benefit from a more level playing field where other member states carry a fairer share.
Lower-income member states would lose the preferential target treatment they currently receive based on their GDP.

Consultation response

ENEL SpA, 8 Nov 2021

Enel warmly welcomes the Commission’s proposal amending the EU Effort Sharing Regulation included in the “Fit for 55” Package. The Effort Sharing Regulation (ESR) is a key piece of legislation within the EU energy and climate framework, given that it addresses GHG emissions reduction in sectors…

Consultation response

ELECTRICITE DE FRANCE, 26 Nov 2020

Please find enclosed EDF's feedback on the ESR revision

Consultation response

ENEL SpA, 26 Nov 2020

Enel welcomes the revision of the Effort Sharing Regulation (ESR) and the related Impact Assessment, aimed at enhancing EU climate policies in light of the more ambitious climate targets. The current ESR target (30% reduction vs. 2005 in sectors not covered by the ETS such as transport and…

Consultation response

Eni S.p.A., 26 Nov 2020

Eni supports the European Commission in the effort to strengthen the current EU climate policy framework in order to enable it to cope with the increased EU climate ambition. Please, find attached our key messages.

Consultation response

Hydrogen Europe, 8 Nov 2021

Hydrogen Europe welcomes the proposed increased ambitions of GHG emission reduction targets under the Effort Sharing Regulation (ESR) proposal and the parallel coverage of buildings and transport sectors by ESR and ETS. Considering the increased net GHG emission target of at least 55% by 2030,…

Consultation response

Wirtschaftskammer Österreich, 24 Nov 2020

We call for a fair burden-sharing between Member States and the EU in case of a redefinition of the climate target. We believe a mere mathematical break down of the overly ambitious EU target to ETS, Non-ETS and – within the Non-ETS – to the Member States not realistic. The allocation of Members…

Neste urges keeping road transport emissions in Effort Sharing Regulation

Neste Oyj, 5 Nov 2021

Neste requests that road transport remain under the Effort Sharing Regulation rather than being moved to the EU emissions trading system. They emphasize maintaining member state flexibility in meeting targets and ensuring a broad feedstock base for biofuels.
This preserves demand for their biofuel products by allowing national implementation flexibility.
No clear harm is identifiable; the position aligns with Commission impact assessment.

Consultation response

Neste Oyj, 26 Nov 2020

Neste (neste.com) fully supports the Green Deal’s ambition for climate neutrality in 2050 as well as stepping up the GHG emissions reduction target to at least 55% by 2030. In our view higher targets within the existing legislative framework can deliver these results. Maintaining the existing EU…

Consultation response

Fortum Oyj, 23 Nov 2020

Fortum is a firm supporter of the EU emissions trading system (ETS) as the main instrument of the EU climate policy, because a well-functioning, market-driven and technology neutral emissions trading is the most cost-efficient instrument to decarbonize the European economy. The EU ETS has proven…

Consultation response

IBERDROLA, 8 Nov 2021

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate…

Consultation response

IBERDROLA, 24 Nov 2020

Decarbonisation price signals and a level playing field for all the available options are essential to tackle emissions and increase efficiency, both for consumers and emitters side. Products must internalise the total environmental cost through a set of consistent climate tools, so that…

Consultation response

Finnish Energy - Energiateollisuus ry, 26 Nov 2020

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment and policy options. We would like to highlight the following points to consider: 1. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the…

Consultation response

Deutsche Umwelthilfe e.V., 26 Nov 2020

To comply with the Paris Agreement, the EU’s 2030 climate target must be raised to at least 65%, supported by a functioning and effective climate policy architecture. The EU outlines three options for the future of the Effort Sharing Regulation (ESR). While some options are worse than others, none…

Consultation response

The Danish Chamber of Commerce, 28 Sept 2021

The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Effort Sharing Directive (ESR). The Danish Chamber of Commerce supports an extension of the ETS to more sectors such as the transportation and building sectors (cf. the Danish…

Consultation response

The Danish Chamber of Commerce, 26 Nov 2020

The Danish Chamber of Commerce thanks the Commission for the opportunity of responding to the roadmap regarding national emissions reduction targets and effort sharing regulation (ESR). We strongly support EU climate ambitions and complementary policies and want to emphasize the importance of high…

Fertilizers Europe calls for balanced targets and competitiveness

Fertilizers Europe, 26 Nov 2020

The organization calls for a level playing field between EU producers and importers through carbon border adjustments. They request financial incentives and infrastructure support to enable the transition to low-carbon ammonia production.
Carbon border measures and free allowances would protect their competitiveness against cheaper imports.
Foreign exporters would face higher costs to access the European market.

German chemical industry calls for EU-wide carbon pricing to level playing field

Verband der Chemischen Industrie e.V., 29 Oct 2021

The association requests an EU-wide system for carbon pricing of smaller industrial facilities to prevent competitive disadvantages. They want hazardous waste incineration exempted from carbon pricing since no technical alternatives exist.
This would eliminate competitive disadvantages from Germany's unilateral carbon pricing for their facilities.

German chemical industry warns against expanding EU emissions trading system

Verband der Chemischen Industrie e.V., 24 Nov 2020

The organization opposes extending the EU Emissions Trading System (ETS) to new sectors to avoid price spikes. They suggest creating separate systems for transport and buildings instead.
This prevents chemical plants from facing uncompetitive carbon prices driven by transport sector costs.
Non-industrial sectors face higher burdens to meet targets if industry contributions are minimized.

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 7 Nov 2021

The Danish Agriculture and Food council (DAFC) appreciate the opportunity to provide feedback to the proposal for a Revision of the Burden Sharing Regulation. The DAFC have the following comments to the proposal. The DAFC note that with the Commission’s proposed revision of the Effort Sharing…

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 26 Nov 2020

The Danish Agriculture & Food council (DAFC) welcomes the Commission’s effort on climate action and supports the joint work on the 2030-climate target as well as the objective of climate neutrality in 2050. DAFC urges the Commission to pursue cost-effective CO2-reductions such as reductions within…

Consultation response

Carbon Market Watch, 26 Nov 2020

Carbon Market Watch - Response to Inception Impact Assessment on Effort Sharing Regulation (ESR) We regret that the Commission did not include a policy option that would ensure the current climate policy architecture is maintained in order to raise the emission reductions achieved by the Effort…

Consultation response

#SustainablePublicAffairs, 26 Nov 2020

Corbion thanks the European Commission for the opportunity to respond to the inception impact assessment for reviewing the Effort Sharing Regulation (ESR). Corbion fully supports the Commission’s proposal to increase Europe’s 2030 climate target to at least 55% and agrees that all sectors,…

Consultation response

Vattenfall, 8 Nov 2021

Vattenfall supports the European Commission’s proposal to revise the Effort Sharing Regulation (ESR) in line with the EU’s increased 2030 climate ambition. All sectors must contribute towards the unprecedented task of making the EU a climate-neutral welfare economy. Without significant progress in…

Consultation response

Vattenfall, 26 Nov 2020

The effort to reach the EU’s new climate targets must be shared between all sectors of the economy in a fair, coherent and cost-efficient manner. The additional effort of reducing GHG emissions that comes with the increased EU 2030 and 2050 climate ambition should be fairly distributed between the…

German municipal utilities reject double regulation under emissions trading

Verband Kommunaler Unternehmen e.V., 8 Nov 2021

The association requests that sectors covered by the new emissions trading system be removed from the Effort Sharing Regulation. They argue double regulation creates regulatory uncertainty and undermines the effectiveness of market-based climate instruments.
This would eliminate duplicate compliance obligations and reduce administrative burden for member companies.

Consultation response

Veolia Environnement, 26 Nov 2020

We welcome the initiative of the European Commission to review the Regulation on binding annual greenhouse gas (GHG) reductions by Member States, the so called Effort Sharing Regulation. Below we provide our thoughts regarding the place the buildings and waste sectors should have respectively in…

Consultation response

International Copper Association Europe, 26 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the Commission’s inception impact assessment on the amendment of the EU Effort Sharing Regulation. Our association supports the clean energy transition towards a climate-neutral EU, while safeguarding competitiveness of the…

Consultation response

Plastics Recyclers Europe, 8 Nov 2021

Dear, Please find enclosed the feedback from Plastics Recyclers Europe to the revision of the Effort Sharing Regulation. We remain available to further discuss the elements tackled in our position paper with the relevant team at the European Commission. Best regards,

FIA advocates including road transport in EU emissions trading

Fédération Internationale de l'Automobile, 8 Nov 2021

The FIA recommends moving road transport into the EU emissions trading system. They also call for lower fuel taxes to keep the reform financially neutral.
This shift would reduce the high cost of cutting emissions for drivers.
Other industries and low-income households would face greater pressure or higher costs.

Consultation response

Efficient Buildings Europe, 26 Nov 2020

EuroACE strongly supports the Commission work in raising the 2030 climate target to at least 55% and the objective of reaching climate neutrality by 2050. All sectors will need to contribute and in particular, the buildings sector, as it represents 40% of the EU energy consumption and 36% of its…

Consultation response

The Coalition for Energy Savings, 25 Nov 2020

The Coalition for Energy Savings would like to thank the Commission for the opportunity to provide feedback to the roadmap on amending the Effort Sharing Regulation (ESR). The ESR and energy efficiency policies are strongly interconnected. National energy efficiency policy measures put in place…

Consultation response

Deutscher Naturschutzring, Dachverband der deutschen Natur-, Tier- und Umweltschutzverbände (DNR) e.V., 25 Nov 2020

Keep ESR and retain nationally binding targets for the majority of GHG emissions Member States will take no responsibility for achieving emission reductions in current non-ETS sectors if they are removed from national obligations under the ESR, undermining the adoption and strengthening of…

Consultation response

European Biodiesel Board, 26 Nov 2020

With more than 11 million tonnes of biodiesel produced per year, the EU is the world leader in the production and use of biodiesel for transport. Biodiesel constitutes a significant European renewable energy source, and the main European solution to reduce emissions from transport and dependence on…

Consultation response

Landwirtschaftskammer Österreich, 8 Nov 2021

Die Land- und Forstwirtschaft als Hauptbetroffene der Klimaverschlechterung sieht es als dringend notwendig an, umfassende Klimaschutzmaßnahmen zur Erreichung des 1,5° C Ziels einzuleiten und unterstützt daher grundsätzlich die Vorschläge der EK zur angestrebten Verstärkung der Emissionsminderung…

Consultation response

Landwirtschaftskammer Österreich, 26 Nov 2020

Ich verweise auf die gesamte Stellungnahme im Anhang, welche alle dzt offenen Politikbereiche betrifft und auch allgemeine Grundsatzüberlegungen beinhaltet. Zur Überarbeitung der Lastenteilungs-Verordnung Wir sprechen uns hier für die Option 2 aus, welche eine Beibehaltung des derzeitigen…

Consultation response

European Insulation Manufacturers Association, 26 Nov 2020

Eurima believes that the current structure of Europe’s climate policy - composed by a GHG emissions reduction target setting the ambition and two instruments for its achievement, namely the EU ETS Directive and the Effort Sharing Regulation (ESR) - should be maintained. Focusing on the building…

Consultation response

The European Association for the Promotion of Cogeneration, 26 Nov 2020

COGEN Europe welcomes the opportunity to comment on the Effort Sharing Regulation (ESR) Impact Assessment consultation. The ESR has been one of the instruments to deliver the decarbonisation of the building sector, along with the energy efficiency directive, ecodesign/energy labeliing, EPBD and…

Consultation response

FEAD, 8 Nov 2021

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As an introductory remark, FEAD highlights that the waste management…

Consultation response

The EU Vegetable Oil and Proteinmeal Industry, 26 Nov 2020

FEDIOL acknowledges the EU carbon neutrality objective by 2050 and the associated need to increase its emissions reduction target by 2030. This ambition must be translated into concrete and practical actions to ensure an effective, sustainable and successful decarbonisation of the European economy,…

Polish Electricity Association demands fair effort sharing for non-ETS sectors

Polish Electricity Association, 26 Nov 2020

The organization calls for keeping the current scope while ensuring new climate burdens do not fall on sectors already in the carbon market. They advocate for national-level targets that reflect different economic capabilities and maintain existing flexibility rules.
This protects the energy industry from higher carbon prices and increased compliance costs.
Environmental goals may suffer if non-ETS sectors like transport and buildings fail to reduce emissions.

Consultation response

FEAD, 26 Nov 2020

FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. Waste management causes a significant…

Consultation response

European Federation of National Associations of Water Services, 26 Nov 2020

EurEau is the European federation of water services representing drinking water and waste water operators in Europe. We support the initiative of the European Commission to set the EU on a sustainable path to achieve climate neutrality by 2050 and the EU-wide, economy-wide net greenhouse gas…

Consultation response

VIER PFOTEN International, 2 Nov 2021

VIER PFOTEN/ FOUR PAWS International welcomes the opportunity to provide feedback on Commission's proposal on the Effort Sharing Regulation. Please find a more detailed answer in the attachment.

Consultation response

UNION FRANCAISE DE L'ELECTRICITE - UFE, 26 Nov 2020

UFE welcomes and supports the EC’s initiative to review the Effort Sharing Regulation (ESR) to align it with the new 2030 and 2050 climate targets of the EU. Although it is of the utmost importance to ensure that all sectors are subject to a meaningful CO2 price signal or CO2 standard regulation,…

Consultation response

Statkraft AS, 8 Nov 2021

Statkraft input to the public consultation for the updating of the Effort Sharing Regulation (ESR) Statkraft is Europe’s largest provider of renewable energy. We have for long been a vocal supporter of a strong EU Emissions Trading System (ETS) as the most efficient tool for driving the…

Czech Industry urges EU to avoid carbon regulation overlaps

Svaz průmyslu a dopravy ČR, 26 Nov 2020

The Confederation prefers maintaining only sectors not covered by the Emissions Trading System within the regulation. They argue that creating an overlap between these two systems would lead to confusion.
The organization seeks to avoid regulatory complexity and ensure transparency regarding how emission targets are calculated.

Consultation response

European Producers Union of Renewable Ethanol, 30 Sept 2021

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and…

Consultation response

European Producers Union of Renewable Ethanol, 20 Nov 2020

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, supports the Commission’s proposal to increase the 2030 EU GHG emissions reduction target to 55% compared to 1990, as an intermediate step to reach climate neutrality by 2050. Achieving the higher…

Consultation response

Österreichs E-Wirtschaft, 8 Nov 2021

With regard to the proposed revision of the Effort Sharing Regulation (ESR), Oesterreichs Energie welcomes the fact that the sectors covered by the ETS are not solely obliged to reduce greenhouse gas emissions. This would place an uneven and disproportionate (additional) burden on these…

Consultation response

Confederation of European Waste-to-Energy Plants, 26 Nov 2020

CEWEP, the Confederation of European Waste-to-Energy Plants, welcomes the initiative of updating the EU Effort Sharing Regulation (ESR) and the review of the national emissions reduction targets based on a higher climate ambition for 2030. We fully support the principle that all sectors will need…

Consultation response

Réseau Action Climat France, 26 Nov 2020

Le Réseau Action Climat France regrette que la Commission n'ait pas inclus l'option de maintenir l'architecture climatique actuelle en augmentant à la fois l'ambition du marché carbone européen (ETS) et des secteurs du partage de l’effort (ESR). Bien qu’un prix du CO2 soit un outil important dans…

Consultation response

Fornybar Norge (Renewables Norway), 3 Nov 2021

Dear Commission, Please find Energy Norway's feedback on the ESR proposal attached. Energy Norway is an association that represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting and trading electricity. Our members produce 130-140 TWh…

Consultation response

Suomen luonnonsuojeluliitto - The Finnish Association for Nature Conservation, 26 Nov 2020

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental non-governmental organization in Finland. We would like to make the following points about EU Effort Sharing Regulation (ESR) review Emissions in the EU must be cut at least 65 %…

Consultation response

Fornybar Norge (Renewables Norway), 25 Nov 2020

Energy Norway would like to thank the Commission for the opportunity to provide feedback on the roadmap inception impact assessment for the EU Emissions Trading System (Directive 2003/87/EC). Energy Norway represents the whole electricity chain in Norway. In other words, our members include…

Consultation response

Verband der Deutschen Biokraftstoffindustrie, 8 Nov 2021

Please find attached our comments on the initiative.

Consultation response

IFIEC Europe, 26 Nov 2020

IFIEC welcomes the opportunity to participate in the consultation on the review of the National Emissions Reduction Targets by Member States, the so-called Effort Sharing Regulation (ESR).  This regulation covers all greenhouse gas emissions which are not covered by the EU Emissions Trading System…

Consultation response

Hospodářská komora České republiky, 8 Nov 2021

Připomínky zasíláme v příloze.

Consultation response

Citizens' Climate Europe, 26 Nov 2020

Citizens’ Climate Europe welcomes the EU’s increased climate ambition and recognises the need for review of the EU’s climate policies, including the ESR. We support the boldness of rethinking the whole architecture of the EU’s climate policies, so that they match increased ambition and are future…

Consultation response

Stadtwerke München GmbH, 25 Nov 2020

Bei der Überarbeitung der aktuellen Lastenteilungsverordnung gilt es unbedingt eine Doppelregulierung auf europäischer und nationaler Ebene zu vermeiden. Deshalb ist die vorgeschlagenen Option 2, also eine Beibehaltung des aktuellen Rahmens der Lasteinteilungsverordnung bei gleichzeitiger…

EURACOAL demands fairer emissions burden across economic sectors

European Association for Coal and Lignite, 3 Nov 2021

The coal industry argues the current proposal for emission reductions is unbalanced between industrial and non-industrial sectors. They call for a fairer distribution of the heavy burden to meet climate targets. Additionally, they demand a detailed impact assessment on social and economic consequences for member states.
A balanced distribution would lower the heavy emission reduction requirements placed on the coal industry.
Households and drivers would face higher costs if non-industrial sectors faced tougher emission targets.

EURACOAL warns against carbon price hikes to protect coal power

European Association for Coal and Lignite, 26 Nov 2020

EURACOAL requests that the emissions trading system remains the sole climate instrument. They argue member states must remain free to retain their coal assets.
Maintaining current rules prevents further bankruptcies and protects the viability of coal producers.
Transport and building sectors would lose their lighter regulatory burden under these proposals.

Consultation response

St1 Nordic Oy, 26 Nov 2020

St1 Nordic Oy welcomes the initiative to review the ESR regulation. As climate change is a global challenge. the solution should be designed in a flexible manner to avoid sub-optimization. The ongoing review of the ERS, ETS, and LULUCF should be conducted as a tightly interlinked and coherent…

Consultation response

The Voice of Europe's Independent Energy and Mobility Suppliers, 26 Nov 2020

Context Independent fuel suppliers have experienced a substantial impact on their business activities, as COVID-19 outbreak hit harshly fuels demand across Europe. This unprecedented challenge represents a pivotal opportunity to reshape the energy sector as we know it. To achieve this goal, an…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 25 Nov 2020

Manter em vigor a ESR e as metas vinculativas nacionais para a maioria dos GEE Os Estados-Membros não assumirão reduções das emissões nos actuais sectores não abrangidos pelo ETS se estas forem eliminadas das obrigações nacionais ao abrigo da ESR, prejudicando a adopção e o reforço de medidas…

Consultation response

Equilibre des Energies, 25 Nov 2020

Association EdEn believes that the Effort-Sharing Regulation (ESR) should be maintained in the sectors that are not covered by the emission trading scheme (Option 3 in the inception impact assessment). We also believe the ESR should introduce a sectoral domestic emission reductions target in the…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 8 Nov 2021

Please find attached FNADE's contribution.

Consultation response

Stockholm Exergi, 7 Nov 2021

Make Negative emissions an explicit part of Fit for 55 already now With the urgency to build a completely new industry for negative emissions where the commitment of governments to engage in this task must be ensured without delay, negative emissions should already now become part of the Fit for…

Consultation response

Sandbag Climate Campaign, 26 Nov 2020

The Effort Sharing Regulation (ESR) must be updated to bring national emission reduction targets in line with the 2050 climate neutrality target and the 2030 target of at least 55% emission reductions compared to 1990 levels. The Inception Impact Assessment proposes some rather dramatic changes to…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 26 Nov 2020

Please find here attached FNADE's feedback on National emissions reduction targets (Effort Sharing Regulation) – review based on 2030 climate target plan.

Consultation response

Cia - Agricoltori italiani, 8 Nov 2021

Cia – Agricoltori italiani welcomes the opportunity to provide a feedback to the Commission's Proposal to amend Regulation (EU) 2018/842. Cia is one of the largest agricultural organisations in Europe and it represents more than 900, 000 full members in Italy: farmers and agricultural business…

Consultation response

European Lime Association, 26 Nov 2020

EuLA acknowledges the publication of the European Commission (EC) roadmap for the potential revision of the ESR to be aligned with a GHGs emission reduction target of at least 55% of 1990 levels by 2030. Through the upcoming assessment, we call the EC to consider the impact, not only for ESR…

Consultation response

European Federation of Intelligent Energy Efficiency Services, 8 Nov 2021

EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities.…

Consultation response

European Federation of Intelligent Energy Efficiency Services, 26 Nov 2020

EFIEES, the EU Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in…

Consultation response

Bioenergia ry - Bioenergy Association of Finland, 8 Nov 2021

The Bioenergy Association of Finland welcomes the Commission proposal to revise the Effort Sharing Decision (ESR) as part of the Fit-for-55 package. While the EU ETS is the most important single instrument the European Climate Law, the ESR has an important role in reducing greenhouse gas emissions…

Consultation response

Bioenergia ry - Bioenergy Association of Finland, 26 Nov 2020

The Bioenergy Association of Finland supports a well-prepared transition towards EU’s climate neutrality by 2050. Climate change is a transboundary problem, where coordinated EU action can supplement and reinforce national and local action efficiently. We note that the revision of the Effort…

Consultation response

European Union for Responsible Incineration and Treatment of Special Waste, 26 Nov 2020

Eurits is an association of hazardous waste management companies across the EU. Its membership represents over 90% of the hazardous waste incineration sector in the EU and includes some of the world’s largest waste management companies. Eurits fully supports the ongoing actions towards climate…

Consultation response

Hazardous Waste Europe, 23 Nov 2020

Hazardous Waste Europe (HWE) is a European wide association whose members operate all the diversity of hazardous waste treatments from recycling to final disposal including dedicated hazardous waste incineration. HWE recognizes and endorses the urgent necessity to bring more efforts for achieving…

Consultation response

Clean Air Action Group (Levegő Munkacsoport), 26 Nov 2020

ESR versus ETS The idea to put the land transport’s fuel to the ETS system is not expedient. This measure could not mitigate the fuel consumption, but neither the increase of it. The Handbook on the external costs of transport Version 2019 – 1.1 (…

Consultation response

Republiková únia zamestnávateľov, 25 Nov 2020

We don’t agree with extension of emissions trading to all fossil fuels combustion and related emissions. Our arguments are following: - Increased costs resulting from the administrative complexity of the ETS will be borne by the final consumers in the form of the increased bills for living; - The…

Consultation response

Holding Slovenske elektrarne d.o.o., 11 Oct 2021

HSE Group notes that, unfortunately, the proposal lacks fairer distribution of burden sharing among sectors. The non-ETS sectors are responsible for almost 60% of the total emissions in the EU, but the target for reducing emissions in these sectors by 2030 at EU level will increase from 30% to…

Consultation response

CITTADINI PER L'ARIA, 25 Nov 2020

The missing “Option zero”, maintaining the existing climate architecture, strengthening the ESR Cittadini per l'aria regrets that the Commission did not include the option of maintaining the current architecture by raising both the ambition of the ETS and the ESR. The ESR is efficient…

Consultation response

Helen, 11 Oct 2021

Helen Ltd. thanks the European Commission for the opportunity to give feedback on regulation of the European Parliament and the Council amending Regulation (EU) 2018/842 on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing to climate action to meet…

Consultation response

Focus Association for Sustainable Development, 26 Nov 2020

Existing climate architecture should be kept, ESR strengtened If Member states would not have obligations to achieve emissions reductions under ESR, the adoption and strengthening of additional and complementary measures would be undermined. ESR has incentivized climate action at national and EU…

Consultation response

Nouveau Point De Vue (N.P.D.V.), 8 Nov 2021

les pays sont prêts à tout mettre en œuvre sur le plan des objectifs ultimes à atteindre . mais se rendent compte qu'il faut conjuguer politique , ODD ,et l'économie dans l'état actuel de la coopération sur le but a atteindre, la politique s’efforce de réaliser un certain degré de suffisance…

Consultation response

Český plynárenský svaz, 29 Oct 2021

• CGA considers maintaining Effort Sharing Regulation (EU) 2018/842 as a positive step by the European Commission in light of the revision of the 2030 climate & energy framework. Sectors covered by this Regulation (e.g. the buildings sector) do not respond dynamically to market-driven price signals…

Consultation response

, 26 Nov 2020

Naar aanleiding van de inception impact assessment van de Europese Commissie in voorbereiding op een mogelijke herziening van verordening (EU) 2018/842 “betreffende bindende jaarlijkse broeikasgasemissiereducties door de lidstaten van 2021 tot en met 2030 teneinde bij te dragen aan…

Consultation response

Federação Agrícola dos Açores / Agricultural Federation of the Azores, 26 Nov 2020

Sobre os objetivos em consulta a Federação Agrícola dos Açores entende que: -É muito importante que a União Europeia mantenha a liderança no combate à intensificação das alterações climáticas; - Que uma revisão da legislação é necessária para melhor regular a redução da emissão dos GEE, tendo em…

Consultation response

, 25 Nov 2020

VIK welcomes the opportunity to participate in the consultation on the review of the National Emissions Reduction Targets by Member States, the so-called Effort Sharing Regulation (ESR). This regulation covers all greenhouse gas emissions which are not covered by the EU Emissions Trading System…

Consultation response

Association for District Heating of the Czech Republic, 24 Nov 2020

Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment of Regulation (EU) 2018/842 on binding annual greenhouse gas reductions by Member States from 2021 to 2030 contributing to climate action to meet…

Consultation response

Český plynárenský svaz, 20 Nov 2020

The Czech Gas Association (hereinafter CGA) is an independent association of companies and experts operating in the gas and related industries. It brings together organizations active in the gas industry, along with research and scientific institutes, and further comprises experts whose…