Highly complex issues are leading to disagreements among individual Directorates-General—which must be resolved before the Commission as a whole can rally behind such a far-reaching proposal. As recently as June, the European Council emphasized that efforts to lower energy prices must be accelerated. This also applies to the energy transition and decarbonization, taking into account technology neutrality, as well as to strengthening our resilience. It calls on the Commission to address the concerns expressed by some industries regarding emissions trading benchmarks, while preserving the essential role of the EU ETS in the climate and energy transition.

Place much greater emphasis on EU competitiveness

It is far from clear how these differing demands can be reconciled. The goal is for all—or at least most—of those affected to accept the revision and for the EU ETS to remain the cornerstone of EU climate policy. This climate policy must take competitiveness into account much more strongly in the future than it has in the past, while at the same time reconciling it with climate protection goals.The competitive landscape in the EU has deteriorated significantly in recent years. Without a viable business case, necessary investments will continue to be lacking. In Germany alone, approximately 240,000 industrial jobs were lost in 2024 and 2025. Emissions trading is one of many factors making the overall situation difficult for industry. High energy costs, unfair international competition, excessive bureaucracy, and a lack of sufficient political will for reform are other key factors contributing to this situation.

Without access to the necessary renewable energy, renewable fuels—including green hydrogen—at competitive prices, as well as CO2 and other infrastructure, many players find themselves in a situation where they want to decarbonize but are unable to do so. CO2 costs then act as a penalty and can no longer serve as an incentive to invest in low-carbon and carbon-free processes and products.

CO2 pricing should remain part of the policy mix in the future

At the same time, it is important not to devalue the investment decisions of those who, in good faith, planned their investments based on the assumption that ambitious targets would be achieved as intended by policymakers, with a rising ETS price. The upcoming revision must, in a sense, square the circle—future emissions trading must strike a balance between the two spheres briefly outlined above. Investments already made must not be devalued; in other words, a credible price signal must be maintained. At the same time, exorbitant CO₂ costs must be addressed as long as there are no economically viable CO₂-free alternatives due to a lack of necessary prerequisites. Free allocation must be maintained until sufficient conditions for the transition are in place.

The EU should continue to advocate for ambitious global climate action and a global level playing field through internationally coordinated measures. Unilateral measures, such as a geographic expansion of the ETS¹ to include aviation, however, undermine ongoing initiatives for international climate action and weaken the competitiveness of European companies. An expansion would further increase cost pressures on Europe as an aviation hub and accelerate the ongoing shift of flights to the MENA region, where less ambitious environmental, social, and safety standards apply.
The BDI calls on all political stakeholders involved in the process to strengthen the competitiveness of our companies through a pragmatic and sustainable further development of emissions trading.