Focus Association for Sustainable Development
Focus
Focus Association for Sustainable Development is an independent, non-governmental, non-profit and apolitical association of individuals.
ID: 98048278485-29
Lobbying Activity
Response to Clean corporate vehicles
8 Sept 2025
Boost BEV demand: Corporate fleets represent a significant portion of new vehicle registrations and can drive market growth for BEVs. Create a market for second-hand BEVs: after a lifespan of roughly 3-5 years, corporate cars will enter the second-hand market. Electrifying corporate fleets presents a significant opportunity to create a large influx of affordable second-hand BEVs, ensuring greater access to clean mobility for European citizens. Accelerate the ICE phase-out: This legislation will be a key measure to support the planned phase-out of internal combustion engine (ICE) vehicles.
Read full responseMeeting with Franc Bogovič (Member of the European Parliament)
19 May 2022 · Meeting on CO2 emission standards for new cars and vans regulation
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 level. The targets have been - and will continue to be - an important driver for domestic investment in infrastructures such as charging, low emission zones and building renovation. They have led to ambitious taxation reform in some countries. At EU level Member states have supported regulatory measures (e.g. CO2 standards) to more easily achieve their national objective. Therefore, nationally binding targets need to be maintained and increased in order to contribute to collective overall emission reductions of at least 65%. An alternative option to set economy-wide nationally binding targets per member state towards climate neutrality is missing.
ESR reform should contribute to increasing climate ambition
To align European climate action with the Paris Agreement objective of keeping global temperature rise to 1.5°C above pre-industrial levels overall emission cuts of at least 65% for EU are required. In order to deliver the necessary emission reductions in a socially fair and cost-effective manner, a holistic and comprehensive approach towards the entire policy architecture is needed.
Emissions from transport and buildings should not be part of ETS
FOCUS does not support the inclusion of emissions from road transport and buildings into the EU ETS. Fossil fuel combustion emissions in these sectors have much higher abatement costs than the current ETS carbon price level, particularly in the road transport sector (and increased fuel price would hit the low-income population the most). Also, carbon pricing alone will be insufficient to address key non-market barriers to deploying clean energy solutions at scale in the transport and building sectors. For example, for buildings, these barriers include the lack of tailored advice for renovations that makes it difficult for citizens to act. The Commission’s own analysis shows that simply shifting these emissions into the ETS achieves less emission reductions in these sectors than the consideration of more regulatory policy options such as increased modal shift, infrastructure development, traffic management systems and emission standards.
No offsets from LULUCF, EU ETS
Under the current ESR member states can use loopholes that allow them to cover gaps in actual emission reductions for achieving their 2030 ESR targets, for example by using offsets from the land use sector or surplus allowances from the EU ETS. FOCUS calls for rejecting the possibility for countries to use offsets from the land use sector or surplus allowances from the EU Emissions Trading System (ETS) to reduce efforts in the non-ETS sectors.
Read full responseResponse to Climate Law
6 Feb 2020
Countries agreed in Paris to limit the increase in temperature to 1.5°C. However with current 2030 reduction pledges, we are set on a pathway towards 3-3.2°C increase in temperature. The new European Commission has promised to place the fight against climate change at the centre of its political agenda for the next 5 years with its European Green Deal and one of most important instruments- the European Climate Law, to be drafted within 100 days in office.
Focus Association for Sustainable Development fully support the concept of a European Climate Law. Including climate neutrality net zero and 2030 targets within the law is a clear necessity but Focus also sees this Law as an instrument to work together towards achieving climate neutrality by 2050. If the climate law is to achieve the goals we have set it must include:
- A five year review mechanism for EU climate and energy targets buildling on the common framework of the Governance Regulation.
- Independent scientific advisory and monitoring body to scrutinise the EU’s targets, and its plans and policies to tackle the climate emergency.
- Climate policy coherence (mainstreaming of climate policy), including best available reductions of GHG emissions in all major emissions sectors and upon a search for the most effective competence distribution between the EU and Member States.
- Binding phase out dates for ending all exploration and use of fossil fuels and a ban on all subsidies, tax breaks, advertising and other benefits for fossil fuels like coal, oil and gas.
- Alignment of public and private financing with 1.5°C pathway.
- A binding climate neutrality date of 2040, and an enhanced 2030 target of 65% GHG emissions reduction, recognising the constraints of the remaining carbon budget.
- An obligation for meaningful public participation both in reduction pathway and trarget development and further policy design.
- An EU-wide 'natural carbon sinks' policy that aligns climate objectives with protecting and restoring natural sinks and provides the right signals for restoring, conserving, enhancing and managing natural carbon sinks.
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