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Norsk Industri / Federation of Norwegian Industries

9434415651-11

Industry and employer's organisation.

Lobbying Activity

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

17 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

16 Oct 2023 · Waste Shipment Regulation

Response to European Sustainability Reporting Standards

7 Jul 2023

Change of text in: Annex 1, ESRS E1 Climate Change, AR 33 j) ....The undertaking shall only consider these energy consumptions as deriving from renewable sources if the actual grid caracteristic are renewable or the origin of the purchased energy is clearly defined in the contractual arrangements with its suppliers (....) Why? The Federation of Norwegian Industry supports GHG Protocol plans to holistically examine the appropriateness for market-based accounting across sectors, end-uses, and scopes, a process that should seek to explore whether market-based accounting is appropriate within scope 2. We believe it can be, but that requires a considerably stronger link between renewable certificates and actual grid characteristics. Improving market-based reporting mechanisms should take into account electricity distribution characteristics and actual flows. The benefits of location-based reporting, and the limitations of market-based reporting, can furthermore be extended to scope 2 emissions. As the draft Land Sector and Removals Guidance timely points out, there has been mixed feedback on the use of the market-based method in scope 2, including some criticisms about its efficacy and appropriateness. The biggest limitation is the lack of climate credibility associated with the use of guarantees of origin for electricity, which frequently are completely detached from actual scope 2 emissions. The limitations of market-based reporting of scope 2 emissions are highlighted through important EU policy developments, most notably the Carbon Border Adjustment Mechanism (CBAM). Umweltbundesamt, tasked to assess what methodology to apply to calculate emission intensities of imported industry products, strongly recommends to not allow use of guarantees of origin, or any other similar certificates, to calculate scope 2 emissions. Allowing for market-based reporting in CBAM offers a formidable chance of circumvention in that both domestic and external industrial producers can bypass credible emission footprint reporting. For this reason, our strong preference is to report emissions using a location-based method (i.e., use of on-site emissions for rather than a market-based method (i.e., emissions determined based on the qualities of the purchase of book-and-claim certificates or carbon offsets).
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Response to European Critical Raw Materials Act

26 May 2023

The Federation of Norwegian Industries welcome the new proposal for a Critical Raw Materials Act. Reaching the targets of the European Green Deal and the accelerated ambitions of REPowerEU will require a significant increase in the use of minerals and metals. Going forward, improving Europes access to critical minerals and metals will be decisive for securing strategic autonomy and delivering the green transition. The list of strategic raw materials listed in Annex I, Section 1 is an important measure to secure access to raw materials of strategic importance to energy and digital transitions and an identified potential supply concern in the next decade. Shortlisted raw materials are eligible for accelerated permitting measures and extra financial support. We recommend that materials such as aluminium, synthetic graphite, all lithium grades and silane are added to the list. Futhermore, the main metallurgical process for accessing listed by-products should also be considered as strategic. Please find enclosed our input to the consultation.
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Response to Revision of the EU’s electricity market design

12 May 2023

12.05.2023 Electricity Market Design Input from Federation of Norwegian Industries The Federation of Norwegian Industries, representing 20-odd sectors that include energy-intensive process industries and engineering industries, submits the following short comments on behalf of its members: We anticipate involvement by Norwegian authorities in the market design process, reflecting certain national characteristics of importance. Secure, clean and affordable electricity is of strategic importance to the competitiveness of European industry, employment and the economy as well as one of the defining enabling factors in the transition to climate neutrality. The end-user market must to a greater extent be organized in a manner whereby prices reflect real costs in the value chain. Europe's independence of import of certain critical raw materials and semi-refined products can be achieved with an ambitious energy policy that promotes affordability and security of supply. Given the right framework conditions, Norwegian industry is well-suited to supply Europe with critical and strategic industrial products. There must be no unnecessary barriers to hydro-power expansions, onshore or offshore wind-power It is crucial that the proposal concerning virtual Hubs in order to secure better price signals for future trade must not imply changes in the Nordic future market. Improved power system flexibility must be continuously pursued. Energy-intensive consumers capable of providing flexibility should be rewarded in the remuneration system of the flexibility market and in the grid tariff. The Commission has proposed to incentivize demand response and facilitate a more efficient transmission system based on incentivized grid tariffs. The strengthening of electricity grids is of key importance for rapid electrification and industrial development However, the grid development should be cost efficient and based on identified projects. A well-functioning spotmarket must remain in place. Adjustments should be done in a way that improves market fundamentals, such as removing barriers to more generation and attracts more participants, boosting liquidity. Regulations should include clause(s) allowing for consumer protection in case of unforeseen or extreme market disturbances causing price hikes. PPAs have an important role to play. Access to competitive PPAs for industry should be improved and facilitated.. This requires access to guarantors, available balancing and firming instruments, and improved incentives for suppliers to offer competitive and tailored PPAs. The EU electricity system must allow for different long-term contract options to compete in the market and remain voluntary. Liquid forward markets together with efficient PPAs, will be important, both as enablers of investments in new renewable capacity and in industrial decarbonization projects, as financial hedging tools and furthermore goes hand in hand as a liquid forward market is needed to deliver a transparent price reference for the PPA market. Contracts for difference have been singled out as a key instrument securing supply and capacity. Mature technologies shall in principle not be eligible for support, but this should not exclude other measures deemed necessary in attaining the 2030/2050 climate targets. CfD schemes should also be designed in a way that upholds CfD recipients incentives to offer competitively priced PPAs. Speeding up permitting procedures is vital to achieve the energy and climate goals, while also ensuring local acceptance, so as to avoid public opposition to such projects at a later stage. Best regards Ole Børge Yttredal (sign) Norsk Industri
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Response to Initiative on EU taxonomy - environmental objective

30 Apr 2023

The Federation of Norwegian Industries represents 3,100 member companies with approx. 130,000 employees, within a wide range of industry branches. We welcome the effort in shaping the EU taxonomy legislation to increase investments in the green transition of the EU economy. We believe technical screening criteria must be based on realistic criteria, awarding industry companies and other economic activities, which are environmental frontrunners. We enclose our input to the development of new criteria for circular economy and pollution prevention and control.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

21 Oct 2022

The Federation of Norwegian Industries welcomes an evaluation of the WEEE directive. Our input focuses on challenges related to meeting the WEEE collection targets. In Norway, two reports have been carried out in 2018 and 2021 to study trends of sold EE products and WEEE collected. The latter report is attached. The report from 2018, which was carried out on behalf of the Norwegian Environmental Pollution Agency exceeds 5 MB, but may be provided upon request from the Commission. The reports conclude that gaps between EEE put-on-market (or waste generated) and that collected, can be related to uncertainties or inaccuracies in data and/or complementary flows. Important sources of errors contributing to discrepancy between amounts POM and WEEE collected were identified as follows: • Potential sources of error related to POM • Errors in registration or calculation of weights • Errors in the estimation of the effect of packaging weight • Companies have not been registered to the PRO (for instance online sales) • Uncertainty in the estimate of products “in stock” • Delayed entry of EE products into the waste stream, through e.g. customer retention/“hibernating stock” and C2C reuse, upstream of the PRO scheme • Export of products for reuse • Reuse within takeback systems • Issues concerning definition of reuse • Uncertainty in the estimates of “complementary flows” • Estimates of B2B collection • Estimates of WEEE registered as non-WEEE (e.g., iron and metal) • Estimates of WEEE in residual waste • Estimated levels of theft and illegal exports • Inconsistency in product group classification The two reports also provide recommendations for actions which can improve the accuracy of data and increase the collection rate of WEEE in Member States. Please contact us for any further information required.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

20 Sept 2022 · Waste Shipment Regulation

Response to EU rules on industrial emissions - revision

23 Jun 2022

The Federation of Norwegian Industries represents a wide range of industry branches. We represent over 3.000 companies with approx. 130.000 employees. Our main input to the revision of Directive 2010/75/EU can be found below. The Commission proposes that competent authorities in the Member States shall set the strictest possible emission limit values that are consistent with the lowest emissions achievable by applying BAT in the installation. The emission limit values shall be based on an assessment by the operator analysing the feasibility of meeting the strictest end of the BAT-AEL range and. We underline that it will - in any event - still be a need for flexibility, both for industry and for the competent authorities, when emission limit values in permits are determined. The Commission proposes that in the event of a breach of permit conditions, the Member States shall ensure that the operator immediately informs the competent authority (article 8 no. 2). A requirement to inform Competent Authorities of all minor breaches, will result in an overload of information and heavy administrative burdens. We believe that a requirement to inform the Competent Authorities of breaches to permit conditions, should be limited to more significant breaches to permit conditions (meaning breaches that have noticeable environmental effects). The Commission proposes that permits should establish, where possible, mandatory environmental performance limit values on consumption and resource efficiency levels, including on the use of water, energy and recycled materials, based on BAT conclusions. We believe that it will be difficult to develop BAT-AELs related to water use and resource consumption. Such requirements should be limited to monitoring requirements. According to the proposal for a new art. 14 a), companies' environmental management systems shall take into account life-cycle environmental performance of the supply chain. The Commission also proposes that the overall life-cycle environmental performance of the supply chain is taken into account as appropriate, as a general principle for operation of an installation (art. 11 fb)). We advise against introducing such requirements in the IED, as this directive mainly specifies requirements to emissions, as well as energy and resource efficiency, from an industrial installation under normal operating conditions. Requirements to consider overall life-cycle environmental performance of supply chains should be reserved for other types of EU legislation, such as e.g. the proposal for a Directive on corporate sustainability due diligence. According to the Commission proposal, penalties applicable to violations of national provisions adopted pursuant to the shall be proportionate to the turnover of the legal person or to the income of the natural person having committed the infringement. The maximum amount of such fines shall be at least 8 % of the operator’s annual turnover. We believe that penalties in Member States should, first and foremost, be determined by the severity of the violation. As we see it, the level of penalties applied in Member States should not be specified in detail in the revised directive. The current IED specifies that all permit conditions are updated in accordance with the new BAT conclusions four years after publication. Our experience is four years may be too little time to implement new BAT conclusions, considering the need to carry out necessary investments and installations of new technology. We believe that the deadline to implement and enforce new BAT-conclusions should be expanded to 6 years. This will provide more flexibility for industry and ease the pressure on case handling capacity within the competent authorities in Member States.
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Response to Promoting sustainability in consumer after-sales

14 Mar 2022

The Federation of Norwegian Industries supports the introduction of a consumer right to repair. Such a "Right to Repair" for consumers must be accompanied by a right for sellers of a product to offer reparation of products within the legal liability period. It should be considered to introduce the consumer right to repair for prioritized product groups to gain experience, before introducing this requirement to a broader selection of consumer products. Instead of obliging producers or sellers to repair goods beyond the legal liability (guarantee) period (sub-option 3A), we believe that the liability period should be extended (sub-option 3B).The obligation of offer a "Right to Repair" should be placed on the seller of products, which may rely on local repairers to repair products close to consumers. According to the European Sale of Goods Directive (EU/ 2019/771), the seller of a product shall be liable to the consumer for any lack of conformity, that exists at the time when the goods were delivered, and which becomes apparent within two years of that time. In Norway, the seller of a product is liable to the consumer for lack of conformity up to five years, for products that are expected to last significantly longer than 2 years. This follows from the Norwegian Act Relating to Consumer Purchases (article 27). We have not experienced any disadvantages with longer time limits than what already follows from the current directive. We recommend amendments to the directive to extend the legal liability period beyond the current minimum period of two years, as described in sub-option 3B. It should be considered to differentiate the legal liability period for different product groups. For instance, consumer products like e.g. furniture should have an expected lifetime even over five years. Achieving a circular economy requires the industry to mobilize. Voluntary agreements between competent authorities and economic sectors have proven to be a powerful measure to reach environmental goals in a cost-efficient way. For instance, agreements between Norwegian authorities and industry have resulted in substantial reductions on SOx and NOx emissions over the last 10-20 years. In Europe, the plastic pacts and the Circular Plastic Alliance have demonstrated their strengths in mobilizing industry. Such commitments and agreements will also be a good measure to foster the transition to more sustainable consumption of goods, e.g. by promoting repair and reuse.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

14 Feb 2022

The Federation of Norwegian Industries support the goals of waste reduction and increased recycling rates within the EEA-area. In addition to Waste Framework Directive, measures for waste reduction should be implemented in European product legislation and by introducing new incentives as right to repair, environmental labelling, etc. For complex industrial waste streams (e.g. sludges, slags, hazardous waste), economic support schemes promoting circular economy, incl. research development, commercialization of new technologies is key to obtain waste reductions. We support new measures to improve separate waste collection and source segregation and high-quality recycling. In should be considered to narrow the current derogations to the WFD art. 10 (3), which makes it possible to deviate from the requirements to implement separate waste collection. The Federation of Norwegian Industries does not see the need for new mandatory extended producer responsibility schemes (EPR-schemes) at European level. Before new EPR-schemes are introduced, the Commission should undertake thorough investigations to ensure that EPR-schemes that are already in place contribute to eco-design, high waste collection rates and high-quality recycling, in a cost-efficient manner. New EPR-schemes should not be introduced where other measures are more cost-efficient to reach goals on waste reduction and recycling. With regard to waste oils, we support collection targets at EU-level. In Norway, the current collection rate for waste oils is around 90 %. The high collection rate can be explained by a deposit/reimbursement system for certain lubricating oils/waste oils. Most of the collected waste oils is energy recovered, substituting virgin fossil fuels. This is regarded as a good environmental solution for management of waste oils. Regeneration of waste oils may be given higher priority in the future. However, regeneration is naturally a more complicated treatment option than energy recovery. We are uncertain whether it is appropriate to set European targets for the regeneration of waste oils. In any event, new EU EPR-schemes for lubricating oils/waste oils are not recommended.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The Federation of Norwegian Industries welcomes the effort in shaping the EU taxonomy legislation to increase investments in the green transition of the EU economy. Please find our input to the draft delegated act attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

The Federation of Norwegian Industries (Norsk Industri) is grateful for the opportunity to comment on the forthcoming revision of the Energy Efficiency Directive (EEDII). It should be noted that Norway is still in the process of transposing the recently agreed review of the Energy Efficiency Directive (Directive 2018/2002) into national legislation. Operators are consequently still in the process of adjusting to the agreed regulatory framework. Re-opening these provisions will spur regulatory instability, which in turn will delay or terminate planned investments. Under the European Green Deal, the Commission has committed to stronger action on climate change and, in particular, in the field of energy. Norsk Industri agrees that an efficient use of energy can contribute to an improved greenhouse gas efficiency and help to achieve the European Green Deal targets. Norsk Industri is not in favour of defining energy efficiency squarely as a reduction in absolute energy consumption. 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 being produced in a less efficient way and with a more carbonized energy mix. Rather, energy efficiency should be defined as gains in energy intensity, i.e. a reduction of energy consumed per output expressed for example in GJ/tproduct. Industry companies in Norway continuously strives to improve energy intensity as a means to improve its competitiveness in global markets where competition is fierce. All companies have energy management and energy auditing systems in place, and electricity consumption fully comes from renewable sources. Energy intensity improvements with existing technologies are almost saturated. To improve further means reaching thermodynamical limits, for which disruptive technologies are needed. Therefore, the level of ambition should be aligned to the reduction potential of the concerned sector, and targets should be weighted to sectors with remaining potential for energy efficiency gains. Norwegian industry has ambitions to fully remove its CO2 emissions by 2050. Achieving this requires technologies that require more electricity, not less. One example is use of hydrogen generated from renewable electricity. Generating renewable-based hydrogen on a sizable scale is incompatible with strict targets for absolute energy consumption. The EED should be an enabler, not a disabler, for decarbonisation technologies. Targets and energy efficiency definition should be designed accordingly.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The Federation of Norwegian Industries recommends an assessment of the Commission's 2030 Climate Target Plan and relate the 2030 ambition for renewable energy to the climate ambitions. The impact on energy-intensive industries should be given attention. It should consider how ambitions and policies will secure abundant renewable energy for large consumers at low costs. Norwegian energy-intensive industries are fully electrified, from renewable sources. Norway will decarbonise within 2050, which for many non-industrial sectors means replacing fossil fuels with electricity. A directive that promotes generation of more renewable power is welcome. This will require strong political support, timely development, and financing of adequate infrastructure for energy generation, transport, and energy imports. The inception document notes that “more industrial and commercial companies are directly generating or purchasing renewable electricity to lower their electricity costs and increase their competitiveness”. This is fragmented. PPAs can be an optimal tool to source more renewable electricity but supportive tools should be aligned and further policy measures should be developed. Direct generation is not an option for power intensive industry as the amount of energy needed exceeds areas available close to the plants, as well as the financial capabilities of companies in the sector. Renewable electricity is sold at prevailing market prices and is not cheaper than other sources of electricity. A complication is the Guarantees of Origin (GOs) scheme. Norwegian power consumption is 100% renewable and emission-free. GOs has no connection to actual electricity distribution or consumption. GOs should be limited to voluntary renewable support and not be reported in the electricity mix of member states. Any link between GOs and carbon footprint should be severed. It is counterproductive for both decarbonisation and promotion of actual renewable generation to provide a purely financial instrument as an alternative to these efforts. A necessary firming up of the GO regulation should be extended to low-carbon gases to better promote use of biogas, hydrogen etc. On Article 3 of REDII, we recommend refraining from setting new overall EU targets for renewables, until we understand the impacts of COVID-19 in the entire economy and the feasibility of the options elaborated by the Commission’s 2030 Target Plan. Among the options described, our industry supports a better use of waste streams (i.e. financial and regulatory support for development of industrial waste heat), the establishment of a comprehensive terminology for all the current and potential low carbon fuels (i.e. renewable gases, different types of hydrogen, etc.), introduction of a common certification of fuels to preserve the integrity of the internal market and new provisions on public procurement for the promotion and access to renewable electricity for electro-intensive industries. Norwegian industries’ collective ambition is to fully remove all its GHG emissions by 2050. This will require a formidable roll-out of many technologies, processes and products that are not yet commercially viable. Policy must promote these efforts, e.g. increased use of bio-carbon. Access to biomass will be limited and should be promoted in sectors where alternatives to decarbonisation is limited, e.g. process industry. Road transport should not be incentivised to increase use of biomass, as it has numerous decarbonisation alternatives. Biomass, recycled carbon fuels and hydrogen should be considered as energy carrier enabling reduced emissions in production of heat or other processes. Biogas/biofuels should be recognized in the EU ETS scheme, with a zero CO2 emission factor, whichever way it is financially supported. The same accounting rules need be applied in ETS and non-ETS. It is of the utmost importance that all the pieces of regulation covered by the green deal are revised in a consistent manner.
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Response to Carbon Border Adjustment Mechanism

30 Mar 2020

Carbon leakage is a clear and present danger for many Norwegian industries. It should be noted that the risk of carbon leakage is not limited to the threat of relocation of activities but also impinge on daily operations and profitability and most importantly, future investments. It is difficult to assess whether CBAM will be a measure that can effectively create a level playing field vis-à-vis 3rd countries with no GHG obligations. We are in great doubt about this. If such a scheme is to be introduced, it is paramount that it cannot be questioned within the confines of the WTO rules. The EU ETS has embedded carbon leakage measures with free allowances and the possibility for MS to grant compensation for indirect costs in the electricity price. Indications that these measures could be substituted by CBAM give rise to deep concern among Norwegian undertakings. Stability of framework conditions is of key importance, not the least with regard to investments and industry need predictability. Through the EEA-agreement, Norway is fully integrated in the internal market and have been part of the EU ETS since 2008. It is not possible to give an adequate assessment of the legal basis without knowing the design of the measure. Should Art. 192 TFEU become the basis, one could envisage that Norway would be obliged to follow suit, given that this article is reflected inn EEA, Annex XX. Norway, neither through the EEA or otherwise, is not bound by Art. 207 and if this article forms the basis for CBAM other solutions has in case to be found regarding the EEA/EFTA countries. These undecided points give further ground for concern. Norwegian industry cannot live with such legal uncertainty. Likely impacts are hard to determine, nevertheless we give the following remarks and questions: -The yet undesigned CBAM, including operational instruments (e.g. taxes, tariffs, regulations, allowances etc.) increases uncertainty for industry, -An initial trial period encompassing steel and cement, could in principle be followed by other energy intensive sectors. Without consultations, this cannot be accepted, -How will CBAM cater for European export and import of intermediaries likely to go into products bound for re-export? -The administrative burden for companies is expected to rise, -How is the concept of "carbon footprint" to be defined; how to deal with complex products and advanced transnational value chains? -WTO; 'like product', Most favoured Nation principle, Art.XX (b)? -Possible trade restricting retaliations from key trading partners cannot be excluded, -CBAM measures might potentially be side-lined by 3rd countries by only directing their "green" products to Europe, whereas carbon intensive products are directed to other markets thus having no effect on global mitigating efforts, -Eliminating ETS free allowances and indirect cost compensation in favour of CBAM must be regarded as potentially counterproductive, both with regard to European industrial competitiveness, carbon leakage and mitigation of the global climate challenge. Whichever form, EU CBAM seem presently to deliver more problems than solutions for the Norwegian process industry. European energy intensive industry cannot be included in a CBAM system without thorough and necessary consultations. Ideas proffered so far does not cater for companies trading globally, there is no legal certainty, revenues from a potential CBAM could end up anywhere and there is no proof that any such a system would benefit the climate challenge, hinder carbon- and investment leakage, nor contribute to an international level playing field. The Federation of Norwegian Industries fully support the New Green Deal. Based on close to 100% fossil free energy and in the technological forefront, we presented our vison for a carbon free industry by 2047 as early as 2016. Before launching a CBAM proposal the Commission should explore other instruments.
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Response to A new Circular Economy Action Plan

20 Jan 2020

The Federation of Norwegian Industries welcomes the new initiatives on circular economy. Achieving a circular economy requires mobilisation of industry. It is important that policy making is inclusive, fair and just. Tripartite cooperation is key to secure involvement from industry and unions. Voluntary agreements between competent authorities and economic sectors have proven to be a powerful measure to reach environmental goals in a cost-efficient way. For instance, agreements between Norwegian authorities and industry have resulted in substantial reductions on NOx and SOx emissions. There is ongoing work in Norway to consider how voluntary agreements can be designed to implement relevant provisions in the European single use plastics directive. Similarly, voluntary agreements could be a suitable measure to foster the transition to a circular economy in sectors such as textiles and construction. It is recommended that agreements between competent authorities and economic sectors are juxtaposed to e.g. mandatory extended producer responsibility in European legislation, provided that environmental targets are reached. Harmonisation of definitions and simplification of EU-regulations is necessary, e.g. the Waste Shipment Regulation. Longer validity of notifications and fast-track procedures for notifications to pre-consented facilities is needed. The amount of 25 kg associated to shipments of waste destined for laboratory analysis to determine suitability for recovery should be reviewed, to allow for bigger quantities to be sent. Harmonisation of MS's practice and understanding on definitions of by-products and end of waste and the level of contaminants in "green listed waste" is needed. To increase the demand for recycled materials, we favour quality standards for secondary materials and measures addressing interfaces between chemical, product and waste legislation. The new sustainable products' policy should reward products with limited environmental footprints and to provide incentives to manufacture products at locations where the environmental impact is the lowest. A product's environmental footprint should describe the actual environmental impact, meaning that specific data from production processes should be used for emissions, energy use, resource efficiency, chemicals, waste management, etc. Should the methods fail to rely on transparent and objective assumptions this may hamper market access. Examples of wrongful discrimination can be use of the primary energy factor and renewable energy guarantees of origin. Product policies is a key driver for increasing the demand for secondary raw materials. EU product standards should include requirements to document recyclability, reusability, and content of recycled materials. Where appropriate and realistic, minimum requirements for content of recycled materials should be considered. The exact product groups for which such requirements are appropriate must be considered on a case-by-case basis. Public procurement is an effective measure to increase the demand for environmentally friendly products, materials and services. Public authorities must lead by example and ensure that their procurement is green and award innovative solutions. Circular economy is rarely prioritised in public procurement. There is a need for better legislation and guidance, for instance in choosing efficient award methods for circularity and how to document circular product properties. Industrial parks and clusters, where energy and material flows are shared though industrial symbiosis, are drivers for research circular economy projects. To initiate more R&D, increased research grants are required as well as extended grant periods in order to follow innovation projects from the initial research period via piloting and industrial testing to commercialisation. Financial support to “first of a kind” investments must reflect socio-economic additional costs and corporate risk.
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Response to Revision of the ETS State aid Guidelines

11 Jan 2019

Norwegian power-intensive industry companies manufacture and develop materials with a low emission footprint that form the building blocks of a decarbonized Europe. They compete on global markets and are price-takers with no ability to pass additional costs on to customers without losing market shares. Their low emissions are due to high electricity-intensity in a country where power generation is 100% renewable. Power prices in Norway, on the other hand, are heavily influenced by CO2 prices. Norway is connected to markets where thermal power, whose costs rise with rising CO2 prices, dominates and sets prices. Historical observations and empirical testing using quantitative power market models indicate an average pass-through factor in Norway is 0,72 tCO2/MWh between 2013 and 2017. Moving forward, more intermittent renewable generation in Europe means that the share of thermal power will decline, but its influence on prices will not diminish accordingly. In most periods, renewable generation cannot cover all demand, and thermal power will remain the marginal output needed to clear the market, i.e. set the price. CO2 prices will continue to influence Norwegian power prices in the 4th phase, amplified by coming new interconnectors. Proportionately, the carbon leakage risk for Norwegian power-intensive industry will increase. To mitigate the risk of carbon leakage, it is imperative that the EU continues to allows Member States to partially compensate eligible industries for the impact of the CO2 costs on electricity prices. As a principle, industries where product prices are set globally (price-takers), and electricity cost is a major factor, should be automatically eligible. In terms of the options presented in the evaluation, a more targeted list, specific for the purposes of the Guidelines should be established. We agree that the list should be established based on to economic situation of the relevant sectors, with two factors; 1) exposure to international (outside EU) competition and 2) exposure to indirect ETS costs being most relevant. In the EU ETS' 4th trading period, CO2 prices will likely rise as the cap is lowered and no more cheap abatements exist. Risk of carbon leakage will increase proportionally. Permitted carbon compensation must reflect this development. A non-degressive support for eligible sectors, with a percentage of 85% throughout the period, is imperative. The evaluation notes that "it would also be possible to introduce specific rules for sectors that are partilcularly exposed to carbon leakage risk". This possibility is welcome, though it is important that this does not impede carbon leakage protection overall. To avoid under- or over-compensation, the applied pass-through factor (the influence of CO2 costs on power prices) should be as accurate as possible. To achieve this, we strongly recommend applying a pass-through factor based on marginal price-setting principles, derived with the use of power market models with an accurate representation of all European markets. In order to reflect power market dynamics, calculations of pass-through factors should be done at prespecified intervals, say every five years. Power market modelling will also reveal degree of bottlenecks between power markets. If these bottlenecks exist, and power prices differ, a single uniform European pass-through factor should not be contemplated. Compensation should be based on previous year’s production data (no coordination on EU level as for free allowances).
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Response to Towards a more comprehensive EU framework on endocrine disruptors

17 Jul 2018

We agree with the Commission’s proposed Roadmap, but would underline the need for scientific advice on this complex topic. A clear distinction should always be made between what is policy driven and what is science driven. Joint efforts between scientists and politicians should be made to ensure prioritizations - a risk based approach should guide where to use forces and money. We also support the Commission’s engagement with the OECD for test method development/validation.
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Response to Carbon Leakage List 2021 - 2030

13 Nov 2017

See attachment
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Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

8 Sept 2016 · TTIP; CETA; CHINA MES; Russia; WTO