Read our EU ETS response

Read our Innovation Fund response

Our main messages:

  • Simplify the EU ETS by phasing out free allocation

  • Aviation: put a seat belt on EUA supply

  • Free allocation: switch from process to products

  • Link indirect cost compensation to carbon-free electricity only

  • Reform the Innovation Fund to:
    – Better assess the carbon footprint of electricity use
    – Reserve grants to technology risk
    – Reserve scale-up subsidies to poorly capitalised sectors

  • Market Stability Reserve: reduce the reinjection rate as well as thresholds

  • Keep carbon removals out of the ETS

  • Do not shift CCU carbon accounting down value chains

  • Limit linking with other ETS

Read our responses on the European Commission’s website: 

Related publications

More on the EU ETS and climate financing

Simulating CDR in the EU ETS: The Risks of Premature Integration

Simulating CDR in the EU ETS: The Risks of Premature Integration

Sandbag has developed an ‘ETS + CDR simulator’ to help visualise and explore the impact that CDR integration could have on the ETS, assess the demand it could create for CDR, and highlight the potential consequences of this demand. This report uses the simulator to explore how different integration pathways could affect emissions reductions, carbon prices, and potentially lead to negative externalities.

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