Qemetica S.A.
Qemetica is a leading chemical group in the European market, driving many sectors of the modern economy on all continents with its products.
ID: 773177497617-27
Lobbying Activity
Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines
5 Sept 2025
1. General Assessment We welcome the European Commission's initiative to update the ETS State Aid Guidelines. The electricity price compensation is essential for us as an electro-intensive manufacturer of soda ash to maintain the competitiveness of our production in the European Union, in our production facilities in Poland and Germany. The proposed review of emission factors, geographic zones, and efficiency benchmarks is appropriate and necessary given the changing CO2 price developments. At the same time, it should be ensured that the adjustments are fair, transparent, and industry-appropriate. 2. Relevance for our Sector - Soda Production The production of soda (sodium carbonate) is both energy- and electricity-intensive. Due to several continuous processes, there is a consistently high demand for electricity. Furthermore, soda is an indispensable raw material for numerous downstream industries, including glass manufacturing, cleaning agents, further processing chemicals, the food, feed, and pharmaceutical industries. The CO2 costs resulting from the EU Emissions Trading System (EU ETS) significantly impact our production costs through electricity prices. Without electricity price compensation, a considerable competitive distortion threatens from providers in third countries with lower energy and CO2 costs. 3. Our Recommendations to the Commission We recommend that the Commission consider the following points: - Aid intensity should be increased from 75% to 100%: in order to fully offset the rising CO-related costs in electricity prices, aid intensity should be set at 100%; there is no reason for the compensation to be limited to 75%, since the beneficiaries of the state aid have no influence over CO2 costs in electricity prices. - State aid schemes compensating indirect costs of ETS should be extended well-beyond 2030. The carbon leakage risk, which is a rationale of the state aid, is not decreasing over time to the contrary, as the EU ETS allowance prices increase, the carbon leakage is not a risk but a material reality of many businesses. Expiration of the schemes after 2030 would have drastic effects on European industries competitiveness. - Transparent and comprehensible data bases - No retroactive changes: Any adjustments should only come into effect from the calendar year 2027 to ensure existing planning security for companies is not jeopardized. - Avoidance of unintended aid reductions: The technical review should not lead to a systematic reduction of aid for existing sectors. It should still be possible to adequately compensate for the real burden. - Industry-specific benchmarks with caution: If an adjustment of electricity consumption benchmarks is necessary, close involvement of the industry is desirable to make realistic assumptions based on current technical conditions. - Any decision to broaden the scope of support by including new sectors must not come at the expense of sectors already receiving compensation: if this a case an overall amount of funds available should be adjusted accordingly. 4. Final Remarks We thank the European Commission for the opportunity to comment and the transparent consultation. From our point of view, the targeted further development of the aid framework is a central contribution to securing industrial value creation in Europe while maintaining climate goals and fair competition.
Read full response8 Jul 2025
Qemeticas Position on the review of ETS1 and MSR recommendations aiming to ensure that the EU ETS is an effective, fair, and predictable instrument for achieving climate neutrality while maintaining industrial competitiveness and supporting social cohesion. 1. Aligning Allowance Withdrawal with the 2050 Climate Neutrality Goal Proposal: Adjust the current linear reduction trajectory of emission allowances so that their availability extends up to the 2050 climate neutrality target, rather than ending in 2039. Rationale: The current system projects exhaustion of allowances by 2039, creating a regulatory gap for the decade leading up to 2050. This premature end undermines long-term investment planning. Extending the allowance trajectory to 2050 would: o Provide regulatory certainty for industry and prevent carbon leakage. o Support the development and deployment of low-carbon technologies. o Ensure a just and gradual transition for all sectors. 2. Extending Free Allocation for Sectors at Risk of Carbon Leakage Beyond 2034 Proposal: Continue free allocation of allowances for sectors at significant risk of carbon leakage beyond 2034, decoupling the phase-out from the introduction of the Carbon Border Adjustment Mechanism (CBAM). Rationale: The current plan links the phase-out of free allowances to CBAMs rollout by 2034. There is uncertainty about CBAMs global acceptance and effectiveness in preventing carbon leakage. Premature removal of free allocation will expose EU industries to unfair international competition and risk relocation of production outside the EU. Maintaining free allocation until CBAM proves equivalently protective will safeguard jobs and investment, support the EUs industrial base and allow time to address CBAM design issues and secure reciprocal international climate action. 3. Simplifying and Extending the Modernisation Fund Beyond 2030 Proposal: Prolong the Modernisation Fund beyond 2030 and increase its flexibility, especially for industrial decarbonisation investments. Rationale: The Fund is vital for supporting energy transition and decarbonisation in lower-income Member States. The 2030 cut-off risks creating a financing gap during a critical period for technological deployment. Extending and simplifying the Fund would: o Ensure continued support for the most challenged Member States and industries. o Broaden eligible project categories and simplify access, adhering to technology neutrality. o Strengthen EU industrial resilience and bridge the investment gap for climate neutrality. 4. Excluding Waste-to-Energy Installations from the EU ETS Proposal: Maintain the exemption for waste-to-energy (WtE) installations from the ETS and do not impose surrender obligations on these facilities. Rationale: Subjecting WtE to ETS obligations would: o Increase costs for municipalities and citizens. o Fail to deliver meaningful emission reductions, since emissions depend on upstream waste composition. Potential negative consequences include: o Increased landfill use or waste exports to less regulated jurisdictions. o Undermining climate and circular economy goals. 5. Utilizing MSR Allowances to Support Industrial Decarbonisation Proposal: Allocate all or part of the emission allowances held in the MSR to directly finance decarbonisation investments in energy-intensive industries (EIIs), by selling these allowances and channeling proceeds into the EU Industrial Decarbonization Bank or similar mechanisms. Rationale: The MSR was intended to stabilize the carbon market but has only reduced the number of allowances, contributing to price spikes. High EUA prices and insufficient free allocation have created financial pressure on EIIs, which face a competitiveness crisis and struggle to finance essential emissions reduction investments. Redirecting a controlled volume of MSR allowances would provide a stable funding source for industrial decarbonisation.
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