To Glass for Europe, the reviewed criteria based on the carbon intensity and trade intensity of the sectors is appropriate to define risks of carbon leakage for Europe’s industrial sectors.
However, the methodology needs to be applied using appropriate statistics that match the ETS production and activities of sectors. In this spirit, the assessment of carbon leakage risk needs to be improved to better take into account the variety and complexity of sectoral realities.
The directive should allow for a sub-sector to request a quantitative assessment at a more disaggregated statistical level, i.e. PRODCOM-8 where justified and appropriate. In the flat glass sector for instance, NACE-4 includes both activities that are subject to ETS, i.e. basic flat glass production, and downstream activities that are excluded from the scope of ETS, like glass coating.
It results from this statistical mismatch that an assessment at NACE-4 consistently underestimates the effective risk of carbon leakage in the flat glass sector. Only PRODCOM-8 statistics allow a proper assessment in the flat glass sector, i.e. an assessment limited to ETS production and activities.
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