Climate Policy Engagement Analysis
Climate Policy Engagement Overview In 2021-23, the American Chamber of Commerce to the EU (AmCham EU) engaged with EU climate policy with mixed to negative positioning. While the associations’ top-line messaging generally supports the EU Green Deal and 2050 targets, its position on various EU climate policies remains mixed.
Top-line Messaging on Climate Policy AmCham EU appeared to support the EU’s Fit for 55 package in its November 2021 feedback on the Energy Efficiency Directive. Similarly, it called the Fit for 55 package “critical to the successful decarbonisation” of the aviation sector in a position paper published in June 2022, though it appeared to use support for regional GHG emissions regulations to oppose national regulations. The association seemed to support the European Green Deal but called for “clearly defined targets” in its 2021 Annual Report published in June 2022. Both the Chair and CEO of AmCham EU, Zeger Vercouteren and Susan Danger, stated general support for achieving the goals of the Paris Agreement in the opening remarks of a conference in March 2021. However, in its November 2021 comments on the EU’s Carbon border adjustment mechanism, the association stated support for government regulation but qualified this statement by stating that regulations should not affect export competitiveness.
Engagement with Climate-Related Regulations AmCham EU engaged with EU climate policy with negative to mixed positioning in 2021-23, commenting on multiple roadmaps and public consultations.
AmCham EU appeared generally unsupportive of the EU Carbon Border Adjustment Mechanism (CBAM) in its November 2021 comments on the Carbon Border Adjustment Mechanism. This position was reiterated in a May 2022 position paper, which also appeared unsupportive of the phase out of free allocation of emissions allowances under the EU Emissions Trading Scheme (EU ETS), stating it was “concerned about the impact of the phase-out trajectory”. Similarly, in a position paper published July 2022, the association advocated for a gradual phase out of free allowances for exposed sectors under the EU ETS over an unspecified period of time. Regarding the EU ETS, AmCham EU appeared to support its introduction alongside other EU regulations for aviation, while emphasizing carbon leakage concerns from a package of mechanisms and advocating for measures to be tailored to the needs of the aerospace sector, in its November 2021 comments on ReFuelEU Aviation.
In its November 2021 comments on ‘EU renewable energy rules – review’, the association had an unclear position on the EU Renewable Energy Directive, but supported market-based policy such as Power Purchase Agreements (PPAs). In its March 2022 comments on the revision of the EPBD, AmCham EU restated support for PPAs. Furthermore, the association appeared generally supportive of the EU sustainable aviation fuels mandate under ReFuelEU Aviation, but opposed higher ambitions or sub-targets at a national level in a June 2022 position paper.
In its June 2021 Energy Performance of Buildings Directive (EPBD) consultation response, AmCham EU appeared to strongly support energy performance certificates and mandatory renovation and minimum energy performance standards as part of the EPBD. However, this position appeared to weaken in its March 2022 comments on the revision of the EPBD, as though the association appeared supportive of Long-Term Renovation Strategy sub-targets, it broadly opposed the definition of zero-emission buildings and regulating data centres under the EPBD. AmCham EU appeared to strongly supportive of the Energy Efficiency Directive (EED) in stating support for increased annual energy savings obligation to 1.5% and Energy Efficiency Obligation Schemes in its comments on the EU EED in November 2021.
In a Joint Statement published in June 2021, AmCham EU appeared generally unsupportive of the Packaging and Packaging Waste Directive, advocating for the EU Commission to "prevent or address disproportionate or unjustified measures on unilateral packaging labelling". Similarly, in a Joint Statement from November 2022, the association appeared to oppose several elements of the Packaging and Packing Waste Directive revision, expressing “serious concerns with regards to the approach taken by the European Commission”.
Positioning on Energy Transition AmCham EU appeared generally supportive of an energy transition away from fossil fuels in 2021-23. A February 2023 blog post by the AmCham EU CEO, Susan Danger, appeared broadly supportive of the EU Green Deal Industrial Plan, calling the proposal a “step in the right direction”. In its March 2022 comments on the revision of the EPBD, the association appeared broadly supportive of a transition towards zero-carbon technologies and infrastructure. Similarly, in its June 2021 EPBD public consultation response, AmCham EU appeared to support the electrification of transportation through support for electric vehicle charging points. The association engaged with the EU’s Energy Taxation Directive (ETD) with mixed positioning in its November 2021 comments on ReFuelEU Aviation by stating the ETD should be introduced to complement ReFuelEU while advocating that regulation be “tailored” to the needs of the aerospace sector.