Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision

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Carbon Market Watch calls for the revision of the Industrial Emissions Directive (IED) to address a gap in greenhouse gas (GHG) regulation. The organization argues that the EU Emission Trading System (ETS) has failed to provide sufficient incentives for industrial decarbonisation due to the over-allocation of free allowances, which led to windfall profits of over €25 billion between 2008 and 2015. To align the IED with the European Green Deal's zero-pollution and climate neutrality goals, the author recommends deleting Article 9(1) to allow GHG emission limits in permits, making energy efficiency standards binding under Article 9(2), phasing out coal and lignite by 2030, and introducing a Paris Agreement compliance test for new industrial investments.

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  • The EU Emission Trading System (ETS) has failed to incentivise industrial decarbonisation because more than 90% of industrial GHG emissions are covered by free allowances, resulting in stagnating emissions since 2012 and windfall profits exceeding €25 billion from 2008 to 2015.
  • The current Industrial Emissions Directive (IED) is insufficient for climate goals because Article 9(1) prohibits the inclusion of GHG emission limits in operating permits, and Article 9(2) makes energy efficiency and fuel choice requirements optional, which Member States generally do not apply.
  • Carbon Market Watch proposes four specific policy changes for the IED revision: deleting Article 9.1 to allow combined command-and-control and market-based approaches; making energy efficiency standards binding under Article 9.2; setting GHG standards to phase out coal and lignite by 2030 and achieve industrial neutrality by 2040; and implementing a Paris Agreement compliance test for new investments to prevent carbon lock-in.

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APA
Carbon Market Watch (n.d.). Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision. https://carbonmarketwatch.org/wp-content/uploads/2020/04/Inception-impact-assessment-on-IED-revision_CMW-2.pdf
Chicago
Carbon Market Watch. Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision. n.d. https://carbonmarketwatch.org/wp-content/uploads/2020/04/Inception-impact-assessment-on-IED-revision_CMW-2.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision |url=https://carbonmarketwatch.org/wp-content/uploads/2020/04/Inception-impact-assessment-on-IED-revision_CMW-2.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch’s response to the inception impact assessment on Industrial Emissions Directive revision}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2020/04/Inception-impact-assessment-on-IED-revision_CMW-2.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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