OpenLobby.EU
Explore

EUROALLIAGES

Euroalliages represents European ferro-alloys and silicon producers.

Lobbying Activity

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

14 Nov 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Raphaël Glucksmann (Member of the European Parliament)

1 Oct 2025 · Safeguards on Alloys

Ferro-alloy industry urges stricter carbon accounting for EU imports

25 Sept 2025
Topic — EU consultation on methodologies for calculating embedded emissions in imported CBAM goods.
Message — Apply national default values based on the most carbon-intensive installations to prevent circumvention. Emissions should be attributed to entire manufacturing sites to avoid selective reporting of low-carbon inputs. The option for non-EU producers to use individual power purchase agreements should be removed.123
Why — This protects European producers by preventing foreign competitors from claiming unfairly low carbon footprints.4
Impact — Efficient non-EU exporters lose the advantage of using specific green energy contracts for imports.5
Read full response

Euroalliages demands strict audits of foreign carbon price claims

25 Sept 2025
Topic — Rules for deducting carbon prices paid abroad from EU border tax obligations.
Message — The association requests public access to emissions reports to monitor foreign carbon price claims. They propose using audited accounts to prove that carbon taxes were effectively paid abroad. They also demand that any state subsidies be deducted from the reported carbon price.123
Why — This prevents foreign competitors from gaining an unfair advantage through hidden state subsidies.4
Impact — Exporters from planned economies would lose the cost advantage provided by indirect state support.5
Read full response

Meeting with Vicente Hurtado Roa (Head of Unit Taxation and Customs Union) and European Chemical Industry Council and

19 Sept 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and ERAMET and

11 Sept 2025 · The situation of the ferroalloys industry in the EU

Euroalliages Urges Full ETS Compensation to Protect Industry Viability

5 Sept 2025
Topic — Technical updates to EU guidelines for compensating electro-intensive users for indirect carbon costs.
Message — Euroalliages requests full implementation of current compensation and the inclusion of auxiliary power consumption in benchmarks. They also propose removing degressive factors that fail to reflect thermodynamic production limits.123
Why — This would protect the sector's financial viability against soaring carbon and electricity prices.4
Impact — Newly eligible industrial sectors risk receiving lower aid if existing industries prioritize their shares.5
Read full response

Euroalliages warns chemical import rules threaten strategic metal production

11 Aug 2025
Topic — Revision of EU rules governing the international trade of hazardous chemicals.
Message — Euroalliages requests exemptions for coal tar pitch when used as an intermediate. They propose aligning import decisions with existing chemical safety regulations like REACH.12
Why — Maintaining current import permissions preserves the industry's ability to operate electric furnaces.3
Impact — Strategic industries like defense and renewables face production risks and delays.4
Read full response

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and

6 May 2025 · EU’s steel industry

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and European Chemical Industry Council and

14 Mar 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

The European Association for Ferro-Alloys and Silicon, Euroalliages, welcomes the European Commission's swift adoption of implementation and delegated acts for the Net-Zero Industry Act and appreciates the opportunity for industry to provide feedback. Ferro-alloys and silicon are essential raw materials in low-carbon value chains, as they enhance the properties of steel and aluminiumparticularly in casting, strength, wear, and corrosion resistance. Steel and aluminium, essential for nearly all net-zero technologiesincluding wind turbines, solar panels, electric vehicles, hydrogen infrastructure, and electricity gridsare unusable without ferro-alloys and silicon. These materials play a strategic role in reducing CO2 emissions both in Europe and worldwide. While we acknowledge that the Annex list is non-exhaustive, we believe that the significant role of ferro-alloys and silicon in the green transition should be explicitly recognized. The list should include ferro-alloys and silicon as both primarily used components and specific main components. Both materials meet the definition of processed materials under Article 3 of the regulation and should not be required to undergo an additional external process to benefit from the provisions of the Act. Therefore, we call on the European Commission to classify ferro-alloys and silicon as processed materials in the implementation and delegated acts. More is detailed in the attached position paper.
Read full response

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

The European Association for Ferro-Alloys and Silicon, Euroalliages, welcomes the European Commission's swift adoption of implementation and delegated acts for the Net-Zero Industry Act and appreciates the opportunity for industry to provide feedback. Ferro-alloys and silicon are essential raw materials in low-carbon value chains, as they enhance the properties of steel and aluminiumparticularly in casting, strength, wear, and corrosion resistance. Steel and aluminium, essential for nearly all net-zero technologiesincluding wind turbines, solar panels, electric vehicles, hydrogen infrastructure, and electricity gridsare unusable without ferro-alloys and silicon. These materials play a strategic role in reducing CO2 emissions both in Europe and worldwide. While we acknowledge that the Annex list is non-exhaustive, we believe that the significant role of ferro-alloys and silicon in the green transition should be explicitly recognized. The list should include ferro-alloys and silicon as both primarily used components and specific main components. Both materials meet the definition of processed materials under Article 3 of the regulation and should not be required to undergo an additional external process to benefit from the provisions of the Act. Therefore, we call on the European Commission to classify ferro-alloys and silicon as processed materials in the implementation and delegated acts. More is detailed in the attached position paper.
Read full response

Meeting with Maria Elena Scoppio (Director Taxation and Customs Union) and

17 Jan 2025 · Discussions on technical issues concerning the design and implementation of the Carbon Border Adjustment Mechanism (CBAM)

Euroalliages urges EU to stop penalizing green process improvements

9 Jan 2025
Topic — Updating EU ETS rules for adjusting free emission allowances during production changes.
Message — Euroalliages requests that companies reducing process emissions through green technologies keep their free pollution permits. They want the rules to recognize carbon capture and biocarbon use as valid emission reductions.12
Why — This would allow producers to lower emissions without facing a costly reduction in free permits.3
Impact — Companies that have already started decarbonizing lose out if the rules favor later adopters.4
Read full response

Meeting with Maroš Šefčovič (Commissioner) and

2 Dec 2024 · Steel value making chain and the role of ferroalloys in European defense industry

Response to European Defence Industry Programme

4 Jun 2024

Please find attached the reply of Euroalliages, the European Association representing the ferroalloys and silicon manufacturers
Read full response

Meeting with Adam Romanowski (Cabinet of Vice-President Maroš Šefčovič), Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

7 Mar 2024 · Energy

Euroalliages urges EU to keep free carbon emission allowances

29 Dec 2023
Topic — The European Commission is updating rules for free carbon emission allowance allocations.
Message — The association requests maintaining current levels of free pollution permits. They also propose excluding crisis years from calculations of past activity. Finally, they call for realistic timelines for complying with energy efficiency rules.123
Why — Maintaining higher levels of free permits avoids financial losses and protects European production.45
Read full response

Euroalliages Urges Strict Enforcement of Carbon Border Reporting Rules

11 Jul 2023
Topic — Consultation on reporting obligations during the transitional period of the Carbon Border Adjustment Mechanism.
Message — Euroalliages demands that reporting rules strictly mirror EU standards to ensure equal treatment. They argue for mandatory data checks and call for an end to flexibility for importers.123
Why — Stricter enforcement would prevent unfair competition and protect the industry's carbon leakage safeguards.45
Impact — Foreign producers lose the ability to use flexible monitoring systems that provide a competitive advantage.6
Read full response

Meeting with Tom Vandenkendelaere (Member of the European Parliament) and Umicore and

10 May 2023 · Critical raw materials act

Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find attached our position paper.
Read full response

Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and The European Steel Association and

7 Jun 2021 · Carbon Border Adjustment Mechanism

Meeting with Thierry Breton (Commissioner) and

7 Jun 2021 · Pact for skills: re/upskilling needs for a successful green and digital transition in the energy intensive industries ecosystem

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Any proposal to revise the current Energy Efficiency Directive (EED) should be based on solid evidence and relevant measures for sectors that are struggling to identify energy efficiency gains. The ferro-alloys and silicon sector support an exhaustive assessment (fitness check) of the current framework to overcome non-regulatory barriers, market failures and weaknesses that may arise in the aftermath of COVID-19 crisis. As electro-intensive sector, the ferro-alloys and silicon industry bears electricity costs which are 30 % of its production cost or even more, which de facto incentivise the sector to become as energy efficient as possible. The fierce and unfair competition from third countries (i.e. China) have become another driver to make our technology as efficient as possible. For instance, the cumulated investment in energy efficiency in silicon and silicon alloys has amounted to €350 million since 2005, which is a substantial amount for our sector. Further investments are foreseen for the 2020-2030 period (R&D, energy efficiency and other investment), reaching several hundred million of euros. Another example of these efforts is the recent installation of an ORC (Organic Rankine Cycle) to transform waste heat into electricity. We recall the European Commission to refrain from proposing any particular binding measures for sectors included in the ETS Phase IV, in particular, those highly exposed to a significant risk of carbon leakage, following the original recital 55 of the Directive 2012/27 on energy efficiency. Current EED offers Member States several options how to improve energy efficiency on a national level. Some Member States have opted for article 7b on alternative policy measures. The use of energy efficiency agreements has proven to be successful. We are convinced that the use of voluntary sectoral measures and schemes for further energy efficiency improvements should be continued. Our industry supports new proposal for public procurement criteria and recovery of heat waste that may provide incentives to invest in innovative energy efficiency projects. We urge the Commission to carefully assess the real need and feasibility of more stringent Energy Efficiency targets in line with the results of the submission of National Energy and Climate Plans. Such assessment is crucial to avoid excessive and unrealistic targets that may create divergent outcomes in different countries. EU Member States should continue to have the possibility to set their own indicative national energy efficiency targets. The European Commission should not forget that any system is governed by the laws of thermodynamic which have a fundamental impact on the way to effectively manage and use energy resources. Capping energy consumption as it is now in the current EED is problematic in several ways. European energy sector is going through a revolution from fossil fuels towards use of carbon free and renewable energy sources. Energy storages with sufficient capacity and response time is needed for balancing variations in energy production and consumption. One option is converting renewable energy to hydrogen and further to various fossil free carbon hydrate fuels (power-to-x, P2X). Due to losses in conversions production of green hydrogen and P2X requires significant amounts of clean electricity. On the other hand, electrification itself offers major GHG emission reduction potential in many other industrial processes and operations as well as in transportation and logistics. Combatting climate change is the top priority not only in Europe but globally. Therefore, reducing GHG emissions is more important than cutting total energy consumption particularly when electricity is produced by using fossil free energy sources. Low carbon electricity will be crucial to the carbon neutral future. Therefore, the energy consumption cap should be removed from the EED.
Read full response

Response to Climate Law

30 Apr 2020

Please see our contribution to the roadmap consultation. In addition, we call for a full and robust ex-ante impact assessment that shows all the scenarios and regulation needed to support such an ambitious acceleration of the decarbonisation with particular consideration to regions, industries and communities highly challenged by the costs of climate change policies. Among the different scenarios, the European Commission should include, at least, one crisis-scenario in which key recession indicators (i.e. lower industrial output, higher unemployment rates, the volatility of the CO2 price, etc.) are introduced in the modelling to reflect the potential economic effects of the on-going COVID-19 sanitary crisis. Please find attached our "2050 VISION for the European Ferro-alloys and Silicon Sector". "Nothing is lost, nothing is created, everything is transformed". Law of mass conservation - Antoine-Laurent de Lavoisier, 1743-1794 The goal is to choose the right transformation...
Read full response

Response to 2030 Climate Target Plan

15 Apr 2020

EUROALLIAGES, the voice of ferro-alloys and silicon producers in Europe, calls for a detailed assessment of the electro-intensive industries that are constantly facing unfair trade practices and increasing carbon leakage pressure due to weaker (or inexistent) climate policies in third countries. We also call for a fair redistribution of efforts and timing for all the sectors that need to further decarbonize (i.e. agriculture, transport, etc). Our industry has been electrifying its processes and improving its performance constantly though energy efficiency programmes. Such efforts should be encouraged and promoted with new policies at EU and national levels. A possible increase of EIIs’ carbon leakage exposure should be assessed alongside the revision of the 2030 climate targets as it is inherently linked to our climate targets. Carbon leakage measures should be commensurate with and effective for the high level of pursued climate ambition As part of key strategic values chains, EUROALLIAGES would also like to express its concern about the on-going COVID-19 crisis and its impacts on the energy and climate policies. European Commission should include, at least, one crisis-scenario in which key recession indicators (i.e. lower industrial output, higher unemployment rates, the volatility of the CO2 price, etc.) are introduced in the modelling to reflect the potential economic effects of the on-going COVID-19 sanitary crisis. Last but not least, EUROALLIAGES would highly recommend the European Commission to present the results of the modelling with all the different scenarios before unveiling a new legislative proposal. We believe that, if new ambitious targets are to be set, a debate with relevant stakeholders should take place before new regulation is adopted.
Read full response

Response to Revision of the Energy Tax Directive

30 Mar 2020

Please find attached our position paper. EUROALLIAGES is ready to cooperate with proposals and data that could enrich European Commission’s impact assessment.
Read full response

Response to Carbon Border Adjustment Mechanism

30 Mar 2020

EUROALLIAGES calls for a serious multi-dimensional assessment that includes not only energy and climate angles but also fundamental aspects of EU’s trade and single market instruments and goals. EUROALLIAGES recommends the following: 1. Any CBAM system that intends to replace or remove the carbon leakage regime featured by the ETS Directive should be disregarded. We invite the European Commission to reflect on scenarios in which CBAM will adequately complement the necessary carbon leakage protection of highly exposed sectors like the one represented by EUROALLIAGES. 2. The upcoming impact assessment should be the starting point of a broader discussion between the EU institutions and all the stakeholders potentially concerned. The debate should not be detached from the New Industrial Strategy and the upcoming Climate Law. 3. The impact assessment should address WTO compliance and the potential interlinks between different CBAMs and EU’s trade defence instruments. 4. While EUROALLIAGES is open to CBAM trials for selected sectors, the European Commission should provide details about the expected impacts for the sectors that will fall outside the scope of the mechanism and, ultimately, explain how these will be protected from higher carbon leakage risk. 5. EUROALLIAGES is ready to contribute with material and data to be assessed as a specific sector that may benefit from a future CBAM. Our members are ready to participate in this exercise provided that confidential or sensitive data is not published and that the results are not considered as an official endorsement of the system. Please find our attached position paper for more.
Read full response

Response to Climate Law

6 Feb 2020

EUROALLIAGES members, ferro-alloys and silicon companies located in Europe, will play a fundamental role in shaping more sustainable value chains (batteries, solar panels, steel and aluminium supply chains) across the continent in the next decades. The transition will take place in a highly competitive and dynamic international environment and massive investments will be needed. As a strategic player in this fundamental transition, our sector has outlined key framework conditions to contribute to it as presented in our recent publication setting our 2050 vision (here attached). These considerations were also featured in the report ‘Metals for a Climate Neutral Europe: a 2050 Blueprint’ of the Vrij Universiteit Brussel- Institute of European Studies. The High-Level Group on Energy-Intensive Industries of which EUROALLIAGES is member, has also developed a Masterplan with recommendations to build the policy framework needed to manage this transition while keeping our industry competitive. These recommendations aim to feed into the future EU Industrial Strategy and the European Green Deal: https://op.europa.eu/en/publication-detail/-/publication/be308ba7-14da-11ea-8c1f-01aa75ed71a1/language-en EUROALLIAGES believes that the Climate Law should first define framework conditions to guarantee low carbon free electricity at competitive prices for electro-intensive industries and its value chains. To be sustainable, the Climate Law should also define a very sharp plan on which sectors and what efforts level will need to contribute throughout the next three decades. Setting a realistic and balanced framework to sectoral contributions to the targets should reconcile the different decarbonisation speeds that sectors have gone through in the so-called ETS sectors against non-ETS ones. The cross-media effects/impact on the environment compartments of objectives and related measures should also be fully assessed. The social dimension such as the costs impact on the final consumers should not be underestimated as roughly a half billion citizens will have the bear at least the foreseen one trillion euros costs envisaged for the transition. These elements should also be properly taken into account in the upcoming Sustainable Finance Regulations. EUROALLIAGES has serious concerns regarding the automatic increase of EU GHG target reduction by at least 50% by 2030. We call for a full and robust ex-ante impact assessment that shows all the scenarios and regulation needed to support such transition with particular consideration to regions, industries and communities highly challenged by the costs of climate change policies. If new targets are justified by evidence-based data, we call the Commission to review the EU Energy Governance to allow Member States, including key industries, to review how to reach those targets in the next decade. Our sector is fully electrified and as such, most of the GHG reduction possibilities are beyond our control. One fundamental aspect the new Climate Law should consider is the link between climate change and external trade policy. As an example, in our sector, the massive state-aid in China to Silicon producers generated huge overcapacities which have a disruptive impact on the silicon world market. Not only this unfair competition is severely threatening the European silicon production, but silicon is also a staggering example of the lack of playing field between competitors worldwide as the last expansion of silicon capacities in China is exclusively based on coal fire power stations. The Climate Law should therefore enact new principles and measurements tools of third countries decarbonisation levels to avoid a severe erosion of European competitiveness. EUROALLIAGES recommends to further integrate the upcoming Industrial Strategy into the Climate Law framework. Setting a level playing field to decarbonise the economy should be extended to the entire economy in a fair and realistic manner.
Read full response

Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

7 Jun 2019

EUROALLIAGES is the association representing European Silicon and ferro-alloys producers. While EUROALLIAGES very much supports the basic principles and objectives pursued by GSP, EUROALLIAGS would like to make the following comments: - Within the overall objectives of the GSP – promotion of sustainable development of developing countries -, there was a common understanding that GSP should focus more on the downstream value chain as a major contributor to growth. Hence only semi-finished and finished products were deemed to enjoy this unilateral preferential tariff regime. - On the basis of those principles, ferro-alloys and silicon were not included in the GSP in the first place, as they were righty considered as raw materials belonging to the upstream value chain. - For unclear reasons, this status changed in 1994 and ferro-alloys were included in the GSP product scope – as very sensitive products - while their intrinsic nature (raw materials for steel) had not changed (and will not change). - It should also be noted that for decades now, the ferro-alloys industry is exposed to fierce competition from countries which are GSP eligible. - Ferro-alloys producers were hence confronted to an extremely odd situation where, simultaneously, a product exported from a country is subject to a trade defence measure while benefiting from the GSP tariff reduction: where is the consistency? - While the GSP mechanism provides for the possibility to upgrade (and downgrade) countries according to the development of their respective imports, EUROALLIAGES holds that whenever a country has been found to dump a certain product (the “product concerned” of an AD investigation) in the EU, this product/country should be automatically excluded from the GSP tariff preference as long as the AD measure remains in force. This position is the only one which would ensure consistency within the EU commercial policy. - Furthermore, recent developments have shown that more and more, third countries – including emerging economies – boost their economy through an array of subsidies, most of them in violation of WTO rules (most of them are not even notified). In the context of this artificial economic growth, no (or not enough) consideration is paid to environment. On the contrary, some countries do not hesitate to build additional coal based capacities, to the detriment of environmental friendly basic principles of manufacturing. - The ferro-alloys industry is then competing with industries which, not only enjoy full governmental support, but also in most instances keep producing without respecting the environment. - Last but not least, these heavily subsidized economies generate overcapacities which constitute an additional factor of severe market disruption. EUROALLIAGES would be happy to provide to the Commission more information about this absence of level playing field. - For all these reasons, EUROALLIAGES is of the opinion that GSP should be kept into force as an instrument to promote developing countries’ export performance but at the same time: o Requests ferro-alloys to be excluded from the product scope as it was initially the case, being raw materials in the steel production process. o Asks to remove from the list of GSP eligible countries/products those which are found to be dumped and/or subsidized on the EU market. o Asks to remove from the list of GSP eligible countries those countries which were found to heavily subsidise their industries (the Commission reports regarding the existence of market distortions in relation to trade defence instruments should already constitute sufficient evidence of that). o Asks that the mere existence of overcapacities for a certain product/country lead to the exclusion of the GSP preference for that product/country. o Insists on the need to be much stricter in the assessment process of the environmental impact of the production processes in the GSP countries.
Read full response

Response to Revision of the ETS State aid Guidelines

17 Jan 2019

Please find EUROALLIAGES' feedback attached.
Read full response

Response to Free allocation of emission allowances

23 Nov 2018

EUROALLIAGES is the European association of ferro-alloys and silicon producers. It represent more than 95% of the sector in the EEA. The European ferro-alloys and silicon industry is highly affected by the EU ETS, both directly and indirectly, and therefore takes great interest in the drafting of the future free allocation rules. EUROALLIAGES' members would like to emphasise the need for the future free allocation rules post-2020 to avoid jeopardising the ability of the sector to invest, especially at a time of major efforts towards low-carbon technologies. In this regard, it should not be forgotten that the European ferro-alloys and silicon sector is strategic in implementing EU decarbonisation strategy as it provides essential materials for major European value chains, for example carbon-free electricity. The ferro-alloys and silicon industry has a long history in Europe and has made important efforts to reduce emissions over the years, bringing it to emissions levels very close to the thermodynamic limits. Several significant changes have been proposed and introduced in the draft free allocation rules for phase 4 compared to phase 3, and this without any impact assessment. EUROALLIAGES' members insist that such modifications have to be thoroughly examined by way of an adequate assessment. This would also give the Climate Change Expert Group the possibility to provide educated advice to the European Commission. EUROALLIAGES' members appreciate the fact that the specificity of sectors with process emissions has been recognised and that, by way of consequence, the allocation factor will remain at the level of 0.97 during EU ETS phase 4. Indeed any reduction of this factor would not make scientific sense and would unfairly penalise process emissions sectors. EUROALLIAGES maintains its comment that the median should be used rather than the arithmetic mean for the calculation of the historical activity level (Article 15.6). The median eliminates years with abnormal output levels, while the mean risks leading to an under-estimation of the actual output, for instance because of maintenance.
Read full response

Meeting with Dominique Ristori (Director-General Energy) and FuelsEurope and

23 Nov 2018 · clean energy transition and decarbonisation

Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

Response to Carbon Leakage List 2021 - 2030

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 directly and indirectly. EUROALLIAGES would like to share its views on the future carbon leakage methodology. I. TRADE INTENSITY Ferro-alloys and Silicon are products that are traded on a global market. The European producers face fierce and often unfair competition. They cannot pass through any cost resulting from EU regulation. EUROALLIAGES considers that the trade intensity element is crucial in determining the risk of carbon leakage and that it must remain thoroughly assessed. It is opposed to the possibility of excluding the trade intensity factor in case of linkages with other emission trading schemes. Such an exclusion would reflect a false image of the actual conditions on the global market and would seriously jeopardise the prevention of the carbon leakage list, which is one of the cornerstones of the EU ETS Directive. In case of linkages with other ETS-like systems, their comparability to the EU ETS must be assessed at the level of the cost impact on the industry, including electricity cost, direct and indirect emissions, as well as State support. II. EMISSION FACTOR FOR ELECTRICITY EUROALLIAGES requests the alignment of the carbon leakage methodology with the wording of the State Aid Guidelines for indirect emissions compensation (SWD(2012) 130 final and SWD(2012) 131 final): the marginal power plant should be taken into account for the emission factor, not the average. The price that the industry actually pays for power in the market is set by the marginal plant. The Inception Impact Assessment document notes at the end of page 2 that “ETS costs constitute a very small share of the total costs”. EUROALLIAGES’ members would like to emphasise the fact that notwithstanding the share of these costs, they represent undue costs as far as they are not supported by our competitors on the global market and lead to investment leakage and potentially to carbon leakage. III. ADDITIONAL COMMENTS ON THE CARBON LEAKAGE ASSESSMENT The new methodology already suggested by the draft EU ETS Directive and to be refined by the European Commission casts a shadow of uncertainty about the carbon leakage status of industrial sectors post-2020. EUROALLIAGES would like to recall the importance of predictability and to call for clarity of the assessment criteria as soon as possible. The European Silicon sector more specifically, which is classified within the heterogeneous NACE code 2013 ‘Manufacture of other inorganic basic chemicals’ deeply regrets the recent evolution of the draft EU ETS Directive towards the impossibility for this sector to be assessed at PRODCOM level, following what it considers a discriminatory approach. Therefore it demands that the qualitative assessment allows to take into account all relevant and sector-specific elements in view of the adequate and thorough evaluation of its risk of carbon leakage. For the European Silicon sector, the impact of dropping off the carbon leakage list could be fatal. EUROALLIAGES calls for the consultation of the sectors concerned by the carbon leakage assessment on the accuracy and adequacy of data collected to this purpose.
Read full response

Response to Evaluation Energy Taxation Directive

26 Sept 2017

EUROALLIAGES' feedback is attached.
Read full response

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen) and European Aluminium AISBL and

18 Jul 2016 · China Market Economy Status

Meeting with Michel Servoz (Director-General Employment, Social Affairs and Inclusion) and The European Steel Association and

2 Dec 2015 · Le statut d’économie de marché de la Chine.

Meeting with Bernd Martenczuk (Cabinet of First Vice-President Frans Timmermans) and The European Steel Association and

17 Sept 2015 · Market economy status for China

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and The European Steel Association and

17 Sept 2015 · Presentation of a study

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

17 Sept 2015 · AEGIS presenting new study on consequences of granting MES to China

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen) and The European Steel Association and

17 Sept 2015 · EU-China trade relations

Meeting with Peteris Ustubs (Cabinet of High Representative / Vice-President Federica Mogherini) and Confederazione Generale dell'Industria Italiana and

3 Sept 2015 · AEGIS Europe and MES China

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

7 Jul 2015 · MES China

Meeting with Miguel Arias Cañete (Commissioner) and

19 Feb 2015 · Competitiviness, Energy Union and ETS review