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CLECAT has taken note of the European Commission’s proposal to revise the EU Emissions Trading System (EU ETS), published today as part of the broader package to strengthen the EU’s competitiveness whilst accelerating industrial decarbonisation.

The proposal introduces amendments to both the aviation and maritime ETS in response to evolving international developments. While CLECAT welcomes the Commission’s recognition that climate policy must take account of Europe’s competitiveness, several elements of the proposal require careful assessment to ensure they do not lead to carbon leakage, market distortions, or unnecessary administrative burdens.

On aviation, CLECAT reiterates its long-standing position that the EU ETS should remain limited to intra-European flights. The Commission proposes to include international flights of up to 5.000 km from Frankfurt Airport into the scope of the Regulation, keeping other long-haul flights within the scope of CORSIA until 2032. CLECAT highlights that any unilateral extension beyond the current scope risks undermining the competitiveness and connectivity of European aviation by encouraging traffic and cargo to shift to neighbouring non-EU hubs, whilst delivering limited additional environmental benefits in the absence of equivalent international measures. Although the Commission has proposed a more limited geographical extension than anticipated, CLECAT remains concerned that any expansion beyond intra-European aviation risks creating competitive distortions. CLECAT nevertheless welcomes the Commission’s proposal to further support the uptake of Sustainable Aviation Fuels (SAF) through the revised ETS framework, including the continued use of ETS revenues to accelerate SAF deployment.

On maritime transport, CLECAT welcomes the Commission’s recognition that the current ETS framework must better address the competitiveness of European ports and the risk of cargo diversion to neighbouring non-EU transhipment hubs. The Commission has proposed important measures to finetune the definition of non-EU transshipment hubs, improve the anti-evasion framework, and reinforce coherence with the emerging IMO net-zero framework. While these constitute steps into the right direction, CLECAT remains vigilant about the practical implementation of these measures and their interaction with the future IMO framework. What is more, CLECAT calls to prevent any unintended consequences for European supply chains or additional administrative complexity resulting from the proposed extension of the ETS to additional vessel categories.

Overall, freight forwarders expect the revision to strengthen transparency and traceability across the ETS allowance-allocation chain, so that all actors involved in air and maritime transport can clearly identify the emissions associated with the movement of their goods. This would improve market transparency and enable operators throughout the supply chain to report and account for their CO₂ emissions more accurately.

Nicolette van der Jagt, Director General of CLECAT, commented: “Climate ambition and competitiveness must go hand in hand. European climate policy should reduce emissions - not shift cargo, connectivity, and economic activity beyond the Union’s borders. We welcome the Commission’s recognition of the need to address carbon leakage and the competitiveness of European ports, but we remain convinced that the aviation ETS should not be extended beyond intra-European flights. The Commission should complement its proposals with practical measures, such as a legislative Book-and-Claim framework, that can accelerate SAF uptake while strengthening Europe's logistics sector.

CLECAT will continue to analyse the proposals in close consultation with its members over the coming days. A more detailed position will be published as the legislative discussions progress.