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CLECAT has adopted its position paper on the European Commission’s proposal to revise the EU Emissions Trading System. CLECAT supports stronger incentives for transport decarbonisation, while calling on the European Parliament and Member States to safeguard the competitiveness, connectivity and resilience of European supply chains. Measures that encourage cargo diversion through non-EU hubs risk weakening European transport networks without delivering corresponding reductions in global emissions.

The proposal includes positive elements, particularly increased support for sustainable aviation and maritime fuels. CLECAT calls for ETS revenues to be reinvested in the decarbonisation of the sectors generating them, helping operators and their customers access affordable lower-emission transport solutions.

Retaining the current geographical scope for aviation

CLECAT’s principal concern is the proposed extension of the aviation ETS from 2029 to flights departing the European Economic Area (EEA) for third-country airports within a 5,000-kilometre radius of Frankfurt Airport.

CLECAT opposes this extension and urges co-legislators to retain the current geographical scope. International aviation requires a coordinated global approach, with emissions addressed through the International Civil Aviation Organization’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

Extending the EU ETS to additional international flights risks increasing costs for European airlines, freight forwarders and their customers, while encouraging cargo to move through competing non-EEA airports. The resulting loss of traffic could weaken Europe’s air cargo connectivity and reduce the choice of services available to European businesses. The EU should instead work through ICAO to strengthen CORSIA’s environmental effectiveness and international coverage, while ensuring that its interaction with the EU ETS avoids double carbon pricing.

Making sustainable aviation fuels more accessible

CLECAT welcomes stronger support for sustainable aviation fuels (SAF), including measures that provide investment certainty for production and long-term supply agreements. This should be complemented by a robust European Book-and-Claim framework, enabling freight forwarders and shippers to contribute directly to SAF uptake and credibly account for the associated emission reductions, even where the fuel cannot physically be supplied at their cargo’s departure airport.

Protecting maritime connectivity and ensuring transparent charges

For maritime transport, CLECAT supports stronger safeguards against ETS evasion and the relocation of transshipment activities to non-EU ports. Transshipment volumes help sustain long-distance calls at European ports and direct connections for European imports and exports. Their diversion could therefore affect a much wider range of cargo, reducing service choice and increasing supply-chain costs and complexity. Effective monitoring and targeted relief should help preserve these connections.

CLECAT also calls for clear arrangements to avoid double carbon pricing under the EU ETS and a future IMO framework, alongside greater transparency in shipping lines’ ETS surcharges. Freight forwarders and shippers should be able to verify how charges are calculated and how applicable support and relief measures are reflected in the costs passed on to them.

CLECAT will share its priorities with Member States and the European Parliament as discussions on the proposal progress.