Response to the Commission’s EU ETS reform proposal of 15 July 2015

In line with the October 2014 European Council Conclusions1, Carbon leakage prevention needs to be the first element of the ETS revision. It should be based on technically and economically achievable benchmarks, on actual production, and addressing both direct and indirect carbon costs. The most efficient European installations must be guaranteed access to enough free allowances in order to operate and even grow at no net carbon cost.