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.

read more
In or Out: What’s best for carbon removals and the EU ETS?

In or Out: What’s best for carbon removals and the EU ETS?

What will the future of the EU Emissions Trading System (ETS) look like as the emissions cap heads towards zero? Is integrating carbon dioxide removals (CDRs) into the ETS a solution to help the EU achieve its climate goals? Or would they compromise the integrity and functioning of the system? These questions are at the forefront of the Commission’s mind as they review different options for the future of the ETS ahead of the 2026 revision.

read more
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