CIFF feedback on: Revision of the benchmark values for free allocation of emission allowances (2026-2030)

The Finnish chemical industry is committed to achieving climate neutrality by 2045 and supports the EU Emissions Trading System as a key, long-term and cost-efficient instrument for driving emission reductions. At the same time, it is essential to ensure that industrial competitiveness is preserved and that effective carbon leakage protection remains in place throughout the transition.
Benchmark values should be realistic and based on technologies and processes that are sufficiently available and deployable across EU industry. For example, the proposed reductions in fallback benchmarks for heat and fuel seem to be disproportionate compared to the actual decarbonisation potential of energy-intensive industries in Europe. Non-realistic reductions increase the risk of carbon leakage and weaken the capacity of industry to invest in decarbonisation, rather than reducing global emissions.
We call for a realistic methodology for setting benchmarks that maintains a sufficient level of free allocation to ensure effective carbon leakage protection.
In addition, an EU-wide cost compensation scheme is needed to address indirect carbon cost impacts across Europe.

