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DSM key messages on emission trading (ETS) in the EU

DSM supports the EU’s Climate Change agenda

  1. DSM supports and contributes to the efforts to address climate change by reducing the emission of greenhouse gases (GHG). To that end we have set ourselves ambitious targets for the reduction of N2O emissions (>40% in 2010 and >80% in 2020 compared to 2005) and for CO2 emissions by improving the energy efficiency (2% improvement per year) for our operations worldwide.
  2. DSM supports the principle of a fully harmonized EU-ETS that provides strong economic incentives for reduction of GHG emissions and, at the same time, preserves a global level playing field and drives innovation for more sustainable manufacturing, products and services.

ETS should provide economic incentives for emission reduction while enabling cost-effective clean production in Europe

  1. DSM recognizes that auctioning of emission allowances effectively includes GHG emissions costs in products thereby providing an economic incentive for reduction.
  2. DSM welcomes the EU’s recognition that sectors which are exposed to international competition cannot incorporate CO2 costs in sales prices, as long as there are no comparable carbon price signals in other global regions. We welcome the Commission’s proposal for measures to protect exposed sectors from unfair competition from outside the EU, thereby preventing new and replacement production capacity being allocated outside the EU (the so-called ‘carbon leakage’).
  3. The exposure of the chemicals’ sector to international competition should be recognized as soon as possible to secure our investment potential. The sector should be included in ETS with free allocation of emission rights based on efficiency benchmarking. The indirect effect of increased electricity prices due to inclusion of CO2 costs should be taken into consideration as well.

Allocation of emission allowances based on benchmarks will do a better job

  1. For meeting reduction targets while enabling cost-effective clean production in Europe, DSM promotes the use of EU-wide harmonized product benchmarks for the allocation of free allowances. The standards will gradually be reduced over time to bring down the total emissions according to the EU policy, guaranteeing to meet the overall emission cap. Allocation should include the emission due to the use of electricity taking into account efficiency. As a result the EU will develop as ‘the place to be’ for efficient producers, whereas inefficient production is discouraged, which fits the EU’s Lisbon strategy.
  2. DSM opposes the alternative of border adjustments as they may lead to retaliatory actions and runs counter to the principle of free trade. Border adjustments are judged to be ineffective as complex value chains are involved, which would lead to a huge bureaucracy.
  3. DSM is of the opinion that industry should be responsible to bring forward reliable product benchmarks and monitoring information, under supervision of the EU Commission.

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