Submission to the public consultation regarding revision of the Energy Taxation Directive

The Technology Industries of Finland (TIF) is committed to the fight against climate change and sees that the EU and its Member States must make rapid progress in implementing their emission reduction commitments under the Paris Climate Agreement. We support the Commission’s position that the Energy Tax Directive should be updated in line with the EU’s energy, climate and environment policy framework.

Competitively priced sustainable electricity is a prerequisite for achieving the low carbon targets. It must be ensured that the amendments to the Energy Tax Directive do not significantly weaken the competitiveness of the EU and European companies. Current two-category electricity tax rate model applied in Finland should be accepted since it prevents carbon leakage and ensures competitiveness of the Finnish energy intensive industries.

Energy taxation should be well designed so as to prevent overlapping with Emission Trading System, which is the most important and the most effective market driven tool for reducing GHG emissions. Technology neutrality should be ensured. Nuclear electricity is a zero-carbon source of energy and it should be taken into account as such in the directive. Global co-operation should be supported to reach an agreement on global (floor) price of carbon.