Consultation Response – Roadmap for the EU ETS revision

On 26th November, Bellona Europa has shared its response to the Roadmap for the EU ETS Revision.

The EU ETS covers a range of sectors essential to the transformation towards a low-carbon, net-zero economy. The EU ETS must recognise Europe’s commitments under the Paris Agreement. The revision from 2016-2018 did succeed in ensuring some elements of alignment with the Paris Agreement. Bellona Europa believes that the EU ETS’s revised parameters must be designed carefully to ensure that the scheme robustly supports the rapid decarbonisation of the economy foreseen for the next 3 decades.

Main reccomendations:

  • Novel emission accounting principles, such as the accounting of emissions which are ‘avoided’ elsewhere, should not be included into the EU ETS.
  • The burning of fossil waste-based fuels or fossil waste should not be zero-rated. Avoided emissions should not be used to change the physical metrics within the EU ETS and the MRV Regulation (i.e., emission factors).
  • The EU ETS should continue to track all emissions at the point source. Avoided emissions should not be used to change the concept of when the CO2 is emitted, as is described in e.g., the CO2 storage Directive.
  • If CO2 or carbon are converted to a different product (e.g., plastics or fuel), the double counting of emission reduction must be avoided. Any methodology which allows for emissions created in EU ETS installations to exit the EU ETS without being accounted for should be prevented. Installations must be fully accountable for emissions generated under the EU ETS.

Find our consultation response as it follows:

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