Feedback paper - Inception Impact Assessment on the Energy Taxation Directive Review

Date: 31 March 2020

Author(s): Andrei Marcu, Dana Agrotti and Dariusz Dybka


This position paper accompanied ERCST's response to the feedback opportunity regarding the Commission’s Inception Impact Assessment on the review of the Energy Taxation Directive.

In its submission, ERCST highlights a number of important aspects that should be examined as part of the revision, including:

  • How to design a taxation formula that accounts for both the energy and climate components of energy products and electricity.
  • How to avoid overlaps with other policy instruments, including the EU Emissions Trading System and carbon taxes in the EU.
  • How to avoid double taxation of energy products and electricity as a result of policy overlaps.
  • The issue of earmarking revenues.
  • How to ensure negative social impacts are limited, particularly on low-income households and vulnerable populations.
  • The impacts towards the creation of a market for low carbon products.
  • The impact on the governance of the Treaty on the Functioning of the European Union if Article 192 is used instead of Article 113.