We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Climate Lobbying Overview: The German Chemical Industry Association (VCI) is actively lobbying EU and Germany climate change policy with predominantly negative positions. The association seems to broadly support top-line climate ambition, but with major exceptions, and advocates for the decarbonization of the chemical industry with renewable electricity. However, it has taken negative positions on key policies such as the EU Emissions Trading System and Germany’s Renewable Electricity Levy (EEG).
Top-line Messaging on Climate Policy: VCI appears to broadly support climate policy in its top-line messaging, albeit with major exceptions. In a tweet in November 2022, the association supported the EU’s Green Deal and 2050 climate targets, but has consistently stressed its high demands and potential dangers, for example on its corporate website in November 2022. Additionally, in a press release in May 2021 the Director General, Wolfgang Große Entrup, seemed to stress concerns regarding increasing the ambition of Germany’s climate target to achieve climate neutrality in 2045. VCI has taken mostly negative positions on the need for climate change regulation. In a June 2021 policy briefing, the association seemed to stress the burden of the EU Green Deal on industry and suggested support for global action over regional regulation. In a press release in July 2021, the Director General did not seem to support the EU’s Fit for 55 package, stressing the threat of carbon leakage and advocating that the package must ensure the international competitiveness of European industry.
Engagement with Climate-Related Regulations: VCI takes predominantly negative positions on specific climate regulations in the EU and Germany. On its corporate website in November 2022, the association did not support the EU Emissions Trading Scheme (ETS) revision, criticizing the restrictions around free allowances as “unnecessary double burden.” In addition, it has consistently stated opposition to an EU Carbon Border Adjustment Mechanism, such as in an EU public consultation response in November 2021, arguing that it would harm the European industry due to the risks of unilateral action. The association did not support Germany’s Fuel Emissions Trading Act (BEHG) in a July 2021 position paper and in September 2022 article advocated for the German carbon price to be postponed to 2024.
The Director General stated opposition to the EU level target in the Energy Efficiency Directive in a press release in September 2021, suggesting that fossil free technologies need more energy than fossil fuels. Furthermore, in an EU public consultation response in November 2021, the association did not support an increase in the binding absolute savings target and annual energy savings obligations. VCI’s President, Christian Kullmann, advocated for the gradual reduction and subsequent abolishment of Germany’s renewable electricity levy (EEG) in July 2021, while the Director General expressed support for a sped up abolishment in November 2021. The German government has since announced that the EEG will be funded from the Federal budget from 2023. In a press release in June 2021 the association suggested that the goal of 100% renewable energy in Germany by 2035 is too ambitious. However, in a January 2022 press release the Director General expressed support for the increase in climate protection efforts from the German government, calling for more a more ambitious pace in expanding renewable energy sources.
The VCI has taken mixed positions on the increase of the EU’s 2030 climate target to 55%. The group supported the increase in a press release in April 2021, but in July 2021 in a press release the Director General seemed to stress the risks of unilateral action due to the EU’s increased ambition. The Director General also appeared unsupportive of increasing Germany’s climate target to 65% in a May 2021 press release, emphasizing that it is an “enormous task.”
Positioning on Energy Transition: VCI appears to have largely negative engagement on the energy transition, particularly since the start of the war in Ukraine. In July 2021 the President of VCI seemed to support continued exemptions for industry from energy and electricity taxes. Furthermore, VCI opposed the EU’s Energy Taxation Directive in an official consultation response in November 2021. In a position paper published in December 2022, VCI was unsupportive of Germany’s accelerated coal phase out, and advocated for the use of all existing coal infrastructure in order to diversify the energy mix away from Russian fossil fuels. In addition, the association expressed support for fracking in Germany in a November 2022 position paper, to diversify the country’s gas supply. In a March 2022 position paper, VCI emphasized the importance of renewable energies in Europe in the long run, while supporting the use of existing fossil gas infrastructure for a “longer transition period.”