Review of the German State aid for ETS costs
In Germany, Veyt estimates that the state aid scheme for indirect emission costs could have been responsible for 17.6 TWh of renewable guarantees of origin (GO) demand in Central-Western Europe, and 4.6 TWh in the rest of EU/EEA in 2022, per the last available data.
The importance of legislative drivers on the GO market is growing; Veyt has identified state aid for ETS costs as one of the demand-side legislation that has the potential to stimulate renewable and nuclear GO cancellations across European countries that have the scheme in place - a total of 16 to date.
Veyt has previously provided coverage of the topic, reviewing national state aid schemes, and quantifying demand potential in Norway. With this, we continue to review national state aid schemes and their possible impact on the GO market.
Context
State aid scheme for indirect emission costs guidelines was introduced by the European Commission in 2020 for the 2021-2030 period, with the previous scheme running between 2013- 2020. Member States and EEA countries can implement national state aid schemes and introduce additional requirements, building on the Commission’s guidelines.
The scheme is intended to partially compensate energy-intensive industries that have incurred carbon costs under the EU ETS (see table below). Carbon leakage risk reduction is the main goal; to avoid a situation where European companies relocate outside the EU/EEA to other jurisdictions to bypass or greatly reduce carbon emissions costs.
State aid beneficiaries can qualify for financial compensation by either implementing the recommendations of the energy audit report, investing at least 50 % of the aid amount in GHG emission reduction projects, or reducing the carbon footprint of their electricity consumption. For the latter, unbundled GOs and PPAs are recognised to fulfil the criterion.
German state aid criteria require that at least 30 % of renewable electricity be sourced within defined market boundaries – 80 % can come from Central Western Europe (Germany, Austria, Luxemburg), and 20 % from the rest of EU/EEA. This can encourage electro-intensive users to turn to the GO market.
German state aid scheme overview
Electricity consumption by sector is provided only in the 2020 report, while all subsequent reports do not divulge this data, as this criterion is no longer evaluated, Veyt learned from the German Emissions Trading Authority (DEHSt).
Since the introduction of the state aid scheme in 2013 and until 2020, the shares of the individual sectors have changed very little. However, starting from 2021, companies in the paper and pulp sector have started receiving the largest share of state aid at 29 %, iron and steel industry are stable at second place, receiving 24 %, while the chemical industry moved down from first to third place with around 23 %.
The non-ferrous metals industry had a share of 16.5 % of the compensation. While the clothing industry used to receive state aid until 2020, from then onwards it was replaced by mineral oil processing companies (6.3 %) and mineral processing industry (0.3 %) (see below).
From 2021 onwards, the DEHSt aggregates electricity consumption by company size (see below). In 2022, most applications were in the electricity consumption category up to 20 GWh. These 104 companies had 2 % of total electricity consumption in 2022. Some 98 companies in the 20 to 70 GWh electricity consumption bracket accounted for 5 %, while 37 large companies were in the 70 to 150 GWh bracket, responsible for 87 % share.
Overall, large companies use the largest share of electricity to produce eligible products, accounting for 97 % of total electricity consumption.
Nonetheless, since there is a statistically significant correlation between the state aid amount and electricity consumption, it is reasonable to assume that industries that received the biggest payments also had the highest electricity consumption.
In total, eligible (i.e. through external procurement, not self-generated) electricity consumption of German state aid recipients equalled to 74 TWh in 2022 and 88.7 TWh in 2021. If, out of this, 30 % of electricity consumption were proven with GOs, then this could put RES-E GO demand potential at 22.2 TWh in 2022, and 26.6 TWh in 2021. Data for 2023 has not yet been published, most likely because applications for the 2023 accounting year were submitted between 2 April and 30 June 2024.
For comparison, earlier Veyt estimated the potential for state-aid related GO demand from the Norwegian energy-intensive industry at 11 TWh in 2024 (Norway employs a location-based method under its state aid rules, therefore, this demand does not materialise on the market).
The allocated budget and the payouts for state aid for ETS costs have been increasing and are projected to grow as free allocation allowances are phased out, EUA prices rise, lifting the state aid amounts compared to the previous years (see below).
Notably, the German state aid budget exceeds that of Norway: if, for 2022, Norway disbursed approximately EUR 455 million to energy-intensive industries, Germany spent EUR 1.6 billion. At the same time, it is worth noting that Germany sets aside more funds for state aid to compensate for EU ETS costs than get used up.
Several applications were rejected due to sectoral/product non-eligibility, while other companies were classified as “companies in difficulty”, excluding them from state aid. Failure to meet the environmental requirements also led to applications being rejected.
Market impact
An annual comparison of the period November-May of the 2023 disclosure period with the respective months of the 2022 disclosure period shows an 18 % increase in the demand for RES-E GOs in Germany, totalling 143.9 TWh. State aid, while an important legislative driver, could only be responsible for one-sixth of this demand.
State aid directs German beneficiaries’ demand towards Central-Western Europe. Furthermore, an additional rule came into effect on 1 January 2023 requiring the cancellation of so-called coupled GOs if these were issued in Germany. In practice this means that if state aid beneficiaries want to use Germany-issued GOs to fulfil the 80 % criterion, they must secure a coupled delivery - the parallel delivery of the electricity and the associated GOs – which is stated in the GO after confirmation by an environmental expert. The guidelines covering the issuance, tracking and subsequent cancellation of these country-specific GOs were only clarified in May 2024. The first GOs coupled with the electricity delivery were submitted by German environmental verifier GUTcert for cancellation at the end of July 2024.
Demand for coupled delivery of electricity and GOs is likely to surge in Germany as a result of the new state aid rules (read the full Veyt analysis on the topic). However, given that a coupled GO is not a stand-alone tradeable product, it could mean that a certain amount of regular GOs could be diverted from the traded market to be cancelled as coupled with the electricity delivery.
On the other hand, demand for regular GOs that could have been driven by state-aid receivers would not materialise. This suggests that supply and demand drivers for tradeable German GOs related to this policy are balancing each other out.
Germany’s Federal Environment Agency (UBA) is yet to publish the number of coupled GOs that have been cancelled so far; indicatively, there was a recent power purchase agreement (PPA) announcement where the use of coupled GOs was confirmed.
Dwindling industrial output and energy-crisis era demand destruction could to some extent affect the potential GO demand of state aid beneficiaries as Germany faces the risk of deindustrialisation. Although there are signs of electricity demand recovering in Europe with the IEA projecting a 1.7 % growth in H2 2024, Germany could struggle to get back on track. German electricity consumption has been decreasing for two years in a row to 456 TWh (back to its 1994 level).
Since 2017, industrial production, excluding construction, is down 16 %, while a fifth of Germany’s remaining industrial production could disappear by 2030. Recently, Volkswagen has warned of plant closures, while Thyssenkrupp attempts to halve its steel production and lay off thousands of workers, to name a few.