VIK German Association of Industrial Energy Consumers welcomes the opportunity to provide feedback on the Communication of the European Commission on the EU climate target for 2040.

In our view, a successful industrial transformation towards climate neutrality requires the following framework conditions: time-bound roadmap and achievable targets, improved energy security conditions including competitive energy prices and a stable economic environment as well as an unbureaucratic government financial support and funding for companies to invest in long-term low-carbon projects, complemented with effective measures on carbon leakage protection and unfair international competition.

From our perspective, the proposed target of a 90% net reduction in greenhouse gas emissions by 2040 compared to 1990 levels is highly ambitious and requires a clear implementation plan that assesses whether the legislation put in place will contribute to achieving the targets and takes into account the needs of energy-intensive industries in the context of current economic, social and geopolitical developments.

Ensuring that climate targets are achieved must be balanced regarding the expense of slowing or stagnating economic development and must have a global focus. Investments in climate mitigation must take place where they are most effective and should not lead to the relocation of energy-intensive companies to third countries outside the EU.