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IFIEC Europe

IFIEC Europe

IFIEC Europe represents energy-intensive industries across Europe, advocating for affordable energy policies that maintain their global competitiveness while improving efficiency and environmental performance.

Lobbying Activity

IFIEC Europe Urges Strict Transparency for Foreign Carbon Price Credits

25 Sept 2025
Topic — New EU rules for converting foreign carbon prices into CBAM certificates for industrial imports.
Message — The group urges a cautious approach that subtracts rebates and free allowances from foreign carbon prices. They recommend a transparency instrument mirroring the EU ETS to expose hidden subsidies and greenwashing.123
Why — Strict verification ensures European industry is not disadvantaged by subsidized foreign competitors.45
Impact — Non-EU exporters lose if their domestic carbon pricing systems lack transparency or provide subsidies.6
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IFIEC Europe urges stronger safeguards and CBAM export solutions

25 Sept 2025
Topic — Rules for adjusting CBAM certificate obligations during the ETS free allowance phase-out.
Message — The organization calls for maintaining free allowances and indirect carbon cost compensation to prevent industry relocation. They demand the Commission propose a legislative solution for exporters and align CBAM benchmarks with EU ETS methodology.123
Why — These changes would protect the competitiveness of European industrial sectors and reduce relocation risks.45
Impact — European manufacturers lose international market share as free allocations are gradually reduced.6
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IFIEC Europe demands CBAM focus on direct emissions only

25 Sept 2025
Topic — Calculation rules for measuring embedded emissions in products imported into the EU.
Message — The scope should remain on direct emissions to avoid disadvantaging industries currently receiving power cost compensation. Monitoring and verification standards for imports must mirror the robustness of the EU ETS. Default values for importers should reflect the average emissions of the highest-emitting ten percent of producers.123
Why — This protects European industrial competitiveness by preventing double-exposure to unique carbon power costs.45
Impact — Third-country exporters face significant administrative hurdles and strictly controlled trade for their goods.67
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Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

IFIEC Europe rejects 90% 2040 climate target as unrealistic

16 Sept 2025
Topic — Amendment of the European Climate Law to include a 2040 climate target.
Message — IFIEC Europe calls for a climate target aligned with the pace of technological development. They demand targets be conditional on factors like affordable low-carbon energy.123
Why — This approach would protect energy-intensive industries from high compliance costs.45
Impact — Other industrial sectors might suffer if flexible mechanisms shift burdens opaquely.6
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IFIEC Europe Urges Immediate Expansion of Carbon Cost Compensation

5 Sept 2025
Topic — Updates to State aid rules compensating industries for electricity-related carbon costs.
Message — IFIEC Europe requests an immediate update to the list of eligible sectors. They recommend including all industrial sectors at genuine risk of carbon leakage. Additionally, aid intensity should be 100% without any mandatory investment requirements.1234
Why — Industry members would secure increased financial support to offset high electricity prices.5
Impact — Non-European industrial importers would lose their competitive advantage over European manufacturers.6
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Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

5 Sept 2025 · Clean Industrial Deal and the Affordable Energy Action Plan

IFIEC Europe Urges Realistic Transition to Protect Industrial Competitiveness

8 Jul 2025
Topic — Review of the EU Emissions Trading System and Market Stability Reserve framework.
Message — IFIEC Europe requests emergency measures to maintain current free pollution permits and freeze the carbon market reserve. They argue the emission reduction cap should follow a realistic path matching industrial technology development.123
Why — This would lower their carbon costs and protect them from international price competition.45
Impact — Climate advocates and the environment lose as the 2040 decarbonization targets are softened.67
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IFIEC Europe Urges Industrial Say in European Grid Upgrades

8 Jul 2025
Topic — The European Commission is consulting on measures to modernize and expand energy grid infrastructure.
Message — IFIEC demands a legally binding role for energy-intensive industries in grid planning and operations. They also call for incentives for industrial flexibility and maintaining natural gas infrastructure during the transition.12
Why — These changes would reduce immediate costs for manufacturers and ensure infrastructure supports industrial production.34
Impact — Future energy consumers will bear the financial burden of current infrastructure investments and expansions.5
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IFIEC Europe urges tailored sectoral plans for industrial decarbonization

7 Jul 2025
Topic — The consultation addresses accelerating industrial decarbonization while maintaining competitiveness across Europe.
Message — The organization calls for sector-specific action plans developed with industry to address unique technological challenges. They advocate for technology-neutral standards and a voluntary labeling scheme for low-carbon products.123
Why — Tailored support would ensure their massive decarbonization investments remain economically viable and reduce administrative burdens.45
Impact — Public authorities and taxpayers may face higher costs as procurement moves away from lowest-price criteria.6
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

25 Jun 2025 · To discuss the position paper on the Clean Industrial Deal and the Affordable Energy Plan

Meeting with Lukasz Kolinski (Director Energy)

18 Jun 2025 · Clean Industrial Deal/Affordable Energy Action Plan and Energy Infrastructure Forum debrief

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Industrial Energy Users Demand Flexible EU Carbon Allocation Rules

2 Jan 2024
Topic — The European Commission is updating rules for the free allocation of carbon emission allowances.
Message — IFIEC Europe seeks sub-installation level climate plans and an extension to the May 2024 deadline. They also want to maintain existing definitions for fuel benchmarks and de-minimis reporting rules.123
Why — The industry would avoid disproportionate financial penalties and protect sensitive commercial investment strategies.45
Impact — Regulators and the public lose legal mechanisms to enforce corporate climate neutrality commitments.6
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IFIEC Europe demands fairer climate plan rules for industrial installations

30 Aug 2023
Topic — This consultation defines the content and format requirements for mandatory industrial climate-neutrality plans.
Message — The group argues that obligations should apply to specific units rather than entire installations. They also call for extended deadlines and exemptions for facilities closing before 2036.1234
Why — This would prevent companies from losing site-wide free allowances due to one inefficient process.5
Impact — Non-biomass energy users lose out because existing heat benchmarks already factor in biomass usage.6
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IFIEC Europe Urges Technology Neutrality for EU Carbon Management Strategy

30 Aug 2023
Topic — This consultation explores the strategic deployment of carbon capture technologies to decarbonise the European economy.
Message — Industry calls for a framework recognizing carbon removals and allowing certificates to be used for emissions compliance. They advocate for technology neutrality and EU-wide funding for operational and investment costs. The federation suggests market-driven infrastructure development through competitive tendering.123
Why — Subsidies and incentives would reduce costs and protect the international competitiveness of European industry.4
Impact — Fossil-based manufacturers may lose market share to low-carbon alternatives through carbon-linked consumer fees.5
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IFIEC Europe seeks competitiveness safeguards in 2040 climate plan

22 Jun 2023
Topic — This consultation establishes an intermediate climate target for the European Union's 2040 goals.
Message — The group wants a realistic timeline and stronger carbon leakage protection to keep European companies competitive. They support a technology-neutral approach including nuclear power and carbon capture to reduce emissions cost-effectively. They also urge the EU to align its targets with the climate ambitions of other global economies.123
Why — These measures would lower energy costs and preserve financial support for heavy industry.45
Impact — Environmental groups may see progress slowed by continued reliance on removals rather than direct emission cuts.67
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IFIEC Europe Urges Inclusion of Heavy Industry in Net-Zero Act

9 May 2023
Topic — The consultation concerns a proposal to strengthen the European ecosystem for manufacturing net-zero technologies.
Message — The group requests broadening the definition of net-zero technologies to include industrial production processes. They also demand better access to funding and expedited permitting for energy-intensive sectors.12
Why — Energy-intensive companies would secure more funding and faster permits for their own decarbonization projects.34
Impact — Global competitors like the United States lose their competitive edge in attracting green technology investments.5
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IFIEC Europe urges EU to relax renewable hydrogen rules

17 Jun 2022
Topic — The EU is establishing rules for measuring emissions from renewable and recycled fuels.
Message — IFIEC argues for a technology neutral approach including low carbon hydrogen to avoid hampering market development. They request adjustments to allow continuous production and more flexible links to the power grid.123
Why — Relaxed rules would lower production costs and ensure stable hydrogen supplies for industry.4
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IFIEC Europe urges temporary gas storage and fair cost distribution

25 May 2022
Topic — This consultation concerns new EU requirements for mandatory winter gas storage levels.
Message — The organization wants measures to be temporary and subject to regular impact assessments. They argue that industry should not pay for peak gas demand which they do not cause. Finally, they call for protections against gas supply cuts for vital industrial sectors.123
Why — This would safeguard industrial output and minimize additional energy costs for manufacturers.4
Impact — Households and protected consumers could pay more to cover gas storage costs.5
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Response to Revision of EU rules on Gas

12 Apr 2022

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for a Hydrogen and Gas Decarbonisation Package. We agree that renewable and low-carbon gases, including hydrogen, have an important role to play as we move towards a carbon neutral society. Their efficient and sustainable development can only be achieved through well-functioning gas markets and a reliable as well as cost-effective infrastructure. The ongoing situation in Ukraine and related consequences for European security of supply, further emphasize the need for rapid deployment of harmonized rules to ensure Europe moves together towards the common goal of a carbon neutral future, delivering efficient markets and adequate, cost-effective security of energy supplies. In that context IFIEC is happy to take the given opportunity to contribute a number of relevant aspects which will be helpful to facilitate the penetration of such gases, while at the same time safeguarding the competitiveness of European industry. The aim of the legal framework under discussion should and must be decarbonization of the gas system and gas markets in a manner that is as fast, as efficient and as cost effective as possible. The industries represented by IFIEC have already embarked on the journey towards decarbonizing their processes and production and have realized notable GHG emission reductions. The definitions and framework laid down in the EU Hydrogen and Gas Decarbonisation package as well as other relevant legislation, lay the premisses for the continuation of this process. IFIEC therefore stress the importance of the present framework being clear, taking into account the specificities of industrial users as feedstock users and making sure it does not unduly hamper the step wise decarbonisation that needs to take place. For the industries represented by IFIEC it is important to convey three main messages - Definitions matter by setting the stage for the decarbonization journey industries are now navigating. They as such need to be timely and carefully constructed so as to favour necessary step decarbonization investment decisions, rather than hamper them. - Gas quality matters, for natural gas, renewable and low-carbon gases as well as for hydrogen, and must be duly taken into account, both with regards to its diligent management and possible adverse effects on end users - Geographical origin does not matter – ensuring a level-playing field for all low-carbon and renewable gas and hydrogen consumed in the EU, whether imported or produced domestically, is essential for the credibility and efficiency of the present legal framework.
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Response to Revision of EU rules on Gas

12 Apr 2022

IFIEC, representing energy intensive customers, welcomes and in many aspects supports, the European Commission's proposal for a Hydrogen and Gas Decarbonisation Package. We agree that renewable and low-carbon gases, including hydrogen, have an important role to play as we move towards a carbon neutral society. Their efficient and sustainable development can only be achieved through well-functioning gas markets and a reliable as well as cost-effective infrastructure. The ongoing situation in Ukraine and related consequences for European security of supply, further emphasize the need for rapid deployment of harmonized rules to ensure Europe moves together towards the common goal of a carbon neutral future, delivering efficient markets and adequate, cost-effective security of energy supplies. In that context IFIEC is happy to take the given opportunity to contribute a number of relevant aspects which will be helpful to facilitate the penetration of such gases, while at the same time safeguarding the competitiveness of European industry. The aim of the legal framework under discussion should and must be decarbonization of the gas system and gas markets in a manner that is as fast, as efficient and as cost effective as possible. The industries represented by IFIEC have already embarked on the journey towards decarbonizing their processes and production and have realized notable GHG emission reductions. The definitions and framework laid down in the EU Hydrogen and Gas Decarbonisation package as well as other relevant legislation, lay the premisses for the continuation of this process. IFIEC therefore stress the importance of the present framework being clear, taking into account the specificities of industrial users as feedstock users and making sure it does not unduly hamper the step wise decarbonisation that needs to take place. For the industries represented by IFIEC it is important to convey three main messages - Definitions matter by setting the stage for the decarbonization journey industries are now navigating. They as such need to be timely and carefully constructed so as to favour necessary step decarbonization investment decisions, rather than hamper them. - Gas quality matters, for natural gas, renewable and low-carbon gases as well as for hydrogen, and must be duly taken into account, both with regards to its diligent management and possible adverse effects on end users - Geographical origin does not matter – ensuring a level-playing field for all low-carbon and renewable gas and hydrogen consumed in the EU, whether imported or produced domestically, is essential for the credibility and efficiency of the present legal framework.
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Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

IFIEC Europe, representing energy intensive industries (EIIs), welcomes the opportunity to provide feedback on the proposal related to the revision of the Energy Efficiency Directive (EED). IFIEC is concerned by the potential impact of the revision of the EED on industry competitiveness. 1. Avoid capping of energy consumption IFIEC would like to remind that improving energy efficiency should not mean absolute reduction of energy consumption. Energy efficiency must be a reduction of energy consumed per output. Setting absolute caps on energy consumption will lead to a reduction of the production of the European industry, triggering an increase of the imports from third countries with an increase of the European carbon footprint, imported products being usually produced in a less efficient way. To ensure future economic stability and growth, the prescription of absolute targets for energy efficiency should be avoided. Industrial growth is essential for the further development of innovative energy- and resource-effective technologies. In addition, the new low carbon technologies require more energy and could lead to less energy efficiency performance. Reduction targets of greenhouse gas shall prevail on the energy efficiency principle. 2. National energy savings obligations must be achievable and should focus on economic sectors with high untapped potential The annual energy savings between 2024 and 2030 will increase to 1.5% in comparison to the current 0.8%. Efforts to increase energy efficiency and reduce GHG should be expected mainly from sectors that have a high cost-effective potential for energy savings. In this sense, it is important to introduce sector-specific programs for all economic sectors: buildings, transportation and industry. 3. Policy consistency of EED with any other environmental regulation and avoidance of double regulations The revised EED objectives should not come in conflict with the provisions of other related directives such as ETS, RED, or any other environmental regulation. Some of their provisions could have a conflicting impact on the energy efficiency objective, e.g.: • Switching from fossil fuels to renewable fuels does reduce energy efficiency (a biomass-fired boiler has a lower efficiency than a natural gas fired boiler), • Mitigating emissions through for example Capture Carbon and Storage (CCS) increase by 15 to 20 % the energy consumption of the whole production chain, • The increasing share of intermittent renewable energies may require more energy flexibility from large industrial energy consumers, with the consequence that Industrial processes might be not operate with the highest efficient 100 % of the time. • The increase of environmental protection may require new equipment that will reduce the emissions to air or water but will increase energy consumption without any increase of output, so energy efficiency index will increase for a justified reason: environmental protection. As overlap between directives must be avoided and other directives (e.g. ETS) already regulate CO2 emissions, IFIEC recommends removing the CO2 criterion from the definition of high-efficiency CHP as it deals with energy carrier use and not with energy efficiency 4. Specific attention for hydrogen and synfuels production A clear definition of accounting methodologies for renewable electricity, hydrogen, green hydrocarbon products and synfuels, especially clarifying their use for material and energetic purposes, is required. It is also not clear in what way new definitions will affect energy saving obligation schemes and other indicators related to energy efficiency. In this sense, we ask for more detailed and targeted definitions and an impact assessment clarifying the effects in the current EED proposal. It is crucial to ensure that new EED will not result in additional economic disadvantages for businesses.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

IFIEC Europe, representing energy intensive industries (EIIs), welcomes the revision of the ETD that should give industry better visibility on tax framework and enable it to make long-term investment decisions. However, IFIEC is concerned by the impact on industries’ competitiveness which will be created by the general increase of the minimum taxation level and the cancellation of most of the possibilities for exemptions and tax reductions. Both the EC and MS need to commit to a long-term policy framework without hampering competitiveness for business while supporting climate policy objectives. As EIIs need vast amounts of energy at competitive costs for their operations, increased tax rates should go together with CL protection measures in the ETD. The ETD proposal should not hamper competitiveness of energy intensive users: Europe needs a strong and competitive industry enable to develop innovative sustainable technologies and products in order to meet the Green Deal targets. Therefore, revision of the ETD should not create additional and unnecessary tax burdens. The main priorities of the ETD should be implementation of a harmonized taxation framework avoiding distortion of competition within the EU and safeguarding the competitiveness of European industry that competes globally. Sectors exposed to international competition should keep the possibility to benefit from current reduced tax rates or exemptions. The differentiation between business and non-business users as well as the option to allow differentiated rates according to quantitative consumption levels should therefore be kept, and with a clearer definition of EIIs. IFIEC expresses strong objections on the inclusion in the scope of the ETD of “mineralogical processes” and of activities where electricity represents 50% of the cost of the product. IFIEC recommends setting a taxation ceiling for energy intensive consumers to prevent MS introducing additional levies above the tax component to support renewable energy production, which can represent huge financial burden. Industry needs time to be able to invest for low carbon or renewable fuel conversion, and before this any tax increase would make the concerned industrial sites uneconomical to even consider their reconversion. A moratorium on the ETD proposal concerning fossil fuels should therefore be considered. ETD should focus on energy and avoid overlap with other EU legislation: ETD is not meant to be an instrument to reduce greenhouse gas emissions for activities already covered by EU ETS. The combination of energy and environmental taxation criteria in the proposal could lead to double taxation with the ETS. IFIEC has questions on the basis for EC’s proposal to differentiate minimum rates for certain technologies through environmental performance ranking as this does not seem to be based on a common environmental parameter and as will run counter the energy efficiency targets. The lack of separation between energy and environmental taxation in the proposal could lead to double taxation with other carbon pricing. Technology neutrality should be respected as a principle in any environmental ranking, by topping up a base rate on energy content (€/GJ) with an environmental rate reflecting the emission intensity of the fuels used (converted into €/GJ) to be levied on sectors that are not covered by EU ETS. The ETD link with the definition of High-efficiency cogeneration given in the Energy Efficiency Directive EED can only be kept should the CO2 restrictions in article 2 (34) of the EED be removed. Equal treatment between outsourced and internalised activities: The taxation scheme should be independent of the plant setup and should avoid unfair distortion of competition between companies that perform the same activities. In particular outsourced activities, e.g. industrial gases production, should be treated in the same way as if they were internalised.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

IFIEC believes the revision of RED II could help industry decarbonise provided access to abundant, competitive secure and low carbon energy and hydrogen (H2) is assured. Alongside, the revision should further contribute to create the necessary legal certainty for investment in low-carbon and breakthrough technological solutions according to the principle of technology neutrality. IFIEC fully supports an increasing share of RE in the form of electrons (e.g. electricity) or molecules (e.g. biogas, H2, or derivates). However, as the constant energy demand of industry is not expected to decrease, the potential RE production is limited in the EU and solar and wind energy is intermittent, RE alone will not be sufficient. Furthermore, intermittent RE like wind and solar have huge impacts on the stability of the electrical network and thus on the reliability of industrial production. In addition, injection into the gas network of renewable fuels like biogas or green H2 generate significant fluctuations in gas quality delivered to consumers which is likely to disturb the production processes and lower their efficiency. The development of all kinds of RE must be done in a way that does not harm the reliability of the energy supply, which is vital for the proper functioning of industrial activities. Due to technical constraints, electrification is not always possible for decarbonising industrial activities, and where it is possible might not be the most efficient solution. Biomass, biogas, low carbon H2 and other low carbon energy carriers should also be considered. Those fuels should be considered as energy carrier that enable a reduction of emissions in the production of heat or other processes. In particular, biogas should be promoted by recognizing it in the EU ETS scheme with a zero CO2 emission factor, whatever way it is financially supported and regardless of the installation where it is used. It is of the utmost importance that all the pieces of regulation covered by the Green Deal are revised in a consistent manner. IFIEC welcomes the inclusion of RFNBOs in the targets but also recommends including recycled carbon fuels and other low carbon energy carriers in RED targets and to create an adequate framework to allow import of low carbon energy carriers. IFIEC supports the development of Power Purchase Agreements (PPAs) promoting RE as well as the establishment of long-term contracts. Similar mechanism should also be implemented for biofuels like biogas. However, persisting administrative and financial barriers to RES-PPAs for energy-intensive industries should be removed. IFIEC supports the incentives given to waste heat recovery through Article 23 and asks for recognition of conversion of waste heat to power for self-consumption to be an eligible measure. Credible claims of RE consumption are important to ensure correct incentives for consumers and industry and to avoid greenwashing. A holistic approach focussing on the reduction of the GHG intensity of the entire energy system based on the principles of technology neutrality and cost-efficient should be the basis of the RED. IFIEC welcomes the approach in the transport sector, e.g. a target based on GHG intensity, and asks the EC to consider a similar approach for the overall target, e.g. basing it on GHG intensity without sub-targets for specific sectors or energy carriers. The sub-target for H2 consumption is of high concern as it would endanger the competitiveness of the energy intensive industry and hamper future developments of other low carbon H2. As production and consumption of renewable H2 do not necessarily happen in geographically correlated areas, this target will create unequally spread economic and technical disadvantages for industry across Europe and is not in line with a level playing field. Early uptake of renewable H2 must be accompanied by supporting measures (e.g. contracts for difference) on an EU level, especially in those regions with high risks.
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Response to Carbon Border Adjustment Mechanism

17 Nov 2021

The CBAM proposal raises a number of concerns. • Need for integration with the EU ETS revision: the carbon border adjustment mechanism that is intended to protect industry sectors from carbon leakage regarding imports will start after 2025, but the measures envisioned under the EU ETS revision will come into effect by 2023, or even earlier if implemented retroactively. As a consequence, in the period before 2026, CBAM will not be effective on the import side, but at the same time the first measures of the EU ETS reform are already being initiated to achieve the ambitious climate targets. It is therefore vital that both drafts are discussed/negotiated simultaneously as they do affect each other, and that current measures to avoid carbon leakage such as free allocation are continued. • Should a Carbon Border Adjustment Mechanism (CBAM) be introduced, it should include a solution for exports and co-exist with the current system of full benchmark-based free allocation at least until 2030, to provide certainty for low-carbon investments and avoid market distortions. • High complexity and administrative barriers: IFIEC is concerned about the high level of complexity of the CBAM. The determination of “CO2 emissions embedded in goods”, e.g., seems very complex, and places very high demands on data availability and quality. IFIEC recommends that a CBAM system should not be introduced before the outstanding issues and concerns listed below such as export refunds, value chain aspects, circumvention and carbon footprint assessment have been resolved. In particular, the compensation of indirect costs is of vital importance for energy-intensive industries and should be maintained. • Exports: there should be a complete cost exemption for exporters, to offset increased production costs of climate-friendly technologies that disadvantage export into the global market. CO2 avoidance costs must be compensated as well, not only to avoid carbon leakage, but also investment leakage. • Value chain shifts due to CBAM need to be avoided: In order to maintain correct carbon leakage protection for the whole value chain, in which parts might be covered by CBAM and parts need free allocation as measure, existing carbon leakage measures must remain in place for products that are delivered to sectors not covered by the CBAM or destined for export. In short term, to avoid carbon leakage within the whole value chain the current carbon leakage measures for sectors included in the EU ETS need to be maintained. In long term, a carbon border adjustment mechanism may need to cover the entire value chain, from upstream to downstream production, where carbon leakage risk is proven also for the value chain’s sectors that are currently not in the EU ETS. • CBAM circumvention needs to be avoided: The risk of resource shuffling, whereby exporters reduce their climate obligations by crediting low-carbon electricity/utilities to supplies directed to European countries while allocating high-carbon electricity/utilities to the domestic market or other markets with lower climate costs, must be mitigated. The risk of transhipping, where products from a country without a carbon price are routed through a country which has one, so that they appear to come from the second country, will have to be addressed as well. To avoid the risk of transhipping and guarantee a level playing field, carbon pricing systems in third countries must be consistent with and match ambition and pricing levels of the EU ETS. • Correct calculation of embedded emissions is vital: there is currently no existing global agreement on how to determine carbon footprints of products and how to trace emissions through the value chain. As a consequence, the level of necessary bureaucracy as well as the risk of legal confrontation will increase. • WTO compatibility: a CBAM should be within the rules of existing WTO policies and not undermine the existing frameworks and international trade relations,
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Meeting with Kadri Simson (Commissioner) and

14 Oct 2021 · High energy prices and how this is affecting the competitiveness of European companies in the energy intensive sectors.

Response to Restoring sustainable carbon cycles

7 Oct 2021

The climate law requires Europe to reach net zero emissions by 2050, and to aim to achieve negative emissions thereafter. In order to reach these ambitious targets technologies to reduce GHG emissions as well as technologies to remove and utilise CO2 will be required. Industry is currently looking into carbon capture and storage/usage technologies (CCSU). Negative emissions can be achieved thanks to combining bioenergy production with carbon capture and storage (BECCS). However, several barriers are hampering industry in the further development of CCSU. Therefore, IFIEC welcomes the initiative of the EC to create a long-term vision for sustainable carbon cycles. IFIEC asks the EC to consider following elements: - A robust and consistent GHG accounting is necessary Industrial GHG emissions are regulated in the Emissions Trading System (ETS). The ETS contains detailed accounting rules in the Monitoring and Reporting Regulation (MRR). The accounting rules are to a large extend following IPCC guidelines that set consistent rules to ensure all GHG emissions are accounted for once. However, the current MRR does not recognise all avoided GHG emissions in the case of CCU and even lead to possible double counting of emissions during production and in the use phase. It is important to distinguish different types of CCU products: o CCU products where the CO2 remains chemically bound in the use phase o CCU-products were the CO2 will be emitted during use phase Some CCU-products will have multipurpose uses and can fall in both categories. Adaption of the MRR for these two types can be done following two CCU cases already implemented in the MRR precipitated calcium carbonate and urea while safeguarding following principles: - The avoided CO2 emissions should be recognised in the MRR for phase 4 (2021-2030) to adequately support CCU; - All CO2 emission should be accounted for consistently and only once; - innovation support must allow further development of CCSU technologies without restricting criteria. CCU technologies are in still at low TRL stages and require further research and development. It is important at this stage that any criteria that would hamper further development are avoided. For example, in most CCU application H2 will be needed. To accelerate the uptake of H2 and CCU it is important that no extra restrictions are imposed on the origin of hydrogen (similar to electrification were no criteria are imposed on the origin of electricity used in cars). This would lead to even more expensive hydrogen prices and would hamper further developments of H2 and CCU. - Policy framework based on technology neutrality and cost efficiency can fuel further development. It is important that the proposed policy framework does not favour one renewable or low carbon technology or energy carrier (e.g. targets in RED). If negative emissions are the goal in the long term, technologies utilising CO2 or capturing CO2 from atmosphere will be crucial.
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Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

10 Jun 2021 · Roundtable of the Clean Hydrogen Alliance: 3rd meeting of the co-chairs

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

IFIEC asks to consider the following: 1. Competitiveness safeguarding reporting The draft Art. 8 Delegated Act goes will lead to overreporting and proposes a level of granular information that is unnecessary for investors’ decisions whilst requiring companies to provide information to an extent that may harm their competitiveness. We see such a risk especially in not only requiring companies to disclose how and to what extent their activities are ‘Taxonomy-aligned’, but also force them to report about their activities that are ‘Taxonomy- eligible but not aligned’ and ‘not eligible’. Such detailed information was not foreseen in the Taxonomy Regulation. It provides competitors in and outside the EU access to company’s data that will not be reported by Non-EU businesses and therefore may undermine EU competitiveness. Furthermore, companies are requested to disclose their future objectives and targets for their KPIs and their plans to achieve them. This goes beyond what is requested for the CapEx and OpEx plans and the level-1 legislation and should be revised, especially as such reporting will contain commercially sensitive information and requires publishing even business confidential details. 2. Fair feasible implementation timeline Companies´ future obligations will require new reporting processes and structures. But it is extremely challenging to start preparing for complying with the Taxonomy Regulation, as the basis of the corporate disclosure requirements has still not been finalized. The proposed simplifications for the first reporting year are not far-reaching enough and the scope is still not clear and delimited. There is still a high level of uncertainties for both companies and auditors. Given the complex requirements and very short time to prepare and agree on common definitions, we suggest to extend any Taxonomy’s requirement by one year, starting with a phased-in implementation in 2023, given the current expected timeline to have all relevant DAs in Place around mid-2022. 3. Transparent stakeholder-friendly disclosure Annex II of the draft DA includes a detailed template for the corporate report. It does not give any flexibility to the reporting company, adds considerable reporting complexity and potentially discloses sensitive data. The template is complex and granular and does not apply in the same way to financial market participants, bringing up the question of relevance. To reflect sectorial peculiarities, ensure comprehensibility and limit the reporting costs we strongly recommend requiring companies to only report on their Taxonomy-aligned criteria without splitting per environmental objective. Companies may decide to disclose more granular data, but this should be a voluntary decision to be accorded to each undertaking. The draft DA requires 5 year of retrospective information from the first application date (Art. 9-2). Typically, financial statements are required to provide a 1-2 year comparison. A compliant reporting for 5 years back before the implementation is not possible. Even if this was to be implemented progressively, it would entail complex and recurring re-assessment of historical data based on a framework that will continuously update. We therefore suggest accepting ESMA’s recommendation to the Commission to provide a one-year comparability. The draft Art. 8 uses multiple terms that so far have not been defined in the legal framework of the EU or in other reporting standards (e.g. IFRS), leaving substantial room for uncertainty and misinterpretation. In addition, not all references to other standards are clearly traceable and should be thoroughly revised and updated. Amongst others, the definition of CapEx and OpEx should be clarified by referring to International Accounting Standards. 4. Project implementation time The 7-year maximum time limit for activities to become Taxonomy aligned does not reflect projects for transformation efforts with a longer timeframe and should be cancelled.
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Response to Revision of EU rules on Gas

10 Mar 2021

IFIEC position COMBINED EVALUATION ROADMAP/INCEPTION IMPACT ASSESSMENT HYDROGEN AND GAS MARKETS DECARBONISATION PACKAGE IFIEC supports the aim of the Green Deal Strategy to transform the energy markets in a non-disruptive and cost-effective manner. But for the transition of the industry, also cost-efficiency and availability of climate neutral energy carriers at competitive prices are required to avoid carbon leakage. As laid down in the roadmap, gaseous fuels will continue to be used for energy and feedstock applications, keeping their share also in 2050. The principles of the existing regulation for internal natural gas market and transmission network have proved to be working, by and large, helped to establish a competitve market and could therefore be transferred to hydrogen and low carbon gases as well. IFIEC welcomes the ambition of the revision to establish hydrogen infrastructure and hydrogen markets. On the transmission level, IFIEC advocates for dedicated hydrogen grids (either repurposed or new-built) conveying hydrogen in a pure quality, which is needed by some industrial consumers. Existing rights of consumers need to be strengthened and guaranteed. which also applies for gas quality. Eligible customers need a stable gas composition for safe and efficient use of gases with lowest emissions which should be the central responsibility of natural gas undertakings and gas transport system operators. Because customers can’t choose the gas, nor refuse it or send it back, they are concerned to be exposed to more uncertainty and risks. Moreover, blending of small quantities of hydrogen into gas grids may be possible on the distribution level, taking account of the quality needs of the respective customers. A gas quality management has to be established in accordance of the responsibility and liability of the TSO’s & DSO’s. We strongly support the existing unbundling rules, which call for separation of grid operation from other activities of the respective commodity (e.g., production, storage), and which should also be implemented for hydrogen and renewable/low-carbon gases. Therefore, we recommend that TSO’s operating a hydrogen grid buy hydrogen balancing services on the market to fulfill their obligations instead of operating own electrolyzers. With regard to distribution grids, the regulatory framework should allow for companies to own and operate natural gas grids and hydrogen grids within the same company to increase efficiency. IFIEC welcomes the intention of the revision to have a level playing field for all gases regarding tradability and acces to markets and gas grids, meaning that there will be no preferential grid access for any hydrogen and renewable/low-carbon gas production technology. This also includes guaranteeing non-discriminatory acces for suppliers and users of hydrogen and decarbonised gases at all entry and exit points of the hydrogen grid. IFIEC strongly advocates for a regulation based on cost-effectiveness, transparency, non-discriminatory third party acces, role of NRA’s (including the role of the NRA’s safeguarding the interest of both grid operators and end-users) and preventing cross-subsidisation. We are concerned of facing high tariffs e.g., due to stranded assets of natural gas pipelines and initial low load of hydrogen. According to the roadmap, Biogas/-methane will have an important share in the gaseous fuels in 2050 and play an important role to reach the goals of the Green Deal Strategy. From IFIEC’s point of view there is a lack of consistency as biogas/-methane is not fully covered under the EU ETS. As IFIEC we welcome the approach of the revised TEN-E regulation to establish cross-border infrastructure for decarbonised gases and CO2, paying continuos attention to the goal of market integration. With regard to infrastructure planning, IFIEC supports an integrated approach based on increased coordination of Network Developments Plans for electricity, natural gases and hydrogen.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

4 Mar 2021 · Discussion on regulatory barrier for the deployment of CCU and CCS

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

IFIEC Europe's feedback is contained in the attached file.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

IFIEC Europe's response to the EU Commission IIA on EEAG revision is contained in the attached pdf file.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

IFIEC welcomes the opportunity to participate in the consultation on the review of the National Emissions Reduction Targets by Member States, the so-called Effort Sharing Regulation (ESR).  This regulation covers all greenhouse gas emissions which are not covered by the EU Emissions Trading System (ETS) or by the Regulation on Land-Use, Land-Use Change and Forestry (LULUCF).  It must be ensured that the most cost-efficient and internationally sound burden sharing between ETS and non-ETS should be applied when the target is increased. The planned review of effort sharing regulations should not lead to additional cost increase for the ETS sector, and thus to a decrease in competitiveness of the European industry. This would lead to the departure of production facilities to non-European countries or -in other words- carbon leakage. IFIEC therefore emphasizes the importance of continuing to ensure carbon leakage protection for European industry. In this context, existing measures such as free EU ETS allowances and indirect cost compensation should remain and even reinforce in line with the new climate targets. One of the options considered by the EU commission is the introduction of emission trading for a significant share of the existing effort sharing sectors and its combination with the existing ETS sector. This would have substantial consequences and risks for the economic competitiveness of the ETS sector.  The building and transport sectors have different characteristics as compared to the ETS sector: low price elasticities, long investment cycles, and in some cases, few alternative technologies. These differences indicate that market-based climate protection instruments such as carbon pricing/emission trading are likely to have a different impact on these sectors than on the ETS sector. This will cause an increase in CO2 prices, which as a consequence will put additional pressure on the competitiveness of European industries in the ETS sector. As global competitors do not incur these additional costs, the risk of carbon leakage increases. Therefore, a shared emissions trading system would lead to a disproportional increase of financial burden for the ETS sector. Moreover, a significant reduction in CO2 emissions has already been achieved in the EU ETS sector over an extensive period of time, whereas transport and building sectors fall behind the targets. Again, long investment cycles and low price elasticities have led and will continue to lead to a delay in emission reduction for non-ETS sectors, reinforcing the increase of financial burden for the ETS sector. The consequence will be a significant imbalance in CO2 costs and avoidance measures and a further distortion of competition. IFIEC therefore supports a continuation of a separate ETS sector. In conclusion, IFIEC re-emphasizes that secure legal and economic framework conditions with effective and adequate carbon leakage protection are crucial for the energy-intensive industry in order to maintain international competitiveness and at the same time enable the transformation towards a climate-neutral economy. About IFIEC Europe IFIEC Europe represents 13 national European associations that comprise - on a cross-sectoral level - those industrial sectors for which energy is a significant component of production costs. IFIEC´s membership represents a diverse set of industries including: aluminium, automobile, brewing, cement, chemical, copper, fertilizer, food, glass, industrial gases, metals, paper, pharmaceutical, plastics and steel.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please see the attached file for IFIEC's full response, from which the following selected comments are extracted: IFIEC welcomes the opportunity to participate in the consultation on the roadmap to update the EU Emissions Trading Scheme and supports the EU Commission's discussion on an improved emissions trading scheme. In order to meet possible increased greenhouse gas targets, the EU needs a competitive energy-intensive industry to drive the transition and that continues to develop sustainable innovations, products and jobs in Europe. It must be ensured that the planned reform of emissions trading does not lead to additional cost increase for industrial installations in Europe, and thus to a decrease in competitiveness of the European industry. This would lead to the departure of production facilities to non-European countries, so-called carbon leakage. IFIEC therefore emphasizes the importance of continuing carbon leakage protection for European industry. In this context, existing measures such as the free EU ETS allowances and indirect cost compensation should remain and even be reinforced in line with the new climate targets. IFIEC asks the Commission to thoroughly assess and substantiate the economic impact of revising the ETS Directive. IFIEC re-emphasizes that secure legal and economic framework conditions with effective and adequate carbon leakage protection are crucial for the energy-intensive industry in order to maintain international competitiveness and at the same time enable the transformation towards a climate-neutral economy.
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

9 Nov 2020 · Green deal and fit for 55 package

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

20 Sept 2020

[please see attached document for full response] RED needs to supply clean, affordable and secure renewable energy IFIEC contribution Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of renewable energy. IFIEC agrees that the development of the generation of renewable energy can significantly contribute to reduce greenhouse gas emissions and help to achieve the European Green Deal targets. Access to competitive low carbon energy is key to achieve the European targets. Hence, the availability of abundant, secure and affordable low carbon energy will be necessary. This will require strong political support, timely development and financing of adequate infrastructure for energy generation, transport and energy import. Renewables should not harm the security of supply Security of energy supply is vital for the proper functioning of industrial activities. The development of renewable energy could harm the reliability of energy networks. For electrical network, intermittent renewable electricity, like wind and solar, have huge impacts on its stability and for the gas network, injection of renewable fuels like biogas or hydrogen generate significant fluctuations of the gas quality delivered to the consumers. The revised RED shall ensure that the development of renewable energies will not harm the reliability and the efficiency of the transport and distribution networks and of industrial activities. All kinds of low carbon energies are needed to decarbonize Due to technical limitations, electrification is not always possible to decarbonize industrial activities and will not always be the most energy efficient solution. Industry also strives to use biomass, biogas, recycled carbon fuels and hydrogen. Those fuels should be considered as energy carrier enabling to reduce emissions in the production of heat or other processes. In particular, biogas/biofuels should be recognized in the EU ETS scheme with a zero CO2 emission factor, whatever the way it is financially supported. It is of the utmost importance that all the pieces of regulation covered by the green deal are revised in a consistent manner. For some sectors or processes electrification will be the most effective solution to reduce emissions. The challenge of further/fully decarbonizing electricity supply is still huge, and therefore all forms of low carbon electricity should be supported and implemented. Safeguard European industrial competitiveness Anyway, renewable energy policy must be backed by a strong innovation fund financing research in breakthrough technologies efficient in energy as well as by a comprehensive modernisation fund enabling their deployment in the industrial sector. In any case, the main challenge for the European industry will be the safeguard of its international competitiveness. Innovation will play a crucial role in the increase of the share of competitive climate neutral energy and should be financially stimulated and supported in order to reduce the global cost of renewable energy for the community. This financial support should be cost-efficient, should focus on CAPEX costs, should be temporary and benefit innovative technologies that are – for the time being- not viable without support. Decreasing the overall energy system costs must be in the focus of energy policy. Hardship regimes on energy costs for industrial consumers in global competition, especially for surcharges on top of market prices, must be accepted as long as RES and further climate policies will be causing a non-level playing field in energy competitiveness for these companies.
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Response to Review of Directive 2012/27/EU on energy efficiency

20 Sept 2020

[Please see attached document for full response] EED needs to avoid capping energy usage and should focus on energy efficiency IFIEC contribution Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of energy. IFIEC agrees that an efficient use of energy can contribute to an improved greenhouse gas efficiency and help to achieve the European Green Deal targets. Avoid capping of energy consumption; focus on efficiency First of all, IFIEC would like to remind legislators that improving energy efficiency does not mean absolute reduction of energy consumption, but a reduction of energy consumed per output, expressed for example in GJ/t of product. Setting absolute caps on energy consumption will lead to a reduction of the production of the European manufacturing industry, an increase of the imports from third countries and usually an increase of the European carbon footprint, imported products generally being produced in a less efficient way and with a more carbonized energy mix. All the key economic sectors should play their part in achieving the 2030 energy efficiency target. The level of ambition should be fixed in regards of the reduction potential of the concerned sector. For decades, European manufacturing industry has been improving its energy efficient. It now operates its processes very often close to the thermodynamic limits in term of energy consumption. To fill this gap and reach the thermodynamic limits, disruptive technologies are needed. However, they are not yet available or demonstrated at laboratory scale and/or on a full industrial scale. Furthermore these new low carbon technologies will require more energy and electricity. A cap on the energy consumption would therefor hamper industry to implement these new low carbon technologies. Thus, the revision of EED should be done in a realistic way and set only achievable targets for the near future. Avoid conflicting regulations The EED should also be revised in a consistent way with other pieces of regulation in preparation like RED encompassed in the green deal. Some provisions of other regulation could have a negative impact on the energy efficiency. For example, for the decarbonation of industry, the switch from fossil fuels to renewable fuels will reduce energy efficiency (a biomass-fired boiler has a lower efficiency than a natural gas fired boiler) similarly, implementation of facilities to capture carbon dioxide adds 15 to 20 % to the energy consumption of the whole value chain. The increasing share of intermittent renewable energies in the European energy mix may require more energy flexibility from large industrial energy consumers, with the consequence that Industrial processes might be not operate with the highest efficiency 100 % of the time. This is the reason why the new EED provisions should take into account both the evolution of the European energy mix and the consequences and the impacts of the other regulations. Stimulate sector integration Higher integration amongst the key economic sectors can improve energy efficiency significantly. For example, industrial waste heat can be recovered and used for heating buildings of household or tertiary sectors. However, it could require tremendous investments in heat network to establish connection between sectors. The development of such new energy infrastructures should be supported by public policies, industry not being able to finance them. Safeguard European industrial competitiveness In conclusion, energy efficiency policy must be backed by a strong innovation fund financing research in energy and CO2 efficient breakthrough technologies, as well as by a comprehensive modernisation fund enabling their deployment in the industrial sector. In any case, the main challenge for the Europe.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

16 Jul 2020

IFIEC EUROPE’s response to EU consultation on Updated rules on Monitoring and Reporting Regulation (2021-30) 10 July 2020 IFIEC Europe welcomes the opportunity provided by the European Commission to give input on the draft updated rules on monitoring and reporting (2021-30) of the EU ETS. The main issues that are or still need to be addressed in the MRR update are: 1 Impact assessment needs to be carried out 2 Carbon Capture and Usage needs to be incentivized 3 Correct sustainability criteria need to be set 4 Biogas needs harmonized treatment and accounted with GoOs 5 Other CCS transport modalities need to be recognized For more details on our position and concrete proposals of amendments see both text and annex with amendments in the attached pdf.
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Response to Climate Law

1 May 2020

IFIEC Europe represents 13 national European associations that comprise - on a cross-sectoral level - those industrial sectors for which energy is a significant component of production costs. IFIEC welcomes the possibility to contribute its view on the Commission proposal for a regulation establishing the framework for achieving climate neutrality (European climate law). We believe European energy-intensive industry will play a pivotal role in the transition towards a carbon neutral society. Energy-intensive companies face major challenges to reduce emissions related to energy consumption and feedstock usage and will be highly dependent on the development and implementation of innovations, the availability of affordable and sustainable energy, adequate infrastructure for generation, transport and import of energy and the global context of competitiveness and investments. Therefore, the proposed climate law should include structural monitoring and assessments with regards to enabling conditions for the transition of the economy, availability of (energy) resources, global level of ambition and the pace and expected rate of deployment of breakthrough technologies. It should include policy actions to safeguard industrial competitiveness in Europe, ensure greenhouse gas reduction is achieved in a cost efficient and balanced way and strengthen EU funding to accelerate technology development in energy-intensive sectors.
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Response to 2030 Climate Target Plan

15 Apr 2020

In the European Green Deal, the European Commission proposes increasing the EU’s greenhouse gas target for 2030. IFIEC Europe welcomes the European Commission’s intent to first carry out an assessment on the economic, social and environmental impacts of such an increased target. In order to meet new proposed targets, the EU needs a competitive energy-intensive industry that continues to develop sustainable innovations, products and jobs. Therefore industry needs increased support with regard to technology development, demonstration and market uptake, as well as access to competitive, predictable low carbon energy systems and markets for low carbon products. Long-term predictability principles, which are crucial for energy-intensive industries, must not be jeopardized. A new 2030-target should consider the pace and scale of long-term, low carbon investments. The societal costs resulting from climate adaption and mitigation must be carefully assessed and addressed through necessary legislative updates, where the most cost-efficient and internationally sound burden sharing between ETS and non-ETS should apply. Carbon leakage risks and relevant carbon leakage measures must be an inherent element of the impact assessments accompanying the decisions on climate targets. Legislative updates should address regulatory barriers that hinder industry from reducing greenhouse gas emissions while remaining competitive and innovative in Europe. See attached document. We also support the Alliance statement: https://cefic.org/app/uploads/2020/04/Joint-Alliance-submission15-04-20.pdf
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

[see attached file for full response] IFIEC Europe’s response to the Inception Impact Assessment on Carbon Border Adjustment Mechanism (CBAM) Improving carbon leakage protection of the European Union Executive summary In December 2019, the European Commission adopted the European Green Deal. In relation to policy measures to prevent carbon leakage the European Commission considered the introduction of a carbon border adjustment mechanism. IFIEC Europe welcomes the initiative of the European Commission to assess how the carbon leakage protection of the European Industry can be enhanced when the EU’s ambitions with regard to climate protection exceed these of other third countries. This is a prerequisite if Europe would like to maintain its climate ambition and leadership in the world. But IFIEC also recognizes that full carbon leakage protection with existing instruments becomes more and more difficult with increasing climate targets. IFIEC Europe recommends to take the following aspects into account, when designing new or improving existing policy measures that aim at reducing the risk of carbon leakage: In the following sections these aspects are described in more detail. 1. Effective carbon leakage safeguard policies needed, especially with increased climate ambition. It is crucial that the future carbon leakage protection policy mix remains at least as effective as the existing measures, both for importing and exporting sectors, so that the European industry can play an active role in the transformation of our economy into a low carbon society and to make the European Green Deal a success. The EU ETS with sufficient level of direct and indirect compensation shall remain the key policy for this. If additional carbon leakage protection policies are required due to increasing ambition, they must supplement rather than substitute the existing measures. 2. Detailed impact assessment needed on all possible policy instruments. In case of increased climate ambition, the European Commission should conduct a detailed impact assessment to thoroughly assess the effectiveness of a CBAM. In parallel, impact assessments on other potential or existing carbon leakage protection policies need to be conducted and compared with the effectiveness of a CBAM. Key is to fully understand the impact the introduction of a CBAM or alternative measures would have on all the stakeholders affected. 3. Complete industrial value chains need to be assessed in transparent way in cooperation with all stakeholders. Industrial sectors and value chains are very complex interdependent entities, affecting and affected by the competitiveness of their other value chain actors. The introduction of any new policy measure and their impacts must be carefully assessed, in order to avoid disrupting their functionality. The European Commission should also analyse the characteristics and needs of different value chains and industrial ecosystems. The analyses should be conducted in a transparent way and should closely involve all the stakeholders concerned. IFIEC believes that a structured dialogue and cooperation between the European Commission and the industry sector must be established to investigate the regulatory framework needed.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

(please see attached document)
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Response to Climate Law

5 Feb 2020

1. IFIEC Europe welcomes the EU Commission’s intent to safeguard the competitiveness of EU industries The European Union wants to become the first carbon neutral continent in 2050 which involves massive investment in all sectors of the EU economy. For industry, such investment level can only be achieved with reasonable profitability, and thus comparable costs to those incurred by their competitors in other countries. In light of asymmetric increasing EU climate ambitions, IFIEC Europe requests the explicit translation of the need to safeguard EU industrial competitiveness into short and middle term actions. This should be included in the climate law. If the new European policy forces European manufacturing industry to reduce its production with as a consequence increasing imports from third parties of products with higher carbon footprint, the worldwide emissions will increase with a negative impact on climate. Therefore, a proper impact assessment of the Green deal ambitions and its different options envisaged is required as well as a monitoring and adaptation mechanism in function of the evolution within the global framework. Moreover, transparency on the cost of the transition and a robust ‘green financing deal’ upfront of the investments is needed to turn the strategy into actions that are sustainably supported by the population. 2. Climate law must be designed to keep a high performing industry in Europe Policies must be directed towards GHG reductions in all sectors, in a consistent way. The reduction obligations between sectors need to be balanced appropriately based on the reduction potential of each sector. European industry should remain an essential player to develop innovative technological solutions for combating global warming and achieving carbon neutrality. A successful industrial policy should be coherent and give the necessary stability for industry to transform. Supporting manufacturing industry rather than constraining it is the best way to accelerate the research on new energy efficient technologies and best available technology enabling the transition to a carbon neutral economy. Moreover, the Commission should perform regular impact assessments on the 2050 targets that take into account the global actions over time and that feed the EU strategy. Such impact assessments include the pace and cost of the development and implementation of innovations, the availability of affordable and sustainable energy, and the global context of competitiveness and investments. Carbon leakage safeguard (such as free allocations of emission allowances and financial compensation for indirect emissions) shall be improved. Indeed, if policymakers do choose to raise the 2030 targets, this needs to be accompanied by reciprocal carbon leakage measures to protect the best performing installations from facing undue carbon costs. In particular, the ETS’s indirect compensation schemes and free allowance system would need to be improved as a reciprocal measure to a more ambitious 2030 target. Access to competitive low carbon energy is key to achieve the European targets. Hence, the availability of abundant, secure and affordable low carbon energy will be necessary. This will require strong political support, timely development and financing of adequate infrastructure for energy generation, transport and energy import. 3. Competitive and innovation friendly framework needed to enable industrial investments Making Europe carbon neutral will require massive public and private investments. It is critical that EU capital markets mobilize finance towards environmentally beneficial projects. Funding can support the development and deployment of new production technologies. Additionally, a strong European innovation framework is needed to stimulate new technologies, upscaling, market entry of new products or applications, and ensure costs are not passed on so that trade-exposed energy intensive industries remain competitive.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

9 Jul 2019

Please find attached the response of IFIEC Europe on the revising the rules for free allocation in the EU-ETS (draft implementing act on activity level changes). The response of IFIEC Europe focuses on this main topics: I. Need for absolute threshold next to the relative threshold of 15% II. Adjustments after the initial threshold of 15% is met III. Avoid penalisation for energy efficiency
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Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR)

26 Nov 2018

IFIEC response on the consultation regarding the monitoring and reporting regulation 1) Response to phase 1 of MRR consultation We thank you for the opportunity to comment the draft Monitoring and reporting regulation (“MRR”). We understand that this is only the consultation on the first step, in which clarifications and administrative simplifications are treated. The second step will deal with a number of other elements such as the MRR rules for greenhouse gases that are captured and utilised (“CCU”), both the capturing as the use of source streams. We therefore insist on the importance of a consultation regarding the second step. 2) Support for innovations In this draft MRR an important change vis-à-vis the current version has been proposed based on the Schaefer case. It is important to mention that in this framework, recital 17 explicitly states “those conditions should not exclude the possibilities of future innovations”. We support this statement, and suggest to add it as a separate recital which applies as a general rules to the to the entire MRR, and not only to the change imposed by the Schaefer case. Indeed, other innovations, such as CCU, should also be supported by the MRR.
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Response to Free allocation of emission allowances

22 Nov 2018

IFIEC Europe response on Commission consultation on delegated regulation on free allocations IFIEC-Europe has three main comments on the draft Delegated Act on Free Allocation Rules 1) The benchmarking exercise may not be implicitly included in the current draft Delegated Act on Free Allocation Rules On the one hand, ETS Directive 2018/410 of 14 March 2018 empowers the Commission to adopt Delegated Acts to supplement this Directive concerning Harmonized rules for the allocation of allowances (c.f. article 10a § 1). The Delegated Acts are submitted for advice to the Climate Change Expert Group before being adopted by the College of Commissioners and submitted to European Parliament and Council. On the other, the Commission shall also adopt Implementing Acts for the purpose of determining the revised benchmark values for free allocation (c.f. article 10a § 2). The Implementing Acts will be submitted for voting by Member States representatives in the Climate Change Committee before being submitted to European Parliament and Council. The above exercises require therefore respecting distinctive procedures as set in the ETS Directive. The benchmark update should not already be implicitly included in the allocation rules (Delegated Act). The scope for the benchmark update will be larger than the current one for the activity data. A clear distinction in line with the Directive should be made between data collected for baseline definition and data collected for the benchmark update. The data collection in relation to the delegated act of free allocation rules should be limited to the relevant information (e.g. intermediate products, heat production processes, split between heat and electricity of C02 emissions of cogenerations units are not needed). 2) Fall-back heat benchmark methodology may not be changed for ETS 4 In ETS Directive 2018-410, it is not stated that the benchmarking methodology or assumptions taken into account in 2011 can be changed. Moreover and in line with this, Recital 4 of the draft Delegated Act determining rules for Harmonized free allocations states that the methodology shall remain unchanged other than improvements to legal clarity and linguistic improvements. In 2011, the heat benchmark value was determined on basis of a natural gas fired-boiler with a thermal efficiency of 90%. The choice of a conventional boiler as technology and natural gas as fuel fully meets the methodology principles as set in the Commission decision 2011-0278 of 27 April 2011. The same principles (simplicity, fuel widely available and second best efficient techniques in terms of greenhouse gas efficiency) should therefore be used for updating the heat/fuel benchmark values. The current draft Delegated Act is proposing to change this methodology by going through an extensive data collection of all current boilers in Europe. It would include de facto in the “10% best” boilers most boilers based on renewables with zero GHG emissions driving therefore the resulting heat benchmark to its lowest theoretical level. 3) Absolute threshold for dynamic allocation As the new ETS directive states, if activity changes with more than 15%, free allowances are adjusted. However, the negotiation outcome also includes the possibility for an absolute threshold (Recital 12 of the new ETS Directive). This is important for larger efficient installations that have difficulty to reach the relative threshold, but where an absolute threshold can result in a significant allowance update. - More details can be found in the attachment.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

20 Nov 2018 · Introduce IFIEC Europe, to discuss the EU’s future climate strategy, the role of energy intensive industries EU industry days workshop 2019

Meeting with Dominique Ristori (Director-General Energy) and European Chemical Industry Council and

8 Jun 2018 · clean energy transition

Meeting with Miguel Arias Cañete (Commissioner) and European Chemical Industry Council and

8 Jun 2018 · Energy transition and the energy intensive industry

Response to Revising the rules for free allocation in the EU Emissions Trading System

16 Apr 2018

IFIEC Europe welcomes the European Commission’s publication of the Roadmap on Revising the rules for free allocation in the ETS (Ref.: Ares (2018)1523713). IFIEC Europe represents the interests of industrial energy users in Europe for whom energy is a significant component of production costs and a key factor of competitiveness in their activities in both Europe and throughout the world. Our detailed feedback can be found in the attached PDF file.
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Response to Carbon Leakage List 2021 - 2030

11 Nov 2017

IFIEC Europe represents the interests of those industrial sectors for which energy is a significant component of production costs. IFIEC Europe's mission is to anticipate and to respond to the evolving requirements of those sectors by proposing policies that allow realistically priced energy to be available. This will allow them to continue to improve energy efficiency and environmental performance whilst ensuring international competitiveness both in Europe and throughout the world. Importance of free allowances and therefore also a correct CL list. As also mentioned in the Council conclusions, in order to maintain international competitiveness, the most efficient installations in carbon leakage sectors need to be safeguarded against unilateral climate policy costs. In the EU ETS, this is organized with free allowances. Only when sectors are part of the CL list, they are eligible for receiving this safeguard. It is therefore imperative that utmost is done to make a correct Carbon Leakage list where the principle of equality of treatment should also be reflected. Trade intensity determination: The trade intensity shall be calculated on the basis of the trade flows between countries under the EU ETS (i.e. European Economic Area) and third countries. The trade intensity should take into account trade with all countries which do not have an equal ETS system. The scope and burden of such equal ETS should be similar as the EU ETS system or protection mechanisms that are in place. Indeed, only systems with a similar burden for companies can be considered as equal to the EU ETS system. Some systems only cover power industry or only few industrial subsectors and/or not applicably in the whole region. In that case there is no equal burden and therefore still a carbon leakage risk. The electricity market price is set by the marginal power plant. Thus to be consistent, the CO2 emission factor of the marginal power plant shall be the one to be used for the assessment of indirect CO2 emissions linked to electricity consumption. All depends on the correctness and completeness of data; Sector federations can help. For a correct Carbon Leakage list, complete and correct data is essential. Sector federations need to be part of the data gathering, to ensure timely correct and complete data. Incorrect or incomplete data can result in erroneously removal of a sector from the Carbon Leakage list. Sub-sectoral activities must also be considered for inclusion in the Carbon Leakage list. Maintaining the possibility to be assessed at disaggregated level is crucial to preserve the fairness and completeness of the Carbon Leakage list. In addition to this, the timing, verification, and coherence of data sets and related administrative and procedural rules are essential to preserve the equity of the carbon leakage list. In particular, the timing and administrative requirements applicable to the disaggregated assessment should be aligned with those applicable at NACE level. Carbon leakage protection criteria should also include the assessment of the value chain effects because subsectors might be impacted by exposure of up- or downstream sectors and this should be taken into account. The precautionary principle should be applied.
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Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

28 Jun 2015 · Competitiveness & industrial growth

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

17 Feb 2015 · Presentation IFIEC Europe

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

4 Dec 2014 · Energy policies and EU climate actions