The German association of industrial energy consumers (VIK e.V.) welcomes the opportunity to provide feedback on the Proposal on establishing measures for strengthening net-zero technology products manufacturing ecosystem in the European Union.

In our view, the proposed regulation should take into account that energy-intensive sectors and the related value chains play a fundamental role in the European industrial structure: the maintaining of their competitiveness is crucial to enable net-zero technologies development, manufacturing and deployment. The NZIA fails to recognize that energy-intensive sectors provide essential primary products and raw materials for the manufacturing of the addressed “strategic” climate-neutral technologies. Additionally, NZIA should consider as a key priority the availability of cost-competitive low carbon energy for industrial consumers. Therefore, the EU should give a strong answer to the current initiatives on low-carbon technology subsidising which take place in developed countries, considering the competitiveness aspects. Concrete incentives to boost the transformation of the existing industry in Europe are needed.

This position paper focuses on the following aspects of the proposed regulation:

• List of strategic net-zero technologies
• Proposed benchmark of the annual deployment needs
• Low-carbon markets and green leakage
• Financing aspects and government support for low-carbon technologies in other countries