Fit-for-55: Fit for industry?
investigated in the test phase to find appropriate remedies. Prior to starting this test phase extended diplomatic efforts are necessary to explain the EU´s move in detail to our trading partners. ▪
The calculation method presented in Annex 3 for determining emissions raises severe concerns regarding data quality and data availability. Default values should be set based on the most carbon-intensive production process.
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Too many important aspects of the proposal remain subject to future delegated acts.
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A WTO-compatible mechanism to tackle exports should be introduced.
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A review clause should be introduced to allow accommodating the result of international discussions and Climate Clubs.
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An obligation to preserve the functioning of the internal market should be introduced considering that national solo-runs of national competent authorities remain possible and likely.
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Revenues from CBAM should be reinvested in climate innovation in affected sectors rather than be channelled into the general (EU or national) budget(s).
5. Proposal for a revised Energy Taxation Directive (ETD) The BDI supports the revision of the ETD to ensure clear taxation rules for energy products and electricity to contribute to the smooth functioning of the internal market and to avoid distortion of competition. In view of tackling the climate and environmental-related challenges within the Green Deal, the BDI welcomes that the ETD supports the development of alternatives energy products and electricity and continues to recognize the need to support the European energy intensive business. The introduction of a fixed taxation scheme by environmental performance is seen as a good tool to recognise the climate contribution of energy products under the condition that negative effects and market distortion can be avoided. The concept of the fixed taxation scheme must assure a harmonised low taxation of electricity and alternative energy products. Competitive energy prices must be guaranteed for energy-intensive businesses. The aviation and waterborne navigation sector must be exempted from taxation due to international constraints and a different model for financing of their infrastructure. According to the proposal, however, energy taxation would serve to control consumption and generate additional fiscal revenues, rather than have any steering effect in terms of climate neutrality. As a result, a further increase of energy prices in addition to already existing burdens stemming from other regulations can be expected, which will hinder the transformation to greenhouse-gas neutral production schemes. This in turn risks new debates around energy taxation exemptions and energy price compensation, in particular considering current energy price spikes.
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