Climate Policy Engagement Analysis
Climate Policy Engagement Overview: The European Rail Supply Industry Association (UNIFE) has strategically and positively engaged with EU climate policy in 2021-23. UNIFE has expressed top-line support for the EU's Fit for 55 climate package, and has supported ambitious provisions for rail in the EU Alternative Fuels Infrastructure Regulation and other EU policies promoting a low-carbon modal shift for transport.
Top-line Messaging on Climate Policy: UNIFE's top-line communications on climate policy are positive. In its 2021 Annual Report, published in February 2022, UNIFE supported a reduction in emissions from the transport sector in line with the EU's 2030 GHG emissions reductions target. In March 2022, UNIFE published a report in which it stated support for the Fit for 55 package proposals, concluding that the revised directives are "a step in the right direction." UNIFE Chairman Henri Poupart-Lafarg also stated support for the Fit for 55 package in the association's 2021 Annual Report, published in February 2022. In the same report, he also endorsed the Glasgow Climate Pact agreed upon in COP26, as part of the Paris Agreement.
Engagement with Climate-Related Regulations: UNIFE has been supportive of emissions trading legislation in the EU while expressing reservations about an EU Carbon Border Adjustment Mechanism (CBAM). In its 2022 Annual Report, published in January 2023, UNIFE expressed support for the EU CBAM but also highlighted concerns about the risk of loss of competitiveness for the rail supply industry. UNIFE also advocated for the continuation of existing carbon leakage protection measures under the EU ETS, opposed a phase-out of free allocation of emissions allowances, and supported export rebates in a November 2021 public consultation response to the EU CBAM. In a report published in March 2022, UNIFE supported the revision of the EU Emissions Trading System (ETS) while calling for the ETS revenues to be used to support future rail and public infrastructure.
UNIFE has strongly advocated for a modal shift from other forms of transport to rail. In a May 2021 Open Letter, UNIFE Director-General Philippe Citroën stated that rail solutions should form the "backbone of a sustainable mobility system capable of meaningfully contributing to EU Green Deal decarbonization objectives." In February 2022, the association published a position paper on the revision of the TEN-T regulation, calling for a range of measures that would enable a modal shift to rail. UNIFE also published a press release in July 2021, supporting the increase of the EU's climate target to at least a 55% reduction of net greenhouse gas emissions by 2030.
Positioning on Energy Transition: UNIFE’s engagement on the energy mix has been positive overall, with the association supporting several related EU policies. In a public consultation response to the revision of the EU Energy Taxation Directive submitted in October 2021, UNIFE advocated for the taxation of fuels based on their energy content and the removal of exemptions for the aviation and maritime sectors. In October 2022, following the publication of the EU Parliament’s more ambitious proposal for the Alternative Fuels Infrastructure Regulation (AFIR) regarding the decarbonization of rail, UNIFE published a press release calling for Member States and the European Commission to endorse the proposal. UNIFE Director-General Philippe Citroën welcomed the finalized proposal for the AFIR in a May 2023 press release, while stating that "the level of ambition could have been higher."