Federation of Egyptian Industries - Environmental Compliance Office
ECO SD
The Environmental Compliance Office & Sustainable Development (FEI / ECOSD) was established at FEI as an independent centre of excellence for Sustainable Development and Energy Efficiency striving to support enterprises in Egypt and other Arab countries in achieving environmental compliance combined with financial benefits.
ID: 698731952334-54
Lobbying Activity
Response to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)
24 Sept 2025
Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the opportunity to respond to the CBAM Call for Evidence and welcome the EUs efforts to address carbon leakage. However, we urge the Commission to address the following points: 1- Using a high default values punishes efficient manufacturers and removes any incentive to invest in green technology and unfairly groups non EU manufacturers with the worst performers by Having a philosophy that if an importer or non EU manufacturer can not prove his emissions , he will be treated as the least efficient EU producer; for example most of Egyptian fertilizer companies operate under European technology, particularly through ThyssenKrupp licenses, which is high efficient. so, if in case a company fails to report actual data, it gets penalized indirectly by using default values based on emissions of the lowest efficient EU producers. Accordingly, the system should incentivize using actual emission data and {Default values should be used only when reliable data is unavailable, and they should be tiered to reflect regional or sectoral best practices, not EU worst-case averages}. 2- Verification through EU-accredited verifiers creates costly and redundant bureaucratic hurdles; emissions reports verified under internationally accepted standards (ISO 14064, GHG Protocol) should be recognized, additionally considering mutual recognition agreements with third-country verification bodies would reduce duplication and lower compliance costs. 3- Manufacturers of complex products could face challenging requirements to account for emissions of every minor input or precursor, accordingly, sitting a De Minimis Threshold to exempt minor components with certain % composition could be excluded the calculation of embedded emission reporting and calculation. 4- Using national average grid emission factors ignores investments in renewable energy and regional variations; Producers report their specific electricity emission factor, supported by evidence not limited to Power Purchase Agreements (PPAs) for renewables and direct physical connection, but also to provide evidence through Renewable energy certificates (I-RECs, GOs). 5- For hydrogen produced as a byproduct from chlor-alkali industries, using a Molar Allocation approach could negatively affect the attractiveness of chlor-alkali hydrogen as a feedstock for ammonia/fertilizers under CBAM compared to hydrogen produced from SMR. 6- Emission Benchmark: The sectoral reference standards (Benchmarks) for CO2 emission values per ton of product have not been issued yet, accordingly companies are unable to make informed procurement decisions, and to assess the cost associated. 7- For the fertilizers sector, The lack of a clear EU benchmark for Urea emissions complicates compliance cost calculations and pricing strategies. 8- In the Cement Industry, emission factor of RDF is almost the same as the emission factor of coal. Given the social and health benefits associated with the utilization of RDF as energy source in the cement industry instead of being subject to landfilling or open burning {A more holistic, life-cycle assessment (LCA) approach reveals a different picture}, incentivized emission factor for RDF should be considered. 9- Maintain the bubble approach in the definitive phase same as the transition phase to reduce administrative, compliance, and associated verification obligation.
Read full responseResponse to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out
24 Sept 2025
Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the opportunity to respond to the CBAM Call for Evidence and welcome the EUs efforts to address carbon leakage. However, we urge the Commission to address the following points: 1- Using a high default values punishes efficient manufacturers and removes any incentive to invest in green technology and unfairly groups non EU manufacturers with the worst performers by Having a philosophy that if an importer or non EU manufacturer can not prove his emissions , he will be treated as the least efficient EU producer; for example most of Egyptian fertilizer companies operate under European technology, particularly through ThyssenKrupp licenses, which is high efficient. so, if in case a company fails to report actual data, it gets penalized indirectly by using default values based on emissions of the lowest efficient EU producers. Accordingly, the system should incentivize using actual emission data and {Default values should be used only when reliable data is unavailable, and they should be tiered to reflect regional or sectoral best practices, not EU worst-case averages}. 2- Verification through EU-accredited verifiers creates costly and redundant bureaucratic hurdles; emissions reports verified under internationally accepted standards (ISO 14064, GHG Protocol) should be recognized, additionally considering mutual recognition agreements with third-country verification bodies would reduce duplication and lower compliance costs. 3- Manufacturers of complex products could face challenging requirements to account for emissions of every minor input or precursor, accordingly, sitting a De Minimis Threshold to exempt minor components with certain % composition could be excluded the calculation of embedded emission reporting and calculation. 4- Using national average grid emission factors ignores investments in renewable energy and regional variations; Producers report their specific electricity emission factor, supported by evidence not limited to Power Purchase Agreements (PPAs) for renewables and direct physical connection, but also to provide evidence through Renewable energy certificates (I-RECs, GOs). 5- For hydrogen produced as a byproduct from chlor-alkali industries, using a Molar Allocation approach could negatively affect the attractiveness of chlor-alkali hydrogen as a feedstock for ammonia/fertilizers under CBAM compared to hydrogen produced from SMR. 6- Emission Benchmark: The sectoral reference standards (Benchmarks) for CO2 emission values per ton of product have not been issued yet, accordingly companies are unable to make informed procurement decisions, and to assess the cost associated. 7- For the fertilizers sector, The lack of a clear EU benchmark for Urea emissions complicates compliance cost calculations and pricing strategies. 8- In the Cement Industry, emission factor of RDF is almost the same as the emission factor of coal. Given the social and health benefits associated with the utilization of RDF as energy source in the cement industry instead of being subject to landfilling or open burning {A more holistic, life-cycle assessment (LCA) approach reveals a different picture}, incentivized emission factor for RDF should be considered. 9- Maintain the bubble approach in the definitive phase same as the transition phase to reduce administrative, compliance, and associated verification obligation.
Read full responseResponse to Carbon border adjustment mechanism (CBAM) methodology for the definitive period
24 Sept 2025
Subject: Response to Call for Evidence on CBAM Emission Methodology, Free Allocation Adjustment, and Carbon Price in Third Countries - Federation of Egyptian Industries Position. The Federation of Egyptian Industries (FEI), representing over 104,000 enterprises and 5 million workers, appreciate the opportunity to respond to the CBAM Call for Evidence and welcome the EUs efforts to address carbon leakage. However, we urge the Commission to address the following points: 1- Using a high default values punishes efficient manufacturers and removes any incentive to invest in green technology and unfairly groups non EU manufacturers with the worst performers by Having a philosophy that if an importer or non EU manufacturer can not prove his emissions , he will be treated as the least efficient EU producer; for example most of Egyptian fertilizer companies operate under European technology, particularly through ThyssenKrupp licenses, which is high efficient. so, if in case a company fails to report actual data, it gets penalized indirectly by using default values based on emissions of the lowest efficient EU producers. Accordingly, the system should incentivize using actual emission data and {Default values should be used only when reliable data is unavailable, and they should be tiered to reflect regional or sectoral best practices, not EU worst-case averages}. 2- Verification through EU-accredited verifiers creates costly and redundant bureaucratic hurdles; emissions reports verified under internationally accepted standards (ISO 14064, GHG Protocol) should be recognized, additionally considering mutual recognition agreements with third-country verification bodies would reduce duplication and lower compliance costs. 3- Manufacturers of complex products could face challenging requirements to account for emissions of every minor input or precursor, accordingly, sitting a De Minimis Threshold to exempt minor components with certain % composition could be excluded the calculation of embedded emission reporting and calculation. 4- Using national average grid emission factors ignores investments in renewable energy and regional variations; Producers report their specific electricity emission factor, supported by evidence not limited to Power Purchase Agreements (PPAs) for renewables and direct physical connection, but also to provide evidence through Renewable energy certificates (I-RECs, GOs). 5- For hydrogen produced as a byproduct from chlor-alkali industries, using a Molar Allocation approach could negatively affect the attractiveness of chlor-alkali hydrogen as a feedstock for ammonia/fertilizers under CBAM compared to hydrogen produced from SMR. 6- Emission Benchmark: The sectoral reference standards (Benchmarks) for CO2 emission values per ton of product have not been issued yet, accordingly companies are unable to make informed procurement decisions, and to assess the cost associated. 7- For the fertilizers sector, The lack of a clear EU benchmark for Urea emissions complicates compliance cost calculations and pricing strategies. 8- In the Cement Industry, emission factor of RDF is almost the same as the emission factor of coal. Given the social and health benefits associated with the utilization of RDF as energy source in the cement industry instead of being subject to landfilling or open burning {A more holistic, life-cycle assessment (LCA) approach reveals a different picture}, incentivized emission factor for RDF should be considered. 9- Maintain the bubble approach in the definitive phase same as the transition phase to reduce administrative, compliance, and associated verification obligation.
Read full response