Republiková únia zamestnávateľov
RÚZ
RÚZ vznikla 30.
ID: 253757237449-25
Lobbying Activity
Meeting with Ditte Juul-Joergensen (Director-General Energy)
3 Jun 2025 · REPowerEU, AEAP
Response to Single Market Strategy 2025
30 Jan 2025
Republikova unia zamestnavateľov (National Union of Employers of Slovakia) identified following priority areas, which should be discussed and improved as a part of the Single Market Strategy 2025: 1. Intellectual Property 2. Unfair Trading Practices 3. Unauthorised Sales 4. Territorial Supply Constraints 5. Packaging and Packaging Waste Regulation (PPWR) 6. Sustainability Reporting 7. Data Flows 8. Privacy 9. Digitalizations 10. VAT donations 11. Payments Digital description of the aforementioned problems and our proposed solutions can be found in attachment of this contribution.
Read full responseMeeting with Ľubica Karvašová (Member of the European Parliament)
6 Dec 2024 · Konkurencieschopné Slovensko (Competitive Slovakia)
Meeting with Martin Hojsík (Member of the European Parliament)
6 Dec 2024 · Competitiveness of businesses
Meeting with Ivan Štefanec (Member of the European Parliament) and Confederation of Swedish Enterprise
9 Apr 2024 · Europe Unlocked
Response to Report on the application of the General Data Protection Regulation
8 Feb 2024
Our position is fully stated in the attached file. General overview is following: Several businesses have concerns that certain national data protection authorities are overstepping their powers under the General Data Protection Regulation (GDPR). This risks undermining the balanced approach to data protection that supports innovation and economic growth across Europe. Under the GDPR, national data protection authorities have been granted a range of oversight, investigative, corrective, advisory, and enforcement powers. These include monitoring compliance, conducting audits, advising on high-risk processing, handling complaints, and imposing fines. However, some authorities have taken an expansive interpretation of the GDPR, going beyond the intent of the EU legislators. For example, although Article 48 of the GDPR clearly states it applies without prejudice to other legal grounds in Chapter V, it has been interpreted extensively as providing an exclusive basis for data transfers required to comply with a court order or other binding request. Additionally, we have seen data protection authorities making recommendations on political matters, such as requiring the use of sovereign cloud solutions based on legal constructs for certain sensitive data processing without assessing the technology or protection it provides to the data. This quasi-legislative approach from some authorities, without reasonable safeguards, threatens to fragment GDPR interpretation in ways that damages businesses and consumers across Europe. Ultimately, the European Commission is entrusted with proposing legislation which then goes through a rigorous legislative process. Allowing national authorities to issue conflicting interpretations undermines much-needed legal certainty. We urge the Commission to clearly delineate the parameters of national authorities' powers under GDPR. Their discretion should be exercised within a risk-based framework that protects privacy while supporting innovation. Efforts imposing unnecessary restrictions or lacking EU-wide consistency must be avoided.
Read full responseResponse to Update of list of sustainable biofuel feedstocks
2 Jan 2023
We appreciate the proposal to expand Annex IX. We believe that in order to achieve ambitious targets set by the European legislation more eligible and sustainable feedstock is required. At the same time expansion of the available feedstock pool may lower Europe's dependency on already imported materials and release pressure caused by market high demand. In the text below we would like to point to several identified issues. 1. Expanding the feedstock base in Annex IX part B should be followed by the elimination or increase of the annex IX part B cap. The same applies for the increase of sub-target for advanced biofuels and biogas if feedstocks are added to the list. 2. Avoid negative impact of reclassification of the feedstock which are already classified under Annex IX-A to Annex IX-B 3. Practical problems with implementation of certain aspects of delegated act - criteria not fit for use in food and feed chain; certification of damaged crops; intermediate crops definition, etc.. Further additional comments and more detailed reasoning is provided in the attached document.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
15 Dec 2020
K predloženému návrhu predkladá naša organizácia nasledovné podnety a komentáre:
Biopalivá
Podporujeme princíp, že Taxonómia EÚ by nemala byť v rozpore s cieľmi Európskej zelenej dohody na splnenie zvýšených klimatických ambícií EÚ. Zároveň by sme však radi poukázali na legislatívne rozpory a deficity v konzultačnom procese so zainteresovanými stranami:
Návrh delegovaného aktu je v rozpore s kritériami trvalej udržateľnosti, ktoré vyplývajú zo Smernice EPaR (EÚ) o podpore využívania energie z obnoviteľných zdrojov (ďalej len „smernica RED II“), ktorú v súčasnosti implementujú členské štáty. Navrhované kvalifikačné kritériá vychádzajú zo záverečnej správy vypracovanej skupinou technických expertov na udržateľné financie (TEG), ktorá nesprávne interpretovala kritériá trvalej udržateľnosti biopalív v RED II a vyvodila chybný záver, že RED II podporuje iba pokročilé biopalivá, t.j. biomasa, bioplyn a biopalivá, ak sú vyrobené z pokročilej suroviny uvedenej v časti A prílohy IX smernice RED II.
Jadrová energia
Jadrová energia zohráva nezastupiteľnú úlohu v dekarbonizačnom úsilí EÚ ako celku a predstavuje neoddeliteľnú súčasť jej energetického systému a energetického systému mnohých členských štátov. Chýbajúce posúdenie jadrovej energie v širšej perspektíve rôznych hospodárskych činností pri výrobe elektrickej energie predstavuje diskrimináciu jadrovej energetiky voči ostatným spôsobom výroby elektrickej energie. Chýbajúce posúdenie jadrovej energie tak predstavuje riziko významného narušenia trhovej súťaže v rámci energetického trhu EÚ. Trváme na tom, že predmetom posúdenia pred prijatím navrhovaného delegovaného nariadenia musia byť všetky relevantné hospodárske činnosti (v tomto ohľade predovšetkým v oblasti výroby elektrickej energie) s cieľom predísť narušeniu trhovej súťaže a vytvoreniu nespravodlivého konkurenčného prostredia voči niektorým spoločnostiam prevádzkujúcim jadrové zariadenia.
Oceliarsky priemysel
Cieľ presmerovania kapitálových tokov na pomoc pri vytváraní udržateľného a inkluzívneho rastu je možné dosiahnuť iba v prípade, že taxonómia udržateľného financovania EÚ zohľadní potreby odvetví, pre ktoré je proces dekarbonizácie obzvlášť náročný. Príkladom je oceliarstvo, ktoré si vyžaduje rozsiahle investície do rozvoja, demonštrácie, škálovania, a zavádzania nových nízkouhlíkových technológií v relatívne krátkom časovom období. Taxonómia udržateľného financovania by mala proces transformácie uľahčiť. Navrhujeme flexibilný prístup, ktorý zohľadní vývoj technológií a hodnotových reťazcov.
Výroba hydroenergie
príloha k návrhu delegovaného nariadenia pristupuje pri stanovovaní TSC diskriminačne k vodným elektrárňam, keď pre veternú a solárnu energiu nestanovuje žiadne špecifické TSC, ale pre vodnú energiu áno. Navrhujeme toto kritérium odstrániť.
Výroba vodíka
V časti 3.9. venovanej produkcii vodíka považujeme uvedené emisné kritériá v rámci TSC za málo zrozumiteľné. Žiadame ďalšiu prácu Komisie na vyjasnení TSC tak, aby jeho interpretácia bola jasná a ľahko zrozumiteľná. Zároveň by mala táto časť vhodne reagovať na Vodíkovú stratégiu EÚ a viac zohľadňovať možnosť nízkouhlíkovej produkcie vodíka
Zemný plyn
Zásadne nesúhlasíme so stanovením limitu 100 g CO2e/kWh emitovaných v rámci životného cyklu pre výrobu elektrickej energie z plynných a kvapalných palív. Navrhujeme zvýšiť navrhovaný limit emisií pri výrobe elektrickej energie, resp. kombinovanej výroby elektriny a tepla z plynných a kvapalných palív, ktorý je stanovený pre to, aby činnosť nebola považovaná za významne narúšajúcu cieľ znižovania zmeny klímy z hodnoty 270 g CO2e/kWh na 300 g CO2e/kWh (pri zdroji, nie za životný cyklus).
Nesúhlasíme s označením výroby bioplynu a biopalív pre použitie v doprave ako prechodnej činnosti.
Rekonštrukcia rozvodov tepla a chladu by nemala byť podmienená modifikáciou na nízkoteplotný režim.
Podpora výstavby distribučných sietí pre zemný plyn by mala byť povolená pre súkromné investície a komerčné úvery.
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
10 Dec 2020
Feedback to the Roadmap /Inception Impact Assement on the revision of the EEAG 2014-2020
We are mainly interested in guidelines 112, 113, 114 and 121 of the current EEAG, with regard to investment and operation aids granted to biofuels, some of which should be amended. The context under which the existing Guidelines were adopted is no longer valid The existing EEAG were drafted at a time where the ‘food versus fuel’ and ILUC debates were contaminating the biofuels discussions. Since then, all controversies surrounding European crop-based biofuels have been solved and explained.
There are no legal grounds to discriminate against sustainable biofuels, on the contrary
• Granting aid to biofuels that are sustainable within the meaning of Article 29 of RED II is fully justified. Member States should not refuse to financially support biofuels that are certified as sustainable, e.g. through differentiated taxation.
• Furthermore, discriminating between crop-based and advanced biofuels is not justified according to the EU’s Renewable Energy policy post-2020. The phase-out of policy support for crop-based biofuels in transport coupled, principle upon which the current EEAG are based, has been rejected by the co-legislators, first in the ‘ILUC Directive’ 2015/1513 and more recently in RED II. On the contrary, the co-legislators have renewed their support to all sustainable forms of biofuels.
• It would be inconsistent to have the RED II legislation supporting crop-based biofuels and the EEAG banning support to the same biofuels.
• Given that crop-based biofuels are the only immediate way to decarbonise transport and reduce our dependency on oil, given that supporting measures for biofuels are a prerequisite to counterbalance the massive subsidies that oil companies benefit from, abandoning support to crop-based biofuels would make it totally impossible for the EU to achieve the EU’s climate and energy goals, in particular the share of renewable energy in transport and non-ETS emission reduction targets.
We do not see any ground to rule out the possibility to grant operating aid for sustainable crop-based biofuels post-2020, in particular when support schemes aim at promoting the use of sustainable biofuels that would not otherwise be competitive with a supply or blending obligation only, and
• call the Commission to amend guidelines 113, 114 and 121 of the current EEAG. As per the opinion of the Commission on the Swedish tax exemption for higher biofuels blends, we do believe that that post 2021, the sole restrictions on operating aid for crop-based biofuels should be that
o they remain limited to the crop cap imposed by the RED II;
o operators must demonstrate compliance with the sustainability criteria;
o high-ILUC risk biofuels defined in the 2019 delegated Regulation on high ILUC-risk biofuels should not be eligible;
o they do not result in overcompensation, as is the case today.
• call for a continuation of investment aid for advanced biofuels as foreseen in existing guidelines 112.
Read full response25 Nov 2020
We don’t agree with extension of emissions trading to all fossil fuels combustion and related emissions.
Our arguments are following:
- Increased costs resulting from the administrative complexity of the ETS will be borne by the final consumers in the form of the increased bills for living;
- The member states will lose their options to influence national energy mix by national policies, because decarbonisation will be driven only by the price of carbon;
- The same level of carbon price for the whole EU will have negative impacts at households in countries and regions with lower economic performance;
- Some sectors from the ESR are hardly to decarbonise so the others will have to achieve the additional reduction.
Some of the above stated justifications are based on the European Climate Foundation study “Decarbonisation European transport and heating fuels – Is the EU ETS the right tool?”
https://europeanclimate.org/content/uploads/2020/06/01-07-2020-decarbonising-european-transport-and-heating-fuels-full-report.pdf
Addition building and road transport sectors to the emission trading would have little additional impact on emissions from these sectors, but would significantly increase living costs for poorer households. Low-income households are least able to invest in new technologies – either for cars or heating appliances – before the end of the life of their current investments. While waiting for these products to reach end-of-life, they will face substantially higher running costs for both heating and transport.
Including the building and transport sectors under the emission trading would increase households' heating costs by 30% and fuel costs by 16% by 2030.
Extending a single ETS to cover building and transport sectors would substantially alter the balance in the system. Since the demand for transport and heating fuels is relatively inelastic, other sectors would need to do more to compensate. By 2030, they would have to achieve an additional reduction of 250 mil. tons and by 2040 by 315 mil. tons. This would result in a reduction in competitiveness vis-à-vis competitors from third countries, as well as a reduction in production and staffing. A substantially higher ETS allowance price would be required in the short term than under the current ETS, which would impact on the competitiveness of all industries covered by the scheme.
These impacts were calculated with the current level of ambition (43% below 2005 levels), so with the higher ambition the negative impacts will be even worse.
Read full responseResponse to Updating the EU Emissions Trading System
25 Nov 2020
We don’t agree with extension of emissions trading to emissions from building and road transport or all fossil fuels combustion.
Addition building and road transport sectors to the emission trading would have little additional impact on emissions from these sectors, but would significantly increase living costs for poorer households. Low-income households are least able to invest in new technologies – either for cars or heating appliances – before the end of the life of their current investments. While waiting for these products to reach end-of-life, they will face substantially higher running costs for both heating and transport.Including the building and transport sectors under the emission trading would increase households' heating costs by 30% and fuel costs by 16% by 2030.
Extending a single ETS to cover building and transport sectors would substantially alter the balance in the system. Since the demand for transport and heating fuels is relatively inelastic, other sectors would need to do more to compensate. By 2030, they would have to achieve an additional reduction of 250 mil. tons and by 2040 by 315 mil. tons. This would result in a reduction in competitiveness vis-à-vis competitors from third countries, as well as a reduction in production and staffing. A substantially higher ETS allowance price would be required in the short term than under the current ETS, which would impact on the competitiveness of all industries covered by the scheme.
These impacts were calculated with the current level of ambition (43% below 2005 levels), so with the higher ambition the negative impacts will be even worse. Above mentioned claim is based on the European Climate Foundation study “Decarbonisation European transport and heating fuels – Is the EU ETS the right tool?”
https://europeanclimate.org/content/uploads/2020/06/01-07-2020-decarbonising-european-transport-and-heating-fuels-full-report.pdf
The study found this would have little additional impact on emissions from these sectors, but would significantly increase living costs for poorer households.
Read full responseResponse to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil
29 Oct 2020
The fact, that in the EU every year over 400 000 premature deaths are attributed to ambient air pollution, testifies that this particular problem is the most problematic one.
The use of solid fuels in small combustion sources for the production of heat and hot water can cause high emissions of pollutants, such as fine particulate matter (PM10, PM2.5), SO2, NOx, VOC and benzo(a)pyrene, with negative impacts on human health.
We believe that there is huge room for increasing air quality with replacing inefficient solid fossil fuel boilers with far more cleaner ones for natural gas. For example, in Slovakia we have approximately 120 thousand old highly-inefficient solid-fuel boilers in individual households (older than 30 years), that are the main cause of poor local air quality in Slovakia.
The Slovak republic can be characterized by the exceptionally high coverage of natural gas grid with high percentage of population connected to it, with the ambition to switch to green gases distribution such as the biomethane and hydrogen. This lays downs ways for improving air quality – boilers scraping schemes.
Different scraping schemes are or were in place in European countries (for example in Czech republic) with the aim to improve air quality. There should be possibility for this kind of schemes under the new Green Deal legislation to be funded from the public sources
Read full responseResponse to A EU hydrogen strategy
8 Jun 2020
Clean energy – strategy for energy system integration
Our association supports the proposed initiative of Commision.
In addition to the already stated aims and goals we would like to add following:
- Like RCF in case of fuels used in transport also hydrogen produced from nonrecyclable part of municipal solid waste should be mentioned and its usage should be supported as low emission solution.
- We would like to stress, that hydrogen produced from biomass has renewable character as well. EU should support all potential technologies able to produce renewable materials and not to focus just for one selected method. Technological neutrality as principle needs to be applied
Read full responseResponse to Strategy for smart sector integration
5 Jun 2020
Clean energy – strategy for energy system integration
Climate neutrality and the deep decarbonisation of EU’s economy requires a fundamental restructuring of cross-sectoral energy use. The positive aspect of the system integration is that it can combine the benefits of different energy systems to provide an efficient and fast way to achieve a sustainable low-carbon economy. It requires carbon neutral and carbon negative energy vectors, and increased interlinkages between energy carries and economic value chains: industry, mobility, heating and agriculture. The energy transition cannot succeed by policy measures that seek to decarbonise sectors in isolation of each other. A holistic and technology neutral approach for mature technologies, while fostering the development of commercially non-mature technologies, is primary for climate neutrality to be a success.
The risk of system integration can be the pursuit of a one size fits all solution for countries with fundamentally different starting points or a focus on a single energy system. It is therefore necessary to promote the possibility of a country specific approach and for maximum flexibility on a country level - thus to impose only a final goal on countries – goals for GHG reduction.
Technology neutrality could ensure that we do not remain dependent on a single energy system, which would need to be massively strengthened in the future in order to be able to cope with the increased demand.
It should also be noted that, among the various energy carriers, natural gas has the best-adapted infrastructure for energy storage in large quantities. This and other positive aspects of natural gas, such as the low intensity of greenhouse gas emissions compared to other fossil fuels, or the very small amount of pollutants emitted during its combustion, should be seen when planning the future of energy systems and their interconnections.
There are already technologies that can provide sector integration through natural gas, such as power-to-gas or fuel cells. In our view, gaseous fuels will continue to form the backbone of energy systems during their low-carbon transformation.
Energy system integration should promote the most cost-effective path towards carbon neutrality by 2050. To achieve this a variety of energy carriers are necessary. Energy system integration requires a level-playing field between electricity and gas to facilitate the transition towards renewable and decarbonised hydrogen, biomethane, biogas, synthetic methane and other sustainable fuels.
Also we see that decade of efforts to reach at least 10% RES and 6% GHG reduction in transport is still difficult target. The history of GHG emissions in transport says about still increasing trend. Technological possibilities to decarbonize trucks and ships are still limited. These are the reasons for including all transport as a hard-to-decarbonise sector.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
5 Jun 2020
The Renovation Wave initiative for public and private buildings
We recognize the importance of this initiative, which is opportunity for scaling up current renovation rates and bringing benefits for citizens and businesses, from consuming less energy to healthier homes, and saving money. However, the initiative should keep in mind that the principle of technological neutrality when selecting a type of heat source should be preserved. The different conditions, for example various degree of district heating development or gas distribution grid coverage, in European countries create different starting points. The Slovak republic can be characterized by the extremely high and modern coverage of natural gas grid with high percentage of population connected to it and the very developed district heating sector. This lays downs different way for renewable energy sources integration in Slovakia. Existing gas grids and gas appliances are 100% compatible with biomethane, and recent tests show that condensing gas boilers can accommodate blends of up to 20% hydrogen here-and-now, with just small adaptations to burners and combustion controls. With coal still representing a third of the EU energy mix for district heating, renewable and decarbonised gases have significant potential to curb emissions in that sector too.
Read full responseResponse to 2030 Climate Target Plan
15 Apr 2020
2030 Climate Target Plan
With regards the timing and the process of the 2030 target plan, we regret that they do not allow to take into account third countries’ NDCs submissions to the UNFCCC nor to assess thoroughly the full impact of the COVID-19 outbreak. These two aspects must be considered while increasing 2030 target, its achievability and implementation as well as the carbon leakage measures. We regret that the plan leaves an analysis of carbon leakage measures for a later separate initiative. An increased ambition requires a strengthened framework of carbon leakage provisions that need to be effective and urgently applied once the new target is endorsed. Measures to prevent carbon and investment leakage should address risks coming from direct and indirect carbon costs. Assessments indicate that with existing burden sharing between ETS/non ETS sectors, an increased ambition to 50% or 55% would have a significant impact on EU ETS market, with a reduction in available allowances by 1.2 and 1.8 billion. Without adjustments, that would translate in reduction of free allowances respectively by around 500M and 750M, which would more than nullify the 3 % auctioning/free allocation shares’ flexibility agreed in the recent ETS revision. Moreover, carbon prices are estimated to rise to levels around 50€-75€ by 2030 for an ambition at 50% or 55%.
The carbon leakage assessment needs to be a forward-looking, not the backward-looking mentioned in the assessment. The future potential needs to consider external factors (e.g. regulatory framework and availability and costs of energy and materials) that would allow to overcome the barriers. The plan needs to include proposals on regulatory framework and the abatement potential should not be used as an argument for reducing carbon leakage protection. The coming decade is a time when compliance costs are complemented by abatement costs for deployment of new technologies, which makes EU companies more vulnerable. We would like to stress that innovation will not follow a linear path and that the new technologies needed for the long-term climate neutrality objective will require time for being developed, up-scaled and implemented An accelerated pathway post 2030 could well be achievable when these prerequisites are sufficiently provided for.
The assessment needs to address the three priorities identified in the Masterplan for a competitive transformation of energy intensive industries, notably: measures to create lead markets for low carbon products, access to competitive low carbon energy and financing of breakthrough technologies. A burden sharing between ETS and non-ETS should be applied when the target is set. All sectors of the economy and society will need to contribute. It is crucial to untap the large potential e.g. in the buildings, agriculture and transportation. Simultaneously, we do not support the proposal to include in the existing EU ETS sectors resilient to carbon abatement such as transport since they would drive up the carbon price, with a major impact also on sectors exposed to international competition and carbon leakage risk.
Changing 2030 targets on short period directly contradicts the EU Regulation 2018/1999, which promotes long-term certainty and predictability for investors. Slovakia is likely to miss the 2020 target. There will be a big gap in target goals we need to overcome to reach proposed 2030 target. Overambitious goals can push some states to implement economically non-effective solutions to deploy high shares of renewables at any cost. It should be the highest priority to eliminate the use of GHG intensive solid fuels in the energy sector. Further decarbonization should follow this goal. Slovakia estimates it would need annual investments of 1.8% of GDP to reach 2030 climate target. With current outlook of economic recession there will be huge shortage of public resources decarbonization financing above the level of solid fuels elimination.
Read full responseResponse to Carbon Border Adjustment Mechanism
1 Apr 2020
CARBON BORDER ADJUSTEMENT
It is essential that a carbon border adjustment is implemented as a complementary measure in addition to existing carbon leakage provisions in the transition towards climate neutrality. This measure should be applied, in the form of the customs on the imported products. We strongly oppose any other form of tax, fee or any other financial burden levied on the domestic EU production.
• A carbon border measure aims to reach the combined environment objectives of the EU policy: reducing emissions, avoiding carbon leakage and complying with the costs of the cap & trade system. A complementary border adjustment would not lead to double protection. In fact, even with free allocation and compensation, EU producers bear carbon costs that are not applied to extra EU competitors.
• EU producers are subject not only to compliance costs for the difference between their emissions and free allocation and between indirect costs and compensation, but also to the full abatement costs that are necessary to develop the breakthrough technologies required to fulfil the emission reduction targets. A border adjustment replacing the existing carbon leakage measures would undermine their financial ability to invest in those technologies.
• While it is important to develop the border adjustment as soon as possible, its implementation should not lead to abrupt modifications of existing provisions in order to secure legal certainty for long term investment decisions. In particular, rules on carbon leakage measures for the period until 2030 have been adopted very recently and should not be modified.
• A carbon border measure implemented as a complementary instrument would also reduce the direct impact on trade flows and would mitigate trade tensions as it would provide a longer transition for negotiations with international partners to align climate ambition.
• Similarly, a border measure complementary to free allocation and indirect costs compensation would decrease the product price impact on downstream sectors within the EU.
• As long as it is uncertain whether a border measure may address the environmental and competitiveness concerns linked to EU exports in third countries, a border measure with full auctioning for EU producers would burden them with the full carbon costs, thereby undermining their ability to access export markets.
• If a carbon measure is implemented with full auctioning for some sectors, the legal framework will lead to significant distortions of competition against other sectors that are still largely shielded from the carbon costs through free allocation and indirect costs compensation.
• The use of the EU ETS (benchmark) methodology in the carbon determination methodology, is the fastest solution. At the same time, we call on the Commission to prepare the methodology for setting the amount of duty / charge and to link it to the EUA price. We do not support the development of a separate methodology for the determination of the carbon content of products as this would mean a considerable delay and prolongation of today's adverse situation
• It is clearly possible to design a WTO compliant carbon border measure that complements free allocation and indirect costs compensation in a transition period.
While a border adjustment based on the equivalent direct and indirect ETS costs can be an effective measure in the initial transition phase, a long-term regulatory framework is required for the advanced transition phase and the post-transition, i.e. when the breakthrough technologies reach sufficient market penetration and CO2-lean steel represents a critical mass of the market, but operation costs are still significantly higher than for competitors with CO2-intensive production. Such framework should be based on the actual CO2 footprint of the product over the entire lifecycle, requiring the development of a proper accounting system, both at EU level and at the border
Read full responseResponse to Revision of the Energy Tax Directive
30 Mar 2020
ENERGY TAXATION DIRECTIVE
Inception impact assessment
The following elements should be taken into account by the Commission (extended version of our statement is provided in the attached document):
Keep current exemptions: to keep the possibility of exempted or reduced level energy consumption taxation for those energy‐intensive businesses competing globally. Partial or full taxation exemptions applied on fossil fuel do not contribute to increase their consumption. We disagree with the abolition of the exemption from excise duty on natural gas. The measure will certainly increase the difference between the price of solid fuels in general and natural gas, resulting in a further increase in the number of solid-fueled households (in Slovakia 250 000 households are using nowadays solid fuels; from which 120 000 is using solid fuel boilers older than 30 years) and a further deterioration in local air quality.
Make optional exemptions mandatory: to avoid competition distortion amongst European industrial consumers, optional exemptions or reductions foreseen in the current ETD should become mandatory.
Set a taxation ceiling by category of consumers: today, Member States are free to introduce above the tax component, additional levies to support renewable energy production, which can in certain cases represent huge financial burden for energy consumers.
Treat outsourcing and insourcing of utilities on an equal footing: To avoid unfair distortion of competition between companies which have outsourced some activities and those which have not, exclusion of certain industrial processes from the taxation scope should be applied regardless of the plant set‐up.
Full exemption for CHP: to enforce a full exemption of general energy consumption taxation for high efficiency Combined Heat and Power (CHP) in order to promote energy efficiency by developing this highly efficient energy generation technology.
Non-avoidable energy use or emissions should be exempted: to focus on avoidable emissions or energy use (possibly in a harmonised fashion) when taxation aims to steer energy use or emissions toward a reduction
Promote renewable and alternative energy with tax exemptions: to ensure the development of renewable energy, by maintaining full exemptions or reduced energy taxation rates in the revised Directive, in particular for products produced from biomass and introduce new tax exemptions for secondary energy carriers and industrial waste in order to promote alternative and more ecological uses of those alternative fuels.
Any removal of exemptions or reductions shall be gradual, harmonized and evenly distributed over time. Although the removal of any distortions becomes the cornerstone of ETD revision, this step must not be implemented as a sudden political intervention.
Some exemptions or reductions should remain in force for the transitional period, while substantially justified by transitional needs in lower income Member States where their dependence on certain fossil fuels exists and transformation potential is limited.
Keeping the unanimity vote in the Council in energy taxation matters. The unanimity vote should be retained when deciding on energy taxes, instead of applying the rule on the qualified majority vote in the Council according to Art. 192 TFEU. It is hardly acceptable if the proclaimed goals would be achieved without existing consensus and sustained dedication of all Member States.
Read full responseResponse to Commission Implementing Regulation on the Modernisation Fund
16 Mar 2020
In the proposal of Implementing Regulation on the Modernisation Fund we recommend following changes and clarifications:
1. Please further clarify and define term „scheme“ in art. 4, par. 2.
2. In art. 12, par. 3, last sentence. Please add „and respective beneficiary Member State“ after word „Commission“.
3. In art. 14, par. 2 please add at the end of the last sentence „and beneficiary Member States“.
4. In art. 15, par. 1, please define in detail „relevant proposals“ to be made by the Commission.
Read full response