Free allocation in the 3rd EU ETS period: assessing two manufacturing sectors

This article provides an analysis of the EU Emissions Trading Scheme (ETS) and the harmonized benchmark-based allocation procedures by comparing two energy-intensive sectors with activities in three Member States. These sectors include the cement industry (CEI) and the pulp and paper industry (PPI) in the UK, Sweden, and France. Our results show that the new procedures are better suited for the more homogeneous CEI, in which the outcome of stricter allocation of emissions allowances is consistent between Member States. For the more heterogeneous PPI – in terms of its product portfolios, technical infrastructures, and fuel mixes – the allocation procedures lead to diverse outcomes. It is the lack of product benchmark curves, and the alternative use of benchmark values that are biased towards a fossil fuel-mix and are based on specific energy use rather than emission intensity, which leads to allocations to the PPI that do not represent the average performance of the top 10% of GHG-efficient installations. Another matter is that grandfathering is still present via the historically based production volumes. How to deal with structural change and provisions regarding capacity reductions and partial cessation is an issue that is highly relevant for the PPI but less so for the CEI.

Policy relevance

After an unprecedented amount of consultation with industrial associations and other stakeholders, a harmonized benchmark-based allocation methodology was introduced in the third trading period of the EU ETS. Establishing a reliable and robust benchmark methodology for free allocation that shields against high direct carbon costs, is perceived as fair and politically acceptable, and still incentivizes firms to take action, is a significant challenge. This article contributes to a deeper understanding of the challenges in effectively applying harmonized rules in industrial sectors that are heterogeneous. This is essential for the debate on structural reformation of the EU ETS, and for sharing experiences with other emerging emissions trading systems in the world that also consider benchmark methodologies.