C 152/178
EN
Official Journal of the European Union
6.4.2022
3.3.
It is also necessary to consider the way climate issues are dealt with worldwide and to avoid divergences that may put European business at a disadvantage and/or cause social problems such as energy or mobility poverty.
The EESC regrets that too little attention seems to have been given to these problems and that the solutions offered do not appear fully sufficient.
3.4.
Regarding social effects, there will be an obvious need for reskilling and upskilling to enable the workforce to adapt and meet new skills requirements.
Furthermore, effects on households such as higher costs for electricity and mobility are likely to cause energy and mobility poverty, with the latter being particularly prevalent in distant and sparsely populated regions.
There are plans to deal with those problems through various mitigation measures to be financed largely by ETS revenues, including those falling to the Member States and those to finance the proposed Social Climate Fund.
The EESC takes note that the resources available for the solution of those problems will depend on the fate of proposals still pending before the co-legislators.
The EESC believes that the costs for dealing with these problems will be considerable and lasting.
The EESC therefore also questions whether the resources available will be sufficient even if the financing proposals were approved without significant amendments bearing in mind the number of people involved and the time needed for the envisaged transition.
3.5.
The accelerated pace and the high ambition level of CO2 reductions and reduced availability of greenhouse gas allowances, while bringing environmental benefits, will also mean higher costs for all sectors covered by the ETS system.
While cost effects will be reduced by the availability of free allowances and for some sectors through the CBAM, these measures will not apply to all sectors that use energy in various processes and that will face third country competition on the internal market.
Furthermore, those measures will not protect EU enterprises from a competitive disadvantage on external markets, due to the increased cost level.
3.6.
The EESC also draws attention to the fact that the question remains open whether zero-emission products will become sufficiently attractive to compensate the cost difference caused by the ETS or whether measures with equivalent cost effects to those of the ETS will be generally introduced on world markets.
If that is not the case the competitiveness of European business on world markets may become problematic.
This raises the question whether products or services to be exported to third countries should be exempted from the ETS or whether other support measures should be considered.
It seems doubtful whether innovation support, which appears to be the only support measure compatible with the WTO framework, is sufficient to resolve a possible competitiveness problem.
3.7.
A further question is whether the increased cost level provoked by the modifications of the ETS may have negative effects on the prospects of recovery following the COVID-19 crisis.
The EESC questions whether this risk has been sufficiently taken into account.
3.8.
The EESC is pleased to note that the ETS proposal provides for the revenues of the ETS system to be used in various ways — through the Commission own resources or according to provisions regarding the use of revenues by Member States — to promote sustainability, including social effects on the transition to a carbon neutral society.
3.9.
The EESC underscores that the above remarks should not be seen as questioning the urgent need for action to mitigate the negative climate effects of emissions, but as a caveat regarding the risk of negative effects, both socially and on competitiveness, if issues such as those pointed out above are not addressed and resolved.
Maritime transport extension 3.10.
The EESC welcomes the fact that all ships arriving at or departing from EU ports will be subject to the same rules.
Nevertheless, the cost level of EU ship owners or operators otherwise falling under the ETS will be higher than that of non-EU competitors, which also in some cases lower their costs through social dumping.
The EU needs to pay attention to the effects of reduced competitiveness of EU shipping.
3.11.
It should also be considered that maritime transport is one of the sectors where CO2 reduction is particularly difficult and costly, and that therefore inclusion of maritime transport might provoke a general price increase on emission allowances which would have repercussions on the competitiveness of ETS sectors in general.