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HELLENIC UNION OF INDUSTRIAL CONSUMERS OF ENERGY

UNICEN

UNICEN represents Greek industries for which energy is a significant proportion of production costs and therefore a key factor of competitiveness at international level .

Lobbying Activity

Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

The Hellenic Union of Industrial Consumers of Energy «UNICEN» is a non-profit consumer association established in 2011 under Greek Law, based in Athens, Greece. UNICEN is registered in the EU transparency register, under id. no. 836745216685-46. UNICEN represents energy intensive industries in Greece, with an electro-intensity more than 20%, for which energy is a significant proportion of production costs and therefore a key factor of competitiveness at international level. UNICEN's membership represents a diverse set of energy-intensive industrial sectors, including steel, non-ferrous metals (aluminium, copper), cement, paper, fertilizers, glass, textiles, industrial gases, chemicals and other. UNICEN hereby submits a study (attached) which shows that the average regional (Greece, Bulgaria and Romania) CO factor over 20222024 is estimated at 0.81 tCO/MWh over the last three years. Where bidding zones are market-coupled and exhibit sustained price convergence, the Commission uses a single regional CO factor rather than separate national onese.g., Nordic (SE+FI), Iberia (ES+PT), Baltic (LT+LV+EE), CWE (AT+DE+LU), Adriatic (HR+SI), CZSK. In these cases, the factor is computed for the whole zone as a weighted average of fossil emissions over fossil generation. Greece, Bulgaria, and Romania function as a single, coupled market (SDAC/SIDC) in practice, with wholesale prices co-moving and any residual spreads driven primarily by interconnector saturation rather than domestic grid constraintshence a single regional factor better reflects the shared marginal price-setting reality of the zone In 2024, the GreeceBulgaria border exhibited 80% day-ahead price convergence specifically during hours when fossil generation set the market price, indicating that carbon-cost pass-through is effectively common across the coupled area in the periods that matter for the factor.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Greek Association of Renewable Electricity Producers

27 Apr 2023 · Energy transition; Other participants: DEPA; DAPEEP; Hellenic Association of Independent Power Companies; DESFA; Hellenic Association of PV Energy Producers; Centre for RES and Savings; Hellenic Energy Exchange; IPTO

Meeting with Dominique Ristori (Director-General Energy)

15 Dec 2017 · Energy market Design

Meeting with Miguel Arias Cañete (Commissioner)

25 Jul 2016 · Greek Energy Market