The German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Proposal for a Council Directive restructuring the Union framework for the taxation of energy products and electricity COM(2021) 563 final.
In our view, the proposed reform of energy taxation should consider the following points: current exemptions for large energy consumers should be kept under the new structure of tax rates based on the energy content; mineralogical processes and industrial waste incineration should be excluded from the scope of Directive; special tax reliefs for thermal waste and exhaust air treatment must be re-established. Additionally, an alignment between the ETD, the CEEAG and the EU-ETS should not lead to double carbon taxation and competitive disadvantages. It is also important to reconsider economic risks for a planned increase of minimum tax rates for energy products/electricity and their annual indexation. Finally, the ETD proposal should ensure reliable conditions for future practical applicability of the targeted tax reductions in favour of energy-intensive businesses and industrial park operators.