Position Papers

01/12/2020 Position Paper

Joint letter on the inclusion of sustainable renewable fuels in the EU mobility legislation

The signatories of this joint letter represent a crucial part of the automotive, fuel, energy industry and civil society in Europe, i.e. a combined force behind the transformation of mobility towards...

23/10/2020 Position Paper

FuelsEurope position on reducing greenhouse gas (GHG) emissions in shipping

Shipping is the backbone of international trade and commerce and an indispensable driver of EU prosperity. At the same time, maritime transport was responsible for the emission of 1,076 million tonnes...

23/10/2020 Position Paper

FuelsEurope position on regulatory options to promote a faster deployment of sustainable aviation fuels (SAF) in the EU

Since aviation is primarily a global industry, global commitments are preferred over regional initiatives to ensure the competitiveness of the aviation sector and its supply of fuel. The unprecedented...

05/10/2020 Position Paper

FuelsEurope’s position paper on Review of the Energy Taxation Directive

1.1 A reform of fuel and energy taxation is supported as enabler for very low or zero taxation for low carbon fuels and energies and to ensure a level playing field for all energy sources used. 1.2...

08/07/2020 Position Paper

FuelsEurope comments on the Hydrogen Strategy – July 2020

FuelsEurope recently published its Clean Fuels for All pathway, describing how the transport sector could to contribute to the EU’s climate neutrality ambition by 2050. With this pathway the refinin...

25/06/2020 Position Paper

Clean Hydrogen Letter to VP Timmermans

Reaching climate neutrality by 2050 in the EU will require the right regulatory framework for scaling up clean technologies to reach deeper emission cuts. Clean hydrogen will play a key role in this p...

10/06/2020 Position Paper

FuelsEurope’s response to the EU’s recovery plan from the Coronavirus emergency: a call for a climate-neutral, resilient and socially just economy

FuelsEurope, representing the EU refining and marketing industry, welcomes the Recovery Plan published by the European Commission on the 27th of May. We recognise that the Covid-19 crisis has put our...

27/05/2020 Position Paper

The European Recovery Plan has an essential role to play in shaping the right policy framework to unlock major scale investments in low-carbon technologies

FuelsEurope welcomes the publication of “Europe’s moment”, the European Recovery Plan, by the European Commission today. John Cooper, FuelsEurope’s Director General said, “The Covid-19 crisi...

13/05/2020 Position Paper

A New Industrial Strategy for Europe and the Circular Economy Action Plan – A New Way to See the EU Industrial Value Chains

FuelsEurope supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050, and welcomes the publication of the new Industrial Strategy for Europe and the Circular Ec...

20/04/2020 Position Paper

Response to the inception impact assessment: “Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy”

FuelsEurope (representing the EU refining sector) and IOGP (the International Association of Oil & Gas Producers) welcome the EU’s efforts to establish a sustainable finance framework that unloc...

28/01/2020 Position Paper

Heating with liquid fuels – The potential for liquid fuels to contribute to the EU´s energy and climate policy

A life without heating oil is unthinkable for around 20 million households in the EU. These homes are currently using oil to heat their homes and their water, while new liquid fuel replacements are be...

20/01/2020 Position Paper

Europe’s Industry united for an inspiring future

The critical challenges that Europe faces today call upon EU policymakers and industry to work together more closely than ever before, acting as partners to ensure Europe’s social, environmental and...

26/11/2019 Position Paper

Industry4Europe’s Joint Paper: ‘A long-term strategy for Europe’s industrial future: from words to action’

European industry is everywhere in our daily life: from the houses we build, the furniture we buy, the clothes we wear, the food we eat, the healthcare we receive, the energy and means of transport we...

18/09/2019 Position Paper

Joint Statement for an Ambitious Horizon Europe Programme

We, the undersigned 93 European associations representing key European research & innovation stakeholders, hereby urge the EU Institutions to make research, development and innovation(RD&I) a...

24/04/2019 Position Paper

Industry view for the revision of the benzene OEL

In 2017 the Commission launched the process to revise the current EU-wide occupational exposure limit for benzene (1 ppm). Today the EU Commission is looking at the feasibility of several possible sce...

21/12/2018 Position Paper

FuelsEurope – Position Paper EU Emission Trading Scheme: Compensation for indirect emission costs

In the absence of global climate policies with a comparable ambition level to the EU ETS, and because of the strong exposure to international competition2, it is essential to compensate the refining s...

12/11/2018 Position Paper

FuelsEurope Position Paper – Sustainable Finance: Regulation on a framework to facilitate sustainable investments

The Sustainable Financepackagelaunched by the Commission aims to make sustainability considerations part of financial decision-making in order to enhance the efforts to fight climate change and addres...

12/11/2018 Position Paper

FuelsEurope & UKPIA – Brexit Position Paper Presenting the European refining industry’s position on critical Brexit areas

The refining industry is a key sector for the EU, supplying vital petroleum products used in road transport, aviation, marine and heating fuels, for power generation and feedstocks for the petrochemic...

13/03/2018 Position Paper

FuelsEurope Position Paper – The petroleum industry’s human health workplan: a pragmatic approach to REACH delivery, avoiding excessive animal testing

This paper addresses the issue of the validity of the petroleum industry’s current datasets in its REACH Registrations dossiers regarding human health. The sector believes it is paramount regulators...

13/03/2018 Position Paper

Clean Energy negotiations final stretch: How can the final deal secure Energy Intensive Industries’ competitiveness?

Significant progress has been achieved by co-legislators towards adopting a Clean Energy policy framework for the period towards 2030. During the final stretch towards achieving an agreement, the Alli...

04/12/2017 Position Paper

FuelsEurope – Recommendation on the WFD revision ahead of trilogue (Waste Oils)

The European Parliament report on the WFD revision, adopted on 13 March 2017includes provisions mandating an unconditional separate collection of waste oils as well as the achievement of an 85% regene...

20/10/2017 Position Paper

Position Paper – Governance of the Energy Union

FuelsEurope welcomes the Commission’s proposal on the Governance of the Energy Union as the policy instrument to create an appropriate framework for the EU’s energy transition in the coming decade...

26/09/2017 Position Paper

Recommendations from the Alliance for a fair ETS ahead of the October trilogue meeting

We, the 17 signatories of this paper, energy-intensive sectors representing about 2 million jobs in the EU and comprising many SME’s, are fully committed in taking our share of responsibilities and...

16/06/2017 Position Paper

Joint Statement on the methodology to derive suitable BAT-AELs ranges

In principle, the upper end of the range should be set on the basis of the maximum observe demissions of the plants applying generally applicable BAT for the pollutant at stake, while the lower end sh...

08/06/2017 Position Paper

Position Paper on Renewable Energy Directive II

FuelsEurope welcomes the Commission’s proposal on the Renewable Energy Directive II (RED II) as the policy instrument to promote the use of renewable energy in the electricity, heating & cooling...

08/06/2017 Position Paper

Position Paper on Vehicle efficiency standards post-2020

FuelsEurope is of the opinion that the EU’s transport greenhouse gas (GHG) reduction policy should be holistic, and include in addition to lower carbon fuels and vehicles, traffic demand, infrastruc...

17/03/2017 Position Paper

FuelsEurope Position Paper on implementing measures development by IMO on the global sulphur cap introduction as of 1 January 2020

On 27 October 2016 IMO’s 70th Marine Environment Protection Committee (MEPC) confirmed to implement the 0.50% wt. global sulphur limit outside of Emission Control Areas (ECAs) as of 1 January 2020....

14/11/2016 Position Paper

FuelsEurope – Position Paper on 2017 REACH REFIT Review

The sector is committed to complying with the requirements of REACH and continues to take all necessary steps to achieve timely REACH implementation and compliance, through its role in generating addi...

16/03/2016 Position Paper

FuelsEurope – Position Paper Transport and GHG reductions

Affordable mobility is a key contributor to the quality of life of European citizens and is intrinsically linked to economic growth. While alternative technologies are increasingly used in transpor...

16/03/2016 Position Paper

FuelsEurope – Position Paper Better Regulation

As an active stakeholder in the policy making process, whose work is driven by robust scientific and evidence‐based input, FuelsEurope are hopeful that the proper implementation of the Better Regula...

09/11/2015 Position Paper

FuelsEurope Position on EU ETS Reform

FuelsEurope represents with the EU institutions the interest of 42 companies operating refineries in the EU. Members account for almost 100% of EU petroleum refining capacity and more than 75% of EU m...

27/10/2015 Position Paper

FuelsEurope position paper on REACH and the Refining industry

The Petroleum Refining Industry is a key sector for the EU, fuelling more than 90% of transport and supplying vital products for many other areas of the economy. 140,000 people are directly employed o...

27/10/2015 Position Paper

FuelsEurope Position Paper on REACH: Annex I – SVHC Roadmap

The European Commission developed a plan for the evaluation of substances. This so-called ‘Roadmap for SVHC identification and implementation of REACH risk management measures from now to 2020’, a...

08/10/2015 Position Paper

Climate Change: a critical challenge calling for a global response

Answering the growing global demand for energy while at the same time limiting the emission of greenhouse gases is one of the most critical challenges of our time. The EU refining industry can contrib...

08/10/2015 Position Paper

FuelsEurope Position Paper on Climate Change

Answering the growing global demand for energy while at the same time limiting the emission of greenhouse gases is one of the most critical challenges of our time. The EU refining industry can contrib...

29/07/2015 Position Paper

FuelsEurope Position Paper on REACH and the Refining Industry

The Petroleum Refining Industry is a key sector for the EU, fuelling more than 90% of transport and supplying vital products for many other areas of the economy. 140,000 people are directly employed o...

29/07/2015 Position Paper

FuelsEurope Position Paper on REACH: Annex I – SVHC Roadmap

The ‘Roadmap for SVHC identification and implementation of REACH risk management measures from now to 2020’ agreed by the Council of Ministers end 2012, provides an EU-wide commitment for having a...

29/07/2015 Position Paper

FuelsEurope Recommendations on the Review on the Compulsory Stock Obligation Directive

Directive 2009/119/CE deals with strategic stock obligations. It foresees that Members States have to maintain minimum stock of crude oil, unfinished and/or finished products (gasoline, diesel, jet fu...

27/04/2015 Position Paper

Strategic choices for ETS post-2020: allow Energy Intensive Industries to be competitive and grow in Europe

The Alliance of Energy Intensive Industries, representing over 30.000 European companies and 4 million jobs, wishes to be an active contributor in the upcoming revision of the EU ETS. This paper conta...

07/02/2015 Position Paper

FuelsEurope recommendations on Energy Union

The launch of the European Energy Union is a very welcome initiative, and FuelsEurope is looking forward to contributing to the process led by the new European Commission. Today more than ever, secure...

29/10/2014 Position Paper

Europe’s payment users call for transparent card fees

The European Payment Users Alliance represents businesses and consumers across Europe. Our message for Europe’s politicians: we need an interchange fee regulation, which is transparent and harmonise...

16/10/2014 Position Paper

Industry proposals for improvement of BAT information exchange

The members of the Industrial EmissionsAlliance welcome the initiative of the EU Commission, the German Ministry for the Environment and the German Environmental Agency to discuss the BAT information...

29/09/2014 Position Paper

Joint FuelsEurope-ACEA position on the intention of France to introduce B8 diesel

Following the intention of France to introduce B8 diesel on the French market, ACEA, representing the European automobile industry, and FuelsEurope, representing the European petroleum refining indust...

09/07/2014 Position Paper

We need urgent action on card fees, say Europe’s payment users

The European Payment Users Alliance represents businesses and consumers across Europe. We have a simple message for Europe’s politicians: we need the interchange fee regulation as a matter of urgenc...

05/06/2014 Position Paper

FuelsEurope Position Paper on the EU Air Policy Package

The EU refining industry supports the principle of seeking cost-effective solutions to improve air quality. However, the high ambitions proposed by the Commission’s CAPE1 will lead the industry to t...

21/02/2014 Position Paper

FuelsEurope`s statement on Energy Taxation

FuelsEurope’s views on energy taxation are summarized below. They are intended to contribute to a balanced discussion on the principles that should be considered when deciding how to revise the taxa...

21/02/2014 Position Paper

FuelsEurope’s Recommendations on the 2030 Energy and Climate Policies

Executive Summary The framework package for energy and climate to 2030 proposed by the Commission clearly identifies Europe’s competitiveness as an important success factor but still leaves many con...

11/02/2014 Position Paper

FuelsEurope Response to the public Consultation on the draft Guidelines on Environmental and Energy State Aid for 2014-2020

FuelsEurope welcomes the Commission’s intention to modernize EU State Aid rules and to award aid in a more cost effective way. We believe it is of the upmost importance to create a Single Market for...

01/12/2013 Position Paper

Joint Industry Statement on the EU Air Policy Review

Industry is deeply concerned by aspects of the upcoming EC proposals in the Air Policy Review, in particular the proposed level of ambition for emission reduction targets (so-called “75% gap closure...

01/10/2013 Position Paper

Response to Commissioner Potočnik’s comments on the EU Air Policy Review

Industry needs a predictable and realistically achievable set of measures;we therefore urge EU policy makers to set the ambition levels of the future air policy framework so that they remain consisten...

01/10/2013 Position Paper

The Alliance of Energy Intensive Industries: Carbon leakage protection for EU industry is under threat

The Alliance of Energy Intensive Industries, representing over 30.000 European companies and 4 million jobs, is extremely worried about the instability in the EU regulatory framework for climate actio...

01/07/2013 Position Paper

EUROPIA Position on the EU 2030 framework for climate and energy policies

This document presents EUROPIA’s (representing the European Petroleum Industry) contribution to the debate about the 2030 framework for climate and energy policies....

01/01/2013 Position Paper

EUROPIA Position Paper on Biofuels & ILUC

Following the Commission proposal to amend the Renewable Energy Directive (RED) and the Fuel Quality Directive (FQD), published on 17 October 2012, EUROPIA would like to continue contributing to the p...

01/11/2012 Position Paper

Position of the Alliance of Energy Intensive Industries on the Commission proposal to back-load (set-aside) EU ETS allowances

In July, the European Commission issued a proposal to postpone the auctioning of an as yet undefined number of CO2 Allowances until towards the end of the third trading period. The purpose is to ensur...

01/09/2012 Position Paper

EUROPIA Position Paper on the Refining BREF

EUROPIA recognises the importance of safeguarding the environment and the refining industry has over the years made great strides to improve its environmental performance, for example by reducing sulp...

01/06/2012 Position Paper

EUROPIA Position Paper on Pump Labelling for Road Fuels

EUROPIA agrees that clear and easily recognised pump labelling should be provided at service stations in order to avoid Customer confusion when refilling their vehicle. Appropriate and consistent info...

01/06/2012 Position Paper

The EU Emission Trading System: EUROPIA Position on intervention in the EU ETS market

As the debate on potential intervention in the EU ETS gathers pace, EUROPIA highlights three key principles of the EU ETS which are fundamental to the EU’s GHG reduction approach in a competitive ma...

01/05/2012 Position Paper

EU Refining Roundtable – EUROPIA press release

EUROPIA, representing the oil refining industry in Europe, will join Günther Oettinger,Commissioner for Energy,along with Member States at a first meeting of the EU Refining Roundtable on 15 May 2012...

01/05/2012 Position Paper

EU Refining Roundtable Outcome – EUROPIA press release

EUROPIA welcomes the strong support expressed by Member States and Members of the European Parliament to DG Energy’s proposed way forward to address the competitiveness challenges of the refining in...

01/02/2012 Position Paper

EUROPIA Response to the Commission Roadmaps to 2050

The Commission has published a number of Communications, or Roadmaps, over the past 12 months looking at how the EU might adapt to global resource, climate and energy challenges to 2050. EUROPIA has r...

01/11/2011 Position Paper

EUROPIA Position Paper on the revision of the Directive on the sulphur content of marine fuels

With regards to the adoption of international rules to reduce harmful emissions from ships through the revised MARPOL Annex VI, EUROPIA stresses the need to ensure that EU legislation on marine fuels...

01/10/2011 Position Paper

EUROPIA Position Paper on the proposed Directive on Energy Efficiency

EUROPIA welcomes the EU efforts to encourage energy efficiency in the EU, particularly in end use. The efficient use of energy is vital due to the increasing world energy demand, assessed to grow by 3...

01/07/2010 Position Paper

EUROPIA’s response to the Commission’s Stock Taking Document towards a new Energy Strategy for Europe 2011-2020

EUROPIA is the voice of the refining and marketing branches of the European oil industry. EUROPIA welcomed the 2007 Energy package and welcomes now the opportunity to submit its views on the 2011-2020...

01/12/2009 Position Paper

EUROPIA Comments in view of the 2nd reading in the European Parliament on the Proposal for a Directive on Industrial Emissions (Integrated Pollution Prevention and Control) (Recast). COM(2007)844

While fully acknowledging the task to reduce the effect of pollution on human health and the environment, EUROPIA is of the view that the European Union policies should be based on the key principles...

01/10/2009 Position Paper

EUROPIA Position on Energy Taxation

EUROPIA’s views on energy taxation are summarized below. They are intended to contribute to a balanced discussion on the principles that should be considered when deciding how to revise the taxation...

01/09/2009 Position Paper

EUROPIA Chain of Custody Position – Ensuring biofuels sustainability while meeting the obligations under both the RED and FQD

EUROPIA supports the production and blending of sustainable and cost-effective biofuels....

01/04/2009 Position Paper

EUROPIA Position on the Single European Payments Area (SEPA) for cards

EUROPIA supports the objective/rationale of the Single European Payment Area (SEPA), as it will create opportunities for all parties involved in payment transactions, i.e. customers, banks, merchants,...

01/07/2008 Position Paper

EUROPIA supports the vision of the Single European Payment Area (SEPA)

EUROPIA supports the vision of the Single European Payment Area (SEPA - following Article 95 of the EU treaty), which should lead to potential opportunities for all parties involved in payment transac...

01/05/2008 Position Paper

EUROPIA position on the Commission Proposal for a Directive on Industrial Emissions (Integrated Pollution Prevention and Control)(Recast). COM(2007)844

While fully acknowledging the task to reducethe effect of pollution on human health and the environment, EUROPIA is of the view that the European Union policies should be based on the key principles o...

01/05/2008 Position Paper

EUROPIA Position Paper on a pan-European Biofuels Sustainability/GHG Certification Scheme

A single pan-European biofuels sustainability/GHG certification scheme should be achieved, while maintaining fungibility of fuel components and finished fuels, avoiding market distortions and preventi...

01/04/2008 Position Paper

EUROPIA position on the proposed Directive amending Directive 2003/87/ECso as to improve and extend the greenhouse gas emission allowance trading the Community – COM(2008)16, January 23, 2008 – EU ETS

EUROPIA shares the EU concerns around GHG emissions and acknowledges the need to take effective global action to reduce these emissions. We particularly welcome the clear recognition in the Commission...

01/09/2007 Position Paper

EUROPIA Position Paper on the review of Integrated Pollution Prevention and Control Directive

In recent years, the general approach to environmental regulation has developed from prescriptive regulation addressing individual issues towards a holistic and goal based approach and EUROPIA welcome...

01/07/2007 Position Paper

EUROPIA Position Paper on the review process of the EU ETS Directive

The European Commission has started the process of reviewing the EU greenhouse gas emissions trading scheme (EU ETS) in the light of experience gained since the scheme began operating in January 2005....

08/05/2007 Position Paper

EUROPIA comments on the questions raised in the Commission’s presentation at the 1st FFF WG meeting on Stocks

EUROPIA would first like to thank the Commission for their initiative to engage the FFF WG’s and to build a wider consensus amongst all parties involved in security of supply. The oil industry is co...

30/01/2007 Position Paper

EUROPIA comments on the Commission Energy Package of 10th January 2007

The member companies of the European Petroleum Industry Association (EUROPIA) welcome the opportunity to provide comments to the EU Commission’s proposal on an Energy Policy for Europe and a package...

01/01/2007 Position Paper

EUROPIA comments on the CEN Gasoline, diesel norms and maximum biofuel limits

The member companies of the European Petroleum Industry Association EUROPIA would like to offer suggestions for a way forward, in response to the recommendations of the European Commission’s Fuels D...

01/06/2006 Position Paper

EUROPIA Position Paper on the Green Paper on a European Strategy for Sustainable, Competitive and Secure Energy

The member companies of the European Petroleum Industry Association (EUROPIA) welcome the opportunity to provide comments to the EU Commission on the Green Paper entitled "A European Strategy for sust...

01/03/2006 Position Paper

EUROPIA Position on Biofuel Regulatory Mechanisms

EU Biofuel Directive published in 2003 requires Member States to set national biofuel targets and to develop policies in support of those targets. Many Member States have set national biofuel targets...

01/03/2006 Position Paper

EUROPIA Position on the application of Biomass in the transport sector

The EU Commission recently published two papers on the promotion of the use of biomass in energy applications. While the Biomass Action Plan outlined the broad scope of the use of biomass for energy g...

01/02/2006 Position Paper

EUROPIA position on the Thematic Strategy on Air Pollution COM(2005) 446

Following its Sixth Environmental Action Plan, the Commission launched the Clean Air For Europe (CAFE) programme in 2001, which was completed in 2005 with the adoption of the Thematic Strategy on Air...

01/02/2006 Position Paper

EUROPIA Position on the Water Framework Directive

EUROPIA supports the high level objectives of the Water Framework Directive and the protection of inland surface waters, transitional waters, coastal waters and groundwater, preventing further deterio...

01/09/2005 Position Paper

EUROPIA Principles for the allocation of CO2 allowances in the 2nd period (2008-2012) within the oil refining sector

This document aims to provide guidance to the National Oil Industry Associations, in the event that they are called on to contribute to the definition of the National Allocation Plans foreseen by the...

01/08/2005 Position Paper

EUROPIA/OGP Position Paper on Carbon dioxide Capture & Storage Can Significantly Reduce GHG Emissions but it needs a Legal and Regulatory Framework

In view of the world’s rising energy demand and in the absence of breakthrough carbon-free technology applicable on a large scale, a portfolio of options is needed to manage the risk of global clima...

01/02/2005 Position Paper

Position Paper on Sulphur in Marine Fuels

EUROPIA Comments on the Draft Recommendation for Second Reading of the Council Common Position for adopting a Directive in the European Parliament and of the Council amending Directive 1999/32/EC as r...

01/09/2004 Position Paper

EUROPIA Position on the Draft Directive of the European Parliament and of the Council on Energy End-use Efficiency and Energy Services (COM(2003) 739 final)

The European Petroleum Industry Association (EUROPIA) welcomes the intentions and the aims of the draft Directive. Through enhanced energy efficiency, the security of energy supply will be improved an...

01/05/2004 Position Paper

EUROPIA Position on Alternative Fuels for Transport: Gaseous Hydrocarbon Fuels

The Alternative Fuels Contact Group set up by the Commission has issued a Report on Market Development of Alternative Fuels. The main focus of report is on Compressed Natural Gas (CNG), and Hydrogen,...

01/05/2004 Position Paper

The Environmental Liability Directive (Dir. 2004/35/CE) – Recommendations for Implementation

The Environmental Liability Directive (Dir. 2004/35/CE) - Recommendations for Implementation (May 2004) -...

01/10/2003 Position Paper

Draft Directive on Environmental Liability – Response to Common Position – Joint proposals from CEFIC, EUROPIA, OGP and UNICE

CEFIC, EUROPIA, OGP, and UNICE represent a major part of the industry concerned by this Directive, comprising industry at large and in particular chemical as well as oil companies. Our proposals follo...

01/10/2003 Position Paper

EUROPIA Position on the Commission Proposal for a Directive relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air

EUROPIA, the European Petroleum Industry Association, is a supporter and a contributor to the European Commission initiatives aimed at improving human health and environment, and, in particular, those...

01/10/2003 Position Paper

EUROPIA Position Paper on Waste Oils

The EU directives which regulate used oils management encourage effective collection for pollution prevention, followed by re-refining (regeneration) into lubricant base oils as the most energy effici...

01/09/2003 Position Paper

EUROPIA Position Paper on Commission Communication on the Development of Energy Policy for the Enlarged European Union, its Neighbours and Partner Countries (COM(2003) 0262)

The member companies of the European Petroleum Industry Association (EUROPIA) welcome the general principles and aims of the Communication by the Commission, - especially as regards facilitating inves...

01/09/2003 Position Paper

EUROPIA/OGP joint Position Paper on the Directive amending the Directive Establishing a Scheme for GHG Emission Allowance Trading within the Community in respect of the Kyoto Protocol’s Project Mechanisms (COM(2003) 0403)

The members of the European Petroleum Industry Association (EUROPIA) and the International Association of Oil and Gas Producers (OGP) welcome the linking of the EU Emissions Trading Scheme with the pr...