Fondazione Think Tank ECCO ETS
ECCO
La Fondazione ECCO think tank, ente del Terzo Settore senza fini di lucro, opera nell’ambito della tutela ambientale e delle politiche climatiche.
ID: 698596749014-90
Lobbying Activity
Meeting with Elisabetta Gualmini (Member of the European Parliament)
9 Dec 2025 · Emission Trading System (ETS)
Meeting with Benedetta Scuderi (Member of the European Parliament)
26 Nov 2025 · Industry and Energy
Meeting with Nicola Zingaretti (Member of the European Parliament)
25 Nov 2025 · climate change and decarbonisation
Meeting with Antonella Sberna (Member of the European Parliament)
20 Nov 2025 · Scambio di opinioni sulla ransizione energetica e sullo sviluppo nel Mediterraneo
Meeting with Giorgio Gori (Member of the European Parliament)
13 Nov 2025 · ETS I and II, energy prices
Response to Circular Economy Act
5 Nov 2025
Boosting circularity in Europe is essential to strengthen the EUs economic security, competitiveness and climate leadership. Greater circularity can reduce resource dependency and costs, boost innovation and deliver up to a quarter of the emission reductions needed for climate neutrality, creating quality jobs and enhancing industrial resilience. To achieve this, the CEA should act on two complementary levers: Creating strong demand for circular materials. The CEA should use public procurement and targeted incentives to boost market demand for low-carbon, recycled and bio-based materials, turning circular products into the competitive standard for public procurement across Europe; Developing an integrated single market that enables circularity across value chains, supported by harmonised rules, digital traceability, mutual recognition of shared standards for identifying green products and reinforced by ecodesign measures that make products more repairable, recyclable, and durable. ECCOs position focuses primarily on construction materials (such as cement and steel) and plastics, both essential for achieving industrial decarbonisation and resource efficiency in Europe. The production of these materials originates from hard-to-abate industries, characterised by highly emission-intensive processes, which greenhouse gas emissions are particularly difficult to mitigate. A key lever to reduce the climate impact of these sectors lies in decreasing demand for virgin materials, by enhancing circular innovation through recycling, reuse and material efficiency. Several systemic barriers still hinder the transition to circularity. The EU market for secondary raw materials remains fragmented due to heterogeneous national waste and product legislation, preventing economies of scale. The price gap between primary and secondary materials persists because environmental externalities are not fully internalised and therefore do not always fall on producers of materials from virgin sources. Circular products remain costlier, while limited access to finance and slow permitting further constrain innovation, particularly for SMEs. There is also limited demand for recycled or bio-based materials, stemming from the prevalence of lowest-price procurement practices, a lack of harmonised standards and insufficient digital traceability. To address these barriers, ECCO recommends that the Circular Economy Act: 1. Creates strong demand for circular materials by introducing EU-wide minimum requirements for circular products through public procurement criteria, especially for high-volume sectors such as construction and plastics. 2. Incentives such as tax reliefs or subsidies for materials processed and recycled within the EU, supporting partnerships throughout the value chain. To bridge the price gap between primary and secondary materials, incentives should support value-chain partnerships that secure stable supply, demand and pricing for recycled inputs. 3. Shift from lowest-price to value-for-money awarding in public tenders, with carbon intensity performance, that builds upon EU ETS metholdogies incrementally, as well as circularity of the production as combined award criteria. In the iron and steel industry, in order to keep the incentive for shifting towards less carbon intensive production processes, dedicated awards should be guaranteed, rewarding actual investments in line with the climate neutrality plans, where relevant, or transition plans which are in the permitting phase. 4. Harmonise rules and develop interoperable standards for secondary raw materials, including end-of-waste criteria, certification schemes and digital traceability. 5. Support defossilisation of the plastics industry by promoting sustainable bio-based and recycled feedstocks, setting minimum bio-based and recycled content in key applications like construction and aligning incentives with long-term industrial transition goals.
Read full responseResponse to Revision of the CO2 emission standards for cars and vans
10 Oct 2025
The European Regulation on CO2 Emissions for Passenger Cars and Light Commercial Vehicles constitutes the main pillar of the European Unions climate and industrial policies in the automotive sector. It has historically provided a clear and credible trajectory, enabling the industry and the entire electric mobility value chain to plan investments and organize an orderly transition towards zero-emission vehicles. While it is appropriate to continuously monitor progress and consider the introduction of flexibility mechanisms that take into account the challenges faced by certain manufacturers, any amendment that weakens the regulations innovative drive would risk undermining the progress achieved in recent years. Postponing the targets set for 2030 or 2035 would interrupt the sectors innovation trajectory, erode investor confidence, and benefit global competitors. Maintaining the current objectives is therefore essential to safeguard ongoing investments, support the large-scale deployment of electric vehicles, and ensure a just transition, making electric mobility accessible to all European citizens, including through the development of affordable small electric cars. From the consumers perspective, emission standards contribute to improving vehicle energy efficiency, thereby mitigating the risks associated with rising fuel prices expected from the introduction of carbon pricing mechanisms such as the ETS-2. In this context, any delay or weakening of the regulation would result in direct economic losses and restrict access to affordable electric mobility solutions. When assessing additional compliance flexibility mechanisms for car manufacturers, a clear guiding principle must apply: flexibility should not become a loophole that undermines the achievement of essential emission reductions. Instead, it must be implemented with robust safeguards to ensure steady and predictable progress toward climate objectives. If regulators consider introducing new forms of compliance flexibility, mechanisms such as banking and borrowing could be explored, provided that their design does not compromise the environmental integrity of the CO2 fleet standards. Banking and borrowing allows manufacturers to anticipate or postpone part of their fleet-wide CO2 reduction progress. This instrument can help prevent disruptions in the transition process for instance, in cases where electric vehicle sales are delayed pending new targets, or where derogations are requested for compliance years for which manufacturers are not yet prepared. To preserve environmental integrity, however, banking and borrowing mechanisms must not be combined with the current CO2 target trajectory, as this would result in the generation of unintended windfall emission credits. Instead, credits within a potential banking and borrowing system should be created only in relation to a continuously declining CO target trajectory, thereby ensuring full alignment with the overall decarbonisation pathway. In the absence of such safeguards, flexibility mechanisms risk undermining both the integrity and the credibility of the regulatory framework. It is also essential to keep the regulation of vehicles separate from that of fuels. Biofuels and e-fuels cannot be scaled up sustainably. Biofuels derived from food crops pose serious environmental and climate risks, while genuinely sustainable biomass resources should be reserved for the hardest-to-decarbonize sectors. Moreover, biofuels supply chains are highly vulnerable to fraud and low-cost imports. In this respect, mechanisms such as the carbon correction factor or fuel credits are unreliable and therefore unsuitable for vehicle regulation. Similarly, the use of LCA as a regulatory tool for individual vehicles would not be effective: the complexity of data across the entire value chain would generate a significant administrative burden, leading to operational inefficiencies and inconsistencies in the application of standards.
Read full responseMeeting with Cristina Guarda (Member of the European Parliament)
9 Oct 2025 · Omnibus
Response to Heating and cooling strategy
8 Oct 2025
Accelerating the electrification of Europe's economy is crucial to strengthen the continents energy security, ensure competitiveness of its industries, and meet the social needs of its citizens. The Heating & Cooling Strategy should deliver a coherent policy framework that empowers consumers and businesses to benefit economically from cleaner, efficient technologies. To achieve this, the Strategy should: Set a clear long-term vision for electrification, with explicit sectoral targets and indicators integrated into NECPs; Address both investment and operating costs of electrified solutions to ensure competitiveness; Reform electricity price structures (supply, networks, and taxation) through a renewed subsidiarity pact between the Commission and Member States, to alleviate operating costs and ensure fair, transparent pricing that reflects electricity's strategic value; Strengthen EU-wide coordination, with minimum standards where appropriate, sharing best practices among Member States, and ensuring vertical alignment between national and EU levels. Technologies to electrify key sectors exist, yet structural barriers persist (see attached), chiefly (1) a taxation system making electricity more expensive than fossil fuels, and (2) absence of a coherent policy framework addressing economic, technical and financial barriers to electrification. (1) In Italy, energy taxation does not reflect the energy and CO2 content, environmental performance, or contribution to energy security of carriers. Fiscal (excise, VAT) and parafiscal (system charges, ETS) components weigh more heavily on electricity than on fossil fuels-up to three times more in domestic and transport sectors, and up to eight times more in industrial and commercial uses. SMEs, which are easier to decarbonise, are highly penalised. This imbalance distorts price signals, undermines electric technologies, and acts as an implicit subsidy to fossil fuels. Rebalancing taxation is essential. The revision of the Energy Taxation Directive should ensure excise duties reflect each carriers environmental impact and contribution to energy security. Parafiscal levies concentrated on electricity should be redistributed across all carriers or progressively integrated into general taxation. The Commission should publish its energy taxation recommendations as foreseen in the Affordable Energy Action Plan and enhance its monitoring of national fiscal alignment with electrification goals, via the European Semester. The timely implementation of ETS2 and the SCF is key to strengthen carbon price signals and support households and SMEs in adopting efficient electric solutions. Guidance on national carbon price corridors could enhance revenue predictability and social fairness. (2) A coherent policy framework should create enabling conditions by addressing: Economic barriers: Accelerated renewables deployment at competitive prices, using de-risking tools such as Italy Energy Release mechanism; Consumer access to savings from cheaper renewable generation, including by decoupling electricity and gas prices; Creation of lead markets for decarbonised products via tax incentives and green public procurement. Technical barriers: Expansion and modernisation of electricity grids to meet rising demand and connection needs without high costs for consumers; Improving consumers cooperation schemes, e.g. energy communities or industrial clusters. Financial barriers: A comprehensive financial strategy (European Competitiveness Fund, ETS revenues, State aid) to help households and businesses understand and finance electrification, from project design to implementation (including energy diagnostics); Knowledge barriers: Integrating training, upskilling and re-skilling of workforce in financing programmes; Creating knowledge 'Catalysts', i.e.., knowledge clusters (such as ESCOs for industry) enhancing training and education programmes; Dedicated R&D funding schemes to enable technologies where gaps remain.
Read full responseResponse to Electrification Action Plan
8 Oct 2025
Accelerating the electrification of Europes economy is crucial to strengthen the continents energy security, ensure competitiveness of its industries, and meet the social needs of its citizens. The Electrification Action Plan should deliver a coherent policy framework that empowers consumers and businesses to benefit economically from cleaner, efficient technologies. To achieve this, the Plan should: Set a clear long-term vision for electrification, with explicit sectoral targets and indicators integrated into NECPs; Address both investment and operating costs of electrified solutions to ensure competitiveness; Reform electricity price structures (supply, networks, and taxation) through a renewed subsidiarity pact between the Commission and Member States, to alleviate operating costs and ensure fair, transparent pricing that reflects electricitys strategic value; Strengthen EU-wide coordination, with minimum standards where appropriate, sharing best practices among Member States, and ensuring vertical alignment between national and EU levels. Technologies to electrify key sectors exist, yet structural barriers persist (see attached), chiefly (1) a taxation system making electricity more expensive than fossil fuels, and (2) absence of a coherent policy framework addressing economic, technical and financial barriers to electrification. (1) In Italy, energy taxation does not reflect the energy and CO content, environmental performance, or contribution to energy security of carriers. Fiscal (excise, VAT) and parafiscal (system charges, ETS) components weigh more heavily on electricity than on fossil fuelsup to three times more in domestic and transport sectors, and up to eight times more in industrial and commercial uses. SMEs, which are easier to decarbonise, are highly penalised. This imbalance distorts price signals, undermines electric technologies, and acts as an implicit subsidy to fossil fuels. Rebalancing taxation is essential. The revision of the Energy Taxation Directive should ensure excise duties reflect each carriers environmental impact and contribution to energy security. Parafiscal levies concentrated on electricity should be redistributed across all carriers or progressively integrated into general taxation. The Commission should publish its energy taxation recommendations as foreseen in the Affordable Energy Action Plan and enhance its monitoring of national fiscal alignment with electrification goals, via the European Semester. The timely implementation of ETS2 and the SCF is key to strengthen carbon price signals and support households and SMEs in adopting efficient electric solutions. Guidance on national carbon price corridors could enhance revenue predictability and social fairness. (2) A coherent policy framework should create enabling conditions by addressing: Economic barriers: Accelerated renewables deployment at competitive prices, using de-risking tools such as Italys Energy Release mechanism; Consumer access to savings from cheaper renewable generation, including by decoupling electricity and gas prices; Creation of lead markets for decarbonised products via tax incentives and green public procurement. Technical barriers: Expansion and modernisation of electricity grids to meet rising demand and connection needs without high costs for consumers; Improving consumers cooperation schemes, e.g. energy communities or industrial clusters. Financial barriers: A comprehensive financial strategy (European Competitiveness Fund, ETS revenues, State aid) to help households and businesses understand and finance electrification, from project design to implementation (including energy diagnostics); Knowledge barriers: Integrating training, upskilling and re-skilling of workforce in financing programmes; Creating knowledge 'Catalysts', i.e.., knowledge clusters (such as ESCOs for industry) enhancing training and education programmes; Dedicated R&D funding schemes to enable technologies where gaps remain.
Read full responseResponse to EU vision for enhancing global climate and energy transition
11 Sept 2025
Starting from COP30, the EU can redesign its energy and climate diplomacy to fit the strategic goal of building fair and reciprocal partnerships, as underlined by SOTEU 2025. ECCO suggests three lines of action: 1. Laying Foundations at COP30 for Climate Mitigation, Finance and Adaptation Strategic Signals: COP30 must convey three key messages: progress on climate action has been made, global cooperation continues, and there is recognition of being off-track for the 1.5°C goal with plans to intensify emission cuts and adaptation. The NDCs will be critical in assessing this. Leaders-level coalitions: After COP30, the EU should leverage leader-level coalitions, COP30 decisions, and contributions from non-state actors via the Action Agenda to keep on discussing a response to NDCs and gaps to Paris goals. Climate Finance Reforms: The Baku to Belém Roadmap presents an opportunity to establish a robust framework targeting $1.3 trillion by 2035. The EU should push for clear milestones, transparency and defined pathways for implementation maximizing grants, concessional finance, and non-debt instruments for debt-distressed nations. Sustainable Finance: At COP30, the EU should draw on its leadership to promote international finance reform, championing mechanisms to provide finance at sustainable costs. Key levers include MDB reforms and MDB-NDB collaboration. Global Climate Governance Reform: the EU should support strengthening UNFCCCs role in global climate cooperation. The EU needs to focus on quality of finance, ensuring it is affordable and accessible without unsustainable debt burdens for developing countries. Adaptation Cooperation Reset: As climate impacts escalate, the EU should lead a political reset on adaptation, with COP30s decision on Global Goal on Adaptation as a signal commitment to resilience and scaled finance. 2. Building an EU Industry and Energy Foreign Policy Through Fair and Reciprocal Partnerships China Strategy: The EU should pursue selective cooperation with China in areas of mutual benefit renewables, battery recycling, efficiency standards, and methane abatement. Technical dialogue on Chinas emissions trading system and joint adaptation finance support offer constructive paths. US Energy Relations: The EU should reassess its energy relationship with the US in light of its commitment to transition away from fossil fuels. New LNG imports pose risks to existing supplier relationships and EU energy security. Transparent Energy Demand Scenarios: The EU should clearly communicate its future energy demand to help partners develop resilient economies. Independent demand scenarios aligned with EU climate goals should be developed. Just Transition Diplomacy: The EU should support fossil fuel producers just transition, starting with its main suppliers like Algeria, with the BOGA partnership as a framework for cooperation. 3. Renewables and CRMs as Cornerstones of EU Diplomacy Towards Mediterranean and African Partners Mediterranean Clean Energy Cooperation: Building on COP28s global renewables target, the EU should support the TeraMed goal of 1TW renewable capacity by 2030. This can drive investment, enhance energy security, and contribute to a Mediterranean clean energy area. Middle East Reconstruction: Renewables should be central to reconstruction efforts in the Middle East. The EU should back the Peace Triangle initiative (Israel, Palestine, Jordan) under IMEC, promoting green projects for regional stability and development. CRM Diplomacy and Clean Trade: The EU must embed CRM diplomacy in Clean Trade and Investment Partnerships and align CRM agreements with partner development goals, fostering sustainable value chains and governance. Strategic Benefits: CRM diplomacy can support Africas industrial growth while advancing EU economic, foreign policy, and security interests, and strengthening its global partnership model.
Read full responseMeeting with Brando Benifei (Member of the European Parliament)
23 Jun 2025 · Omnibus package (CSRD and CSDDD)
Meeting with Brando Benifei (Member of the European Parliament)
21 May 2025 · Omnibus package (CSRD and CSDDD)
Meeting with Pierfrancesco Maran (Member of the European Parliament) and A2A and
4 Apr 2025 · Public procurement
Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and FoodServiceEurope
27 Mar 2025 · Evaluation of the Public Procurement Directives
Meeting with Alessandra Sgobbi (Head of Unit Climate Action)
26 Mar 2025 · Learnings from the Italian National Recovery and Resilience Plan (NRRP) to inform the MFF
Meeting with Giorgio Gori (Member of the European Parliament)
20 Mar 2025 · overview of activities
Meeting with Irene Tinagli (Member of the European Parliament) and Fédération Européenne d'Associations Nationales Travaillant avec les Sans-Abri
17 Mar 2025 · Introductory meeting
Meeting with Cristina Guarda (Member of the European Parliament)
5 Feb 2025 · renewables
Meeting with Annalisa Corrado (Member of the European Parliament)
11 Dec 2024 · Climate Action
Meeting with Pasquale Tridico (Member of the European Parliament)
1 Oct 2024 · Meeting with ECCO Think Thank