The German Association of Industrial Energy Consumers (VIK e.V.) welcomes the opportunity to provide feedback on the public consultation „EU climate target 2040.“ In our view, the achievement of the Climate Goal 2040 should not jeopardize the economic development, investment security, and cost-effectiveness of industrial production in Europe. It is also essential for energy-intensive companies to have access to affordable and cost-competitive prices for renewable energy and low-carbon fuels. Carbon leakage protection instruments should be extended to ensure the competitiveness of European companies in the global market.

Climate change mitigation is a global task; therefore, among other measures, it is important to consider the climate ambitions of other countries. In our view, stronger efforts should be undertaken by European climate diplomacy at the global level. To secure leadership positions for European industry going forward, it is important to establish common market mechanisms for the global GHG-emissions trading system, at least for the G20 countries.

Finally, EU member states should seriously consider the possibility of including negative emissions in the EU ETS, as well as establishing a reliable political framework for the development of CCU/S technologies.