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Nyrstar Netherlands (Holdings) B.V.

NNH

Nyrstar is an international producer of critical minerals and metals essential for a low carbon future.

Lobbying Activity

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

4 Sept 2025

The European Emissions Trading System (EU ETS) obliges European electricity producers to purchase emission allowances for their CO emissions. They pass these costs on through their electricity prices. Indirect Cost Compensation (ICC) is a European Commission-approved compensation scheme intended to compensate large electricity users for these indirect costs of emission allowances, which are passed on to them by the electricity producer. The main purpose of this compensation scheme is to prevent carbon leakage and preserve the competitiveness of those industries which are significantly impacted by the CO2 costs in electricity prices as a result of exposure to global markets. As Europe works to boost competitiveness and decarbonisation while preventing deindustrialisation, the ETS state aid guidelines remain as relevant as ever. This is especially the case for highly electrified and energy intensive metals producers like Nyrstar. The EUs Clean Industrial Deal and Steel and Metals Action Plan identify the strategic importance of maintaining and strengthening these industries for Europes economic resilience and strategic autonomy, in particular focusing on the green transition, high tech applications and our regional security. As sectors exposed to global markets, a well functioning indirect cost compensation is essential to ensure we can operate on a level playing field and remain competitive across the globe. Nyrstar welcomes the opportunity to provide input to this consultation and would like to emphasize three essential areas for the continued success of the ETS State Aid Guidelines. Eligibility of sectors In its recently published European Chemicals Industry Action Plan the European Commission states that the price assumptions made when the ETS State Aid Guidelines where updated no longer reflect the current market conditions, with prices now also affecting sectors that are not eligible. This is even more valid for the metals industries, which are now affected much more as compared to the assumptions that were taken to update the ETS State Aid Guidelines. It is expected that the impact will remain significant after 2030. If the Commission reviews whether more sectors meet the eligibility criteria set out in the state aid guidelines, it is crucial that the Indirect Cost Compensation remains impactful for the currently eligible sectors. Nyrstar emphasizes: The eligibility criteria should not be adjusted. If additional sectors meet the criteria, the budget available for the indirect cost compensation needs to increase in order to maintain its effectiveness for all eligible sectors. The Commission should therefore issue a recommendation to Member States to increase indirect cost compensation budgets in case additional sectors are added. The Commission should issue a recommendation to Member States to implement the possibility to limit the amount of the indirect costs to be paid at undertaking level to 1.5 % of the gross value added of the undertaking concerned. CO2 factors We encourage the Commission to combine countries with highly interconnected electricity markets into one region with one equal CO2 emission factor (for example Germany, Netherlands, Belgium, Luxemburg and France) to better reflect the CO2 cost component of the electricity price in these countries due to their interconnectivity. To ensure the ETS State Aid guidelines accurately reflect market realities, it is important that the option for a Member State to implement a market based CO2 factor needs to be maintained. Electricity consumption efficiency benchmarks Nyrstar supports the Commissions proposal to only review these for any new sectors meeting the eligibility criteria for Indirect Cost Compensation. There have been no technological breakthroughs in zinc electrolysis and the last 5 years have been abnormal (COVID + energy prices crisis), so the numbers would not be representative for the efficiency of the sector.
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