In a joint letter, representatives of the Polish shipping and aviation industries call for a correction to the EU ETS. They fear that the European emissions trading system will lead to a distortion of competition and an exodus of industrial companies.
According to the initiators of the position paper, the document is the result of an in-depth analysis of the impact of regulation on sectors that are highly exposed to global competition and have limited access to scalable low- and zero-emission technologies. For the first time, such a broad coalition of stakeholders from transport, energy, the fuel industry and the expert and legal environment would present joint recommendations on the redistribution of ETS revenues and on mechanisms to protect the competitiveness of the EU economy, it says.
No reduction in emissions, but rising costs
The authors of the statement point out that the current design of the EU ETS causes considerable cost burdens without providing adequate transformation instruments at the same time. Rising prices for emission allowances would lead to higher costs for operators, while the opportunities to offset these costs through technological and infrastructural investments are limited.
The special features of the aviation and shipping industry – including long investment cycles of 20 to 30 years, high capital intensity of the plants and the lack of industrially available technological alternatives – mean that the ETS in its current form does not directly reduce emissions, but primarily has a fiscal effect.
Adaptation of EU instruments called for
The signatories emphasize that the European Union has already created important instruments to support the transformation, including the Innovation Fund, the Modernization Fund, the Connecting Europe Facility and the ReFuelEU Aviation and FuelEU Maritime regulations. However, market experience to date has shown that these mechanisms do not do sufficient justice to the special features of mobile sectors.
In particular, they are criticized for
This creates a permanent investment gap that limits the sector’s ability to meet the objectives of regulations such as ReFuelEU Aviation or FuelEU Maritime.
Risk of carbon leakage
In view of globally differing regulatory frameworks, the signatories believe there is a growing risk that transport activities will be relocated outside the European Union. This applies in particular to rerouting and the relocation of logistics hubs. The consequence is so-called “carbon leakage” – i.e. a relocation of economic activities outside the EU with simultaneously increasing emissions.
Without a correction to the system, there is a risk of a structural weakening of European operators and a loss of importance of the EU as an international transport hub.
Systemic recommendations
The signatories propose a package of measures focusing on three pillars of reform: Investment efficiency, protection of competitiveness and infrastructure support. These include:
Does the EU ETS weaken the European economy?
In conclusion, the signatories emphasize that an effective climate policy must reconcile environmental goals with economic and technological realities.
The transformation of transport requires not only price signals, but above all stable financing mechanisms and a coordinated expansion of infrastructure and alternative fuels.
Without appropriate adjustments, there is a risk that the EU ETS will not accelerate decarbonization, but rather weaken the competitiveness of the European economy and economic activities will migrate out of the EU.
Voice of the aviation and shipping sector: The joint position paper on the reform of the EU ETS was prepared by the energy company Orlen, the airline Polskie Linie Lotnicze LOT, the Port of Gdańsk, Gdańsk Lech Wałęsa Airport, the energy company Tauron, the Polish Association for New Mobility, Business & Science Poland, SEA Global and the law firm Polowiec i Wspólnicy.




