Integrating the European Trade Indexes Registry (EUTIR) with the ETS State Aid Guidelines Update for Competitive, Low-Carbon Trade

Our feedback to the European Commission proposes the integration of the European Trade Indexes Registry (EUTIR) into the 2025 update of the EU Emissions Trading Scheme (ETS) State Aid Guidelines as a strategic enabler for competitive, low-carbon trade. Rising electricity prices and CO₂ costs are increasingly affecting energy-intensive industries, heightening the risk of carbon leakage and undermining industrial competitiveness. To address these challenges, we advocate for a modernised, data-driven governance framework that leverages EUTIR’s secure, decentralised, and interoperable infrastructure. By anchoring critical ETS-related data’such as electricity consumption, CO2 intensity, and efficiency benchmarks’in a trusted digital environment based on EBSI and Distributed Ledger Technology (DLT), EUTIR ensures that claims for indirect cost compensation are verifiable, up to date, and resistant to overcompensation. This integration would streamline cross-border verification, reduce administrative burdens, and enhance real-time risk assessment, aligning with the objectives of the EU Competitiveness Compass. Furthermore, by embedding global identifiers like LEI/vLEI and enabling machine-readable, AI-ready data exchange, EUTIR positions the EU as a global leader in green-digital trade governance, ensuring legal certainty, interoperability, and long-term resilience in the transition towards a sustainable and digitally integrated single market.