Stanowisko Związku Pracodawców Polska Miedź w sprawie konsultacji dot. zmian klimatu – aktualizacja unijnego systemu handlu uprawnieniami do emisji (ETS)
Lubin, 26 November 2020
ZPPM / 141 / XI / 2020
Directorate-General for Climate Action
Units B1 (EU ETS Policy Development and Auctioning) and B3 (International Carbon Market, Aviation and Maritime)
Rue de la Loi / Wetstraat 200
Konsultacje publiczne: Ref. Ares(2020)6081850 – 29/10/2020
Stanowisko Związku Pracodawców Polska Miedź w sprawie konsultacji dot. zmian klimatu – aktualizacji unijnego systemu handlu uprawnieniami do emisji (ETS).
The Polish Copper Employers’ Association position paper on Amendment of the EU Emissions Trading System (Directive 2003/87/EC) – COMMENTS ON THE INCEPTION IMPACT ASSESSMENT (IIA)
Konsultacje publiczne aktualizacji przepisów dot. unijnego systemu handlu uprawnieniami do emisji (ETS) (Dyrektywa 2003/87/EC)
Proposal for a directive – Inception impact assessment – Ref. Ares(2020)6081850 – 29/10/2020 – Amendment of the EU Emissions Trading System (Directive 2003/87/EC)
The Polish Copper Employers’ Association (former Employers’ Organization of Polish Copper) (Związek Pracodawców Polska Miedź) was established in 1996. We are the biggest, independent and not-for-profit regional employers’ organization whose goal is to represent and protect employers’ interests. We welcome a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make it the world’s first climate neutral continent.
As the representative of the Polish metals mining, processing and smelting industry, we welcome the Commission’s renewed EGD Strategy for Adaptation to Climate Change as a part of actions for a greener and cleaner economy. We are committed to substantially contribute to climate change adaptation. We also believe that an updated Strategy for Adaptation to Climate Change should focus both on prioritizing policy areas and actions where EU interventions can be most effective as well as on assessing how to increase ambitions in a manner that best contributes to sustainable growth and enhances economic competitiveness.
The EC report “A Clean Planet for All” shows that raw materials are indispensable enablers for carbon-neutral solutions. Copper is a key material for the energy transition facilitating GHG emission reductions in numerous other sectors, from renewable energy generation, through energy efficient end-use appliances to electrified transport, heating and cooling systems as well as smart engineering, buildings and computer grids. It is also a key material in battery production, so its contribution to the new EU climate policy is significant and indispensable to meet the Green Deal goals, Europe needs a strong, competitive industry.
As stated in the study “Metals for a climate neutral Europe” the European non-ferrous metals (NFM) sector’s strategic status and globally-set pricing mechanisms means it faces high international competition:
- Europe is already highly dependent on imports of primary raw materials, with other value chain stages under pressure;
- China’s share of NFM production has grown dramatically in the last 15 years, largely based on coal-powered electricity.
This makes the threat of EU production being replaced by more carbon-intensive non-EU production very real, despite the fact that Europe’s metal producers are switching to clean electricity more than any other energy-intensive industry as one of the world’s leading environmental champions. Today, China accounts for 30 to 54 % of world demand for all base metals. The growing European demand for copper and copper products also causes a large (about 23% in recent years) increase in the import of finished products from this metal. Recently in its Conclusions the Council highlighted that achieving strategic autonomy while preserving an open economy is a key objective of the Union in order to self-determine its economic path and interests and recalled that this includes identifying and reducing strategic dependencies and increasing resilience in the most sensitive industrial ecosystems and specific areas. Today’s COVID-19 epidemic clearly shows the relevance and accuracy of this statement.