1 ) quantitative assessment should be possible at disaggregated level (prodcom 8)

In the flat glass sector, NACE 4 includes some downstream activities not covered by EU ETS: coated glass enter calculation when it should be restricted to unprocessed flat glass.

Prodcom 8 is the statistical level to properly assess risk of carbon leakage with focus on unprocessed flat glass products. Assessment at disaggregated level should be possible regardless of any threshold.

At NACE 4 level, the risk of carbon leakage in the flat glass sector is dangerously underestimated.

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2 ) the list of sector exposed should be established for the entire trading period

Certainty, Long-term Visibility and Predictability are needed to plan major investments

The proposal should clarify that the list of sectors exposed to carbon leakage is established for the entirety of each trading period of the EU ETS, to ensure certainty and long-term visibility to industry and investors. This stability has been missing to the ETS mechanism in the last years whereas it is essential to build investor’s confidence much-needed at times of deciding whether or not to upgrade installations meant to continuously produce for the next 16 to 18 years.

A float plant is highly capital intensive

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3 ) benchmarks must remain based on real and verified data.

The flat glass case
Available solutions to reduce emissions have been largely deployed in the previous phases, hence, we observed a 3% reduction in GHG/tonne of float glass in the last 4 years.
However, benchmark is not expected to decrease at a faster pace then 0.2%* because of current knowledge in thermodynamic science and realities of raw material use and infrastructures’ production cycles.

Benchmark will be disconnected from reality and act as a new correction factor generating higher production costs.

*Reduction in benchmark observed between 2008 and 2012.

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