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Proposal for a review of the Effort Sharing Regulation

With regard to the proposed revision of the Effort Sharing Regulation (ESR), Oesterreichs Energie welcomes the fact that the sectors covered by the ETS are not solely obliged to reduce greenhouse gas emissions. This would place an uneven and disproportionate (additional) burden on these sectors.

However, the specifics of exempting the sectors covered by the new emissions trading system (buildings and transport) from the requirements of the ESR are unclear. It is important to achieve coherence with current national regulations at the European level. In particular, this relates to the coherence between national carbon pricing systems and the current EU ETS/the new emissions trading system which is due to come into effect in 2026.

The targets for the member states must not be determined solely on the basis of GDP. Instead, the aim should be to capitalise on potential where CO2 avoidance costs are lowest. The continuation of GDP-based allocation carries the risk that lock-in effects will be amplified, meaning that investment will not be steered towards climate-friendly technologies.


Susanne Püls-Schlesinger
European Affairs
+43 1 501 98 222
Michael Schlemmer
Director EU Representation Office
+32 2 27887 35