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ASOCIACIÓN DE NAVIEROS ESPAÑOLES - SPANISH SHIPOWNERS ASSOCIATION

ANAVE

ANAVE is a business organisation of national scope, constituted for the coordination, representation, management, promotion and defense of the Spanish shipping companies' interests.

Lobbying Activity

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

We welcome the opportunity to contribute to the European Commissions review of the EU ETS as applied to maritime transport. We attach a document outlining Spanish Shipowners Associations (ANAVE) main positions. In summary, we respectfully highlight the following five key points: 1. A global regulatory framework: The EU should fully align with the IMOs forthcoming Net Zero Framework (NZF). Parallel systems would create legal uncertainty, administrative burdens and distortions, particularly affecting SMEs and short sea shipping. 2. IMO as the appropriate forum for raising ambition: Any further climate ambition, such as extending the scope to vessels below 5,000 GT, should be discussed and adopted exclusively within the IMO, to ensure global coherence and avoid disproportionate impacts on smaller operators. 3. Full reinvestment of ETS revenues in the maritime sector: Revenues generated from maritime ETS should be entirely reinvested through dedicated calls to support fleet renewal, energy efficiency improvements and the uptake of alternative fuels. 4. Preventing carbon leakage: The revision should address emerging signs of carbon leakage, including modal shifts to road transport, avoidance of EU ports, and inefficient fleet allocation, issues that only a global framework can adequately resolve. 5. Careful consideration of domestic and island shipping: If cabotage trades are to contribute to decarbonisation goals, this must be done by applying IMO-aligned rules, accounting for the specific needs of island (including Ceuta and Melilla) and outermost regions, and avoiding counterproductive modal shifts. We trust these considerations will help build a more effective and globally coordinated decarbonisation framework for maritime transport.
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Meeting with Rosa Serrano Sierra (Member of the European Parliament)

19 Mar 2025 · EU Maritime Transport