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International Emissions Trading Association

IETA

IETA is dedicated to: - The objectives of Paris Climate Agreement and the United Nations Framework Convention on Climate Change (UNFCCC) and ultimately climate protection; - The establishment of effective market-based trading systems for greenhouse gas emissions by businesses that are demonstrably fair, open, efficient, accountable and consistent across national boundaries; - Maintaining societal equity and environmental integrity while establishing these systems. Goals and Objectives IETA works to: - Promote use of Article 6 to form effective linkages between carbon pricing systems over time. - Promote growth of new market initiatives around the world. - Improve the credibility and functionality of compliance and voluntary carbon markets. - Promote carbon removals in carbon markets to advance the objectives of the Paris Agreement consistent with the UN Sustainable Development Goals. - Support effective models of private sector engagement in climate finance.

Lobbying Activity

Response to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)

25 Sept 2025

IETA welcomes the opportunity to provide feedback on the European Commissions Call for Evidence on the CBAM implementing act on carbon price paid in a third country. IETA reiterates its strong support for the EUs climate objectives and acknowledges an effective CBAM as a tool to address carbon leakage while incentivising global carbon pricing. Clear rules on the recognition of third-country carbon pricing are critical to ensuring the effectiveness, fairness, and credibility of CBAM. Timely publication of implementing acts and clear guidelines are essential for stakeholders to prepare for compliance ahead of the definitive period starting 1 January 2026. IETA encourages the Commission to establish recognition criteria that account for structural elements of third-country carbon pricing mechanisms, while maintaining equal treatment across jurisdictions. For ETSs, the contract used to determine the recognized carbon price should reflect local market conditions, and guidance should allow aggregation of multiple instruments into a single effective price, with clarity on currency conversion. The treatment of domestic and international carbon credits should align with the evolving EU ETS framework, acknowledging the growing role of international credits, including Article 6 credits and high-integrity frameworks. Sector-specific conditions, such as electricity traded on third-country power exchanges, require attention to ensure proportional and consistent CBAM application. Robust enforcement and mitigation of circumvention risks, including cooperation with customs authorities, are also essential. IETA encourages flexible, adaptive rules that reflect ongoing developments in global carbon markets while safeguarding CBAMs objectives. The full response is provided in the attached document.
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Response to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

25 Sept 2025

The International Emissions Trading Association (IETA) welcomes the opportunity to provide input on the Commissions Call for Evidence regarding the adjustment of CBAM obligations to account for the free allocation of EU ETS allowances. The response underlines the importance of timely adoption of implementing and delegated acts to provide clarity and legal certainty for businesses ahead of the definitive regime starting on 1 January 2026. It stresses that CBAM benchmarks must mirror the robustness of EU ETS benchmarks to avoid loopholes and ensure a level playing field between EU producers and importers. Particular attention is drawn to sector-specific challenges, for instance, in the aluminium sector, where the application of a single benchmark for both primary and secondary aluminium could create distortions and incentivise resource shuffling. IETA highlights that the methodology for calculating the adjustment must accurately reflect the level of free allocation under the EU ETS while remaining practical and administratively feasible for importers. IETA remains committed to supporting the successful implementation of CBAM and stands ready to contribute further to the forthcoming steps of the process, representing the perspectives of its members across diverse sectors and jurisdictions. The full response is provided in the attached document.
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Response to Carbon removals, carbon farming and carbon storage - certification methodologies for permanent carbon removals

22 Sept 2025

Representing over 320 companies operating across carbon market ecosystems globally, IETA welcomes the opportunity to respond to the European Commissions consultation on the draft delegated regulation establishing methodologies for certifying permanent carbon removals under the EU Carbon Removals Carbon Farming (CRCF) Regulation. Please see our full response attached.
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Response to European Climate Law amendment

17 Sept 2025

International Emissions Trading Association (IETA) welcomes the Commission proposal for the establishment of EU 2040 climate target and Climate Law review. Kindly find the IETA's feedback attached.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

The International Emissions Trading Association (IETA) welcomes the opportunity to provide feedback to the Commission's consultation on the revision of the EU Emissions Trading System (EU ETS) and the Market Stability Reserve (MSR). Carbon trading is the most effective and economically efficient tool for advancing climate ambition. Following multiple reforms, the EU ETS has become a trusted instrument, offering a reliable carbon price signal to market operators, covered entities, and investors. We are pleased to share our views with the Commission on the future of the EU ETS and MSR.
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Response to Verification of carbon removals, carbon farming and carbon storage in products

1 Jul 2025

On behalf of over 320 global companies operating in the carbon market ecosystem, IETA welcomes the opportunity to respond to the European Commissions public consultation on the draft implementing regulation for the verification of carbon removals, carbon farming and carbon storage in products under the EU Carbon Removals Carbon Farming (CRCF) Regulation. Please see the full response attached.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

18 Jun 2025 · EU’s 2040 climate target and the potential role of international credits in supporting the EU’s decarbonisation pathway

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

5 Jun 2025 · discussions on Green Claims Directive

Response to Report on the evaluation of the LULUCF Regulation

11 Jul 2024

The International Emissions Trading Association (IETA) welcomes the opportunity to provide evidence to support the Commissions review of the LULUCF Regulation. IETA believes this evaluation of the LULUCF rules is an important opportunity to consider how the EU policy toolkit can enhance activity and ambition. In this context, market-based mechanisms have the potential to drive investment from the private sector to help get the EU on track to meet its ambitious targets while also simplifying regulatory burden and aligning the LULUCF regulation with other EU policy tools. Please see the full response attached.
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Meeting with Wopke Hoekstra (Commissioner), Wopke Hoekstra (Commissioner)

13 Feb 2024 · 2040 communication and carbon markets

Response to 2040 Climate Target Plan

23 Jun 2023

The International Emissions Trading Association (IETA) welcomes the EUs initiative to develop a GHG reduction pathway towards the 2050 climate neutrality objective. Setting a 2040 climate target will provide businesses with much needed clarity and predictability on the future framework for decarbonisation of EU economy. Please find attached our recommendations for principles to guide post-2030 target and policy setting. Kind regards, Julia Michalak, IETA
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

24 Mar 2023 · EU ETS review; COP 28

Response to Carbon Removal Certification

23 Mar 2023

International Emissions Trading Association (IETA) welcomes an opportunity to provide feedback on Commission proposal for EU Carbon Removals Certification Framework (CRCF). The CRCF proposal is a first steps towards EU policy on carbon removals, albeit it is lacking details on the actual use of carbon removals. Under the recent review the EU ETS the cap will reach 0 by 2039. It is relevant not to wait with providing clarification on the design of the negative emissions entering the EUs carbon market and launch a discussion on options and modalities for carbon removals integration. See attached more detailed feedback.
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and Germanwatch

21 Sept 2022 · ETS

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

5 May 2021 · Exchange on IETA’s position in relation to linking the EU ETS to the UK ETS

Response to EU emissions trading system – adjusting the auction process for the period 2021-2030

6 Aug 2019

Please find our feedback in the attached document.
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Response to Revising the rules for free allocation in the EU Emissions Trading System

9 Jul 2019

IETA feedback on the draft implementing regulation on Allocation Adjustments 
due to Activity Level Changes 9 July 2019 IETA is pleased to have an opportunity to comment on the draft implementing regulation on Allocation Adjustments due to Activity Level Changes. The response below complements IETA’s response to the first round of public consultation on the Regulation, submitted in February 2019. Our comments are derived from a conviction that rules on allocation adjustments should be fair and transparent, should support industrial growth, avoid over-allocation and be designed with future linking of the EU ETS with carbon markets in other jurisdictions in mind. They should respect the guiding principles agreed by EU leaders in October 2014 for the review of the EU ETS in Phase 4: “Future allocations will ensure better alignment with changing production. (…) Incentives for industry to innovate will be fully preserved and administrative complexity will not be increased.” We hope that our views will be taken into account during the development of the final text of the Regulation. 1. The proposed rules are too rigid as they do not take into account the size of an installation. This disadvantage changes in activity level at large sub-installations. For complex installations, the +/-15% metric represents a significant number of allowances with a high cost impact if the activity threshold is narrowly missed. IETA recommends setting an absolute second threshold at a level of activity change that would give rise to +/- 25,000 EUA allocation. 2. The 5% staged approach, proposed in Article 5.2, does not adequately align the allocation with production increases or decreases. The allocation should be adjusted proportionally to the actual change in production, in a linear manner after meeting either +/15% or 25,000 EUA allocation thresholds. Since the data has to be collected, reported and verified anyway, there is no additional administrative burden. Furthermore, in the first round of public consultation the linear approach was supported by a large majority of respondents. 3. While Article 5.4 aims to avoid free allocation to sub-installations that have stopped activities for 
a year, it is unfair to operators of sub-installations that have a temporary interruption of activity 
(for a full calendar year). While IETA acknowledges that such a situation occurs rarely, it should be addressed in the Regulation so to avoid the installation with a temporary interruption in operation from being disadvantaged. 4. A possibility for the competent authority to require operators to report “additional parameters included in section 3 of Annex IV to Delegated Regulation (EU) 2019/331 in the activity level report” (Parameters for baseline data collection - Data for benchmark update) increases uncertainty and administrative complexity. It is discretionary and may undermine the level playing field, with operators possibly experiencing unequal treatment by competent authorities in different Member States. 5. In Article 3.4 the Regulation should oblige the competent authority to process the data and subsequent allocation adjustment promptly, preferably within a specific time frame. 6. Article 6.4 unfairly introduces the possibility of an adjustment if parameters other than activity levels change, including import of bio-based steam and a change in the electricity/heat energy balance of an installation changes by more than 15%.
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