The July revision of the EU ETS Directive will determine whether the EU can reconcile it with industrial competitiveness. In short, whether it can achieve decarbonization without deindustrialization.

EU’s global competitiveness gap is growing

Europe now operates in a very different environment than when its climate policy was originally designed. According to forecasts from the Organisation for Economic Cooperation and Development (OECD) and the International Monetary Fund (IMF), EU economies are expected to remain among the slowest-growing in the G20 in the coming years, while the gap between Europe and major competitors such as the United States and China continues to widen.^[1]

European industry faces structurally higher energy costs. This is not a short-term fluctuation but a trend. The International Energy Agency’s (IEA) Electricity 2026 report underlines the scale of the challenge. EU electricity prices for energy-intensive industries remained elevated in 2025, averaging more than twice American levels and almost 50 percent above those in China. Wholesale electricity prices followed the same pattern: the EU recorded the highest levels among the markets analyzed by the IEA, matching the twofold gap with the United States, while standing significantly above levels in India, Australia and Japan. The report also points to the role of EU ETS prices in maintaining upward pressure on electricity costs.^[2]

If European industry pays much more for electricity than its global competitors and, at the same time, bears higher climate-related regulatory costs, policymakers cannot simply take it for granted that companies will remain, invest and create jobs within the EU.

The EU ETS revision: time to rebalance priorities

A growing number of stakeholders are highlighting the rising cost burden imposed on EU citizens. The costs associated with the EU ETS already account, on average, for 11 percent of industry electricity prices in the EU. However, in many countries it is substantially more. Poland records that figure at around 50 percent, despite the country having already decommissioned 22 GW of coal-based capacity between 2010 and 2022.This cost is already proving to be an obstacle to accelerate electrification in many member states.

The fact that it is not just about the figures is illustrated by examples such as the latest report on the EU chemical industry (CEFIC). It shows that chemical plant closures in Europe have increased sixfold since 2022, reaching 37 Mt of capacity — around 9 percent of European production capacity — and leading to the loss of 20,000 direct jobs. The report also points to a sharp slowdown in new investments, with energy cost competitiveness cited as the main reason for closures in 49 percent of cases, ahead of demand-related factors (19 percent), overcapacity (9 percent) and regulation (8 percent).^[3]

“Business as usual” won’t work

In this context, it is worth referring to the conclusions of the European Council of March 19, in which heads of state and government called for the EU ETS review to “reduce the volatility of the carbon price and mitigate its impact on electricity prices.”^[4] This message was reaffirmed in the June European Council conclusions, which recalled the need to accelerate work on lowering energy prices.^[5]

The EU’s climate policy model, based mainly on CO2 allowances cost pressure, might be rational in a world where the EU enjoyed a strong economic position, and had no serious competitors capable of scaling industrial production cheaper and faster. But that is not the world we live in anymore.

The key to restoring Europe’s industrial competitiveness lies above all in affordable and secure energy. For many industries, it is the foundation of competitiveness. This is why EU competitiveness should not be built primarily on imposing high EU ETS costs on the European industries. Moreover, planned large-scale electrification requires particular attention to the energy sector.

EU ETS reform: a solution for all 27 member states is needed

Three elements should be at the heart of the upcoming reform.

Addressing the link between carbon costs and power prices would bring down energy costs across the entire EU in a systemic way, which would be far more effective than the current subsidy race. In order to do so, we propose increasing the predictability of CO2 prices by making intervention in the EU ETS market more realistic.

Moreover, a specific volume of energy directed to final customers should be exempted from the obligation to purchase allowances. In exchange, installation operators should reduce their emissions by a specified percentage to comply with the EU 2040 and 2050 climate targets. The volume of energy corresponding to the emission volume should be allocated directly to industrial end users, at a price that reflects the absence of carbon costs.

Market liquidity needs to be restored.

With the current EU ETS parameters, the supply of CO2 allowances on the primary market will end around 2040. The Market Stability Reserve (MSR) will be empty by that time and will not be able to mitigate supply constraints, which will probably occur due to economic recovery after the end of the war in Ukraine, the increase in EU defence capabilities and insufficient supply of decarbonized gases to replace natural gas.

Therefore, to prevent a market squeeze, the EU ETS revision should, in the first place, substantially reform the MSR parameters. The already presented proposal to abolish the invalidation of allowances by the MSR is the right move, but more needs to be done. The current Total Number of Allowances in Circulation (TNAC) indicator is static and does not reflect the number of allowances held in speculative long-term positions. We suggest introducing a dynamic TNAC to better reflect market circumstances. We also recommend lowering the Linear Reduction Factor to reach climate neutrality by 2050, instead of the current 2040 target. What is more, peaking units, which ensure system stability and adequacy, should be exempted from the obligation to surrender allowances. International carbon credits should also be integrated with the EU ETS.

A focus on affordability and investments is also needed.  Further decarbonization of power systems is becoming more challenging, as the remaining emissions are more costly and difficult to abate. The EU ETS auction revenues (estimated at €1.5 trillion by 2050) are expected to cover only 11 percent of the sector’s total investment needs. Since the whole economy benefits from energy infrastructure, initiatives such as the recently announced €30 billion ETS Investment Booster should support the energy sector. It is also of the utmost importance to maintain the Modernisation Fund in the post-2030 framework, which needs to be continued at the level of 4.5 percent of the total pool of allowances. Furthermore, the standard and additional allocation of free allowances for the district heating sector should continue after 2030.

Key message

The real test of the next EU ETS reform is not whether it drives decarbonization, but whether it can do so without driving industry away. Decarbonization has to strengthen the competitiveness of the entire EU, not only selected sectors, companies or member states. It should not be only for first movers, but for the entire European industry.

^[1] OECD Economic Outlook, Interim Report March 2026 | OECD, https://www.imf.org/en/publications/weo/issues/2026/04/14/world-economic-outlook-april-2026,

^[2] https://www.iea.org/reports/electricity-2026/prices

^[3] https://cefic.org/news/chemical-plant-closures-surge-six-fold-in-europe-since-2022-reaching-37mt-new-report-finds/

^[4] en-20260319-european-council-conclusions.pdf

^[5] en-20260319-european-council-conclusions.pdf

Disclaimer

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• The sponsor is PKEE – Polish Electricity Association .
• The entity ultimately controlling the sponsor is PKEE – Polish Electricity Association.
• This article is linked to the revision of the EU ETS Directive.

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