SOLER group
Le Groupe SOLER est un pionnier de la production de carbone renouvelable et un acteur majeur du développement de bioraffineries à partir de pyrolyse.
ID: 075468249655-25
Lobbying Activity
Response to EU emissions trading system - update of Activity Level Changes Regulation
9 Jan 2025
Summary: We commend the proposed reform of the Activity Level Change Regulation (ALCR) as it is key for promoting climate-friendly and competitive production of critical raw materials such as silicon, manganese, and other ferroalloys. Establishing a level playing field for low-GHG technologies in heavy industries has been identified as essential for achieving climate neutrality, as outlined in the revised EU ETS Directive enacted on 23 May 2023. SOLER has previously contributed to this discussion by participating in the consultation on the reform of the delegated regulation for harmonized free allocation of emission allowances (FAR) in January 2024. Our submission emphasized the role of biocarbon as a renewable substitute for fossil reducing agents. While the revised FAR (enacted 30 January 2024) created a level playing field for biocarbon use in some industries, it left significant gaps. For instance, electric arc furnace based silicon and ferroalloy production, which are not covered by a product benchmark, receive free allocations based on historical fossil CO2 emissions. Without an appropriate reform of these allocation rules, the use of biocarbon and other GHG abatement strategies will reduce this historic reference level and lead to a loss of free allowance allocation. This increases the cost of clean compared to fossil-based production methods and thus hampers the industrys transformation to competitive climate neutrality. Furthermore, the FAR did not establish a level playing field for the production of biocarbon as a renewable substitute to coking coal, which is subject to a product benchmark that does not cover and thus discourage the production of biocarbon as a climate friendly alternative. The proposed ALCR partially addresses these gaps by incentivizing greenhouse gas (GHG) reduction strategies in silicon and ferroalloys production, making it an essential step towards climate neutrality and competitiveness of these industries. However, further reforms to the FAR are necessary to fully support biocarbon production and use across industries. We therefore support adopting the proposed ALCR as published for consultation and offer additional insights and recommendations to ensure the EU ETS framework provides sustained support for biocarbon production, helping Europe achieve its climate neutrality, competitiveness, and strategic autonomy goals.
Read full responseMeeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra) and #SustainablePublicAffairs
22 Feb 2024 · Sustainable biocarbon and biochar
Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55
2 Jan 2024
To enhance the climate neutrality of industrial processes under the EU ETS Reform, it is essential to adapt the product definitions and emission benchmarks for certain technologies. This submission proposes amendments to the draft regulation on the update of free allocation rules (FAR), advocating for the recognition of sustainable biocarbon as a renewable alternative to fossil carbon and coke. Specifically, in the production of silicon metal and ferroalloys, where replacing fossil carbon feedstocks with renewable carbon is vital for achieving climate neutrality, it is crucial to establish equitable free allocation allowances irrespective of feedstock or production processes. The SOLER group advocates that sustainably produced biocarbon is acknowledged as a substitute for coking coal, a critical raw material yet a significant GHG emitter. Moreover, a level playing field for the production and use of biocarbon and coke must be assured. Our proposals align with Europe's goals for climate neutrality, emphasizing the importance of coherent policies that support both the Critical Raw Materials and the Net-Zero Industry Act.To enhance the climate neutrality of industrial processes under the EU ETS Reform, it is essential to adapt the product definitions and emission benchmarks for certain technologies. This submission proposes amendments to the draft regulation on the update of free allocation rules (FAR), advocating for the recognition of sustainable biocarbon as a renewable alternative to fossil carbon and coke. Specifically, in the production of silicon metal and ferroalloys, where replacing fossil carbon feedstocks with renewable carbon is vital for achieving climate neutrality, it is crucial to establish equitable free allocation allowances irrespective of feedstock or production processes. The SOLER group advocates that sustainably produced biocarbon is acknowledged as a substitute for coking coal, a critical raw material yet a significant GHG emitter. Moreover, a level playing field for the production and use of biocarbon and coke must be assured. Our proposals align with Europe's goals for climate neutrality, emphasizing the importance of coherent policies that support both the Critical Raw Materials and the Net-Zero Industry Act. For further details, please see the attached document.
Read full response