EuroChem Group AG

EuroChem

We make fertilizers.

Lobbying Activity

Response to Updating the EU Emissions Trading System

25 Nov 2020

I. Introduction: The EuroChem Group (https://www.eurochemgroup.com) is a vertically integrated and leading international manufacturer of mineral fertilizers. EuroChem operates numerous fertilizer production, distribution, logistics and research facilities throughout Europe, Americas, Asia, Russia and the CIS. We are employing more than 28.500 people all of them fully committed to help farmers worldwide to improve crop yield and quality in a sustainable and environmentally friendly manner. EuroChem Antwerp (https://www.werkenbijeurochem.be) in Belgium has been part of EuroChem since 1 April 2012 producing more than 2.2 million tons of fertilizers. The unique location of EuroChem Antwerp at the port is an important link and hub for the entire company in terms of both logistics and production. Lifosa AB (https://www.lifosa.com) is one of the largest and most modern fertilizer manufacturers in Europe. From the end of 2004, the shares of Lifosa AB are controlled by the EuroChem. The company is situated in Kėdainiai in Lithuania and employs more than 1.000 highly committed people producing over 1 million tons of fertilizers annually. We mainly produce phosphate fertilizers for soil enrichment and fertility. II. Summary of key political recommendations: We ask for the continuation of sufficient allowances under ETS IV to secure the competitiveness of our European production sites Lifosa and EuroChem Antwerp. These allowances do not prevent us from investing into abatement technologies and developing CO2 off-setting schemes across the food supply chain. We fear that urgently needed funding to secure the transition towards energy neutral production will simply not be available to support all businesses, especially in the fertilizer industry. The same concerns exist with regards to our need to have access to low carbon energy what is indispensable for the fertilizer industry’s decarbonization efforts. We have drastically reduced our N2O emissions in the last few years, but technological limits of current technologies on energy efficiency in ammonia production in Europe and worldwide have been reached. When it comes to the abatement potential of the fertilizer industry, we contest the outcome of an assessment drafted by a consortium of consultancies for DG CLIMA indicating an emission reduction of 4.9 Mt CO2 and an abatement potential of 41% (!) for the fertilizer industry. To our knowledge, the EU fertilizer industry has not even been consulted or asked by this consortium to provide scientific input before these figures have been presented. Only with unrealistically high costs emission reductions could be “achieved” with the current best available techniques. In our view, it is intolerable to be exposed to such a policy style where the European Commission uses “Commission-friendly” agencies to introduce and impose its climate policies and laws on (EU) businesses. The European Commission should further promote carbon capture and use and storage technologies (CCU, CCS) where fertilizer companies should be able to generate CO2 credits as a result of their carbon sink. In the manufacturing of ammonia, carbon dioxide is produced as a co-product. The fertilizer industry uses this carbon dioxide for the production of calcium ammonium nitrate (CAN) . This should be further applied for other industrial activities that target at permanently storing carbon. Our recommendations are supported by the ruling of the European Court of Justice on the Schaefer Kalk case . Furthermore, the CCU rules should make sure and clarify that only those companies should benefit from allowances that are actually abating CO2 emissions (and not those companies whose CO2 is abated by third companies). Finally, our more detailed contribution is attached.
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