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

Aviation in the Emissions Trading Scheme: The impact of the 2012 ‘Stop the Clock’

The EU Emissions Trading Scheme (EU ETS) initially covered CO2 emissions from all flights to and from EU airports. However, in 2012, facing significant opposition and threats of a trade war, the EU revised the scheme to include only intra-EU flights, a move known as “Stop the Clock.” What is the cost of this scheme? How can it effectively reduce aviation emissions in the future?

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