The European Commission has published a proposal for a Regulation on net-zero industry (NZIA) within the framework of the Green Deal Industrial Plan for the net-zero age. The Confederation of Swedish Enterprise would like to thank the Commission for the opportunity to comment on this matter and has the following comments.
• Overall, the Confederation of Swedish Enterprise welcomes the European Commission’s initiative to improve the investment conditions for certain green technologies within the European Union. The green transition is being challenged by high energy prices in Europe as well as ongoing lengthy and unpredictable permit processes. Securing access to critical components and technologies remains an key issue for industry, as does a stable supply of fossil-free energy at a competitive cost.
• However, the European Commission’s initiative is too limited in its scope. The selection of technologies lacks a clear justification, and the Confederation of Swedish Enterprise believes that general measures, those that promote the industry’s green transition and resilience, are preferable to more technology-specific approaches.
• The Confederation of Swedish Enterprise is against setting specific benchmarks for production shares for these technologies, even if they are only indicative. However, the industry’s relative competitiveness and market development should be closely monitored.
• The Confederation of Swedish Enterprise remains doubtful on the proposal for strategic projects, and believes that all projects that promote green transition and resilience should be subject to facilitation measures. Additional assessment will lead to increased administrative costs and extended project times. The additional assessment involved will in part cancel out the benefits of the shorter time limits proposed in the permit process. As currently proposed, the selected criteria invite interpretation of their meaning and increase uncertainty for market participants. It is unclear whether the projects that will be selected will actually be the projects that are most in need of help with financing and managing the permit processes.
• The main obstacle that both the European Commission and the Member States should focus on is the lengthy and unpredictable permit processes that often constitute crucial obstacles to the establishment of new or expanded industrial activities. The proposal to introduce fixed time limits for certain technologies may be welcome for those affected. However, it is problematic from a market perspective as other activities may be disadvantaged when selected projects are prioritised. More fundamental measures are needed to bring about real change and accelerate the transition. In addition, a new organisation of the permit process on the premises proposed by the European Commission may risk challenging the possibility of an effective assessment.
• The proposal only covers technologies that relate to energy. To be more accurate, and to take into account that there are many important net-zero technologies that are not specifically related to energy, consideration should be given to changing the title of the proposal. This could be, for example, ”Proposal for a Regulation of the European Parliament and of the Council on establishing a framework of measures for strengthening Europe’s net-zero energy technology products manufacturing ecosystem”.