The European Commission’s general approach to broadening the application of the State Aid Guidelines is welcome. However, there is good reason to stress the importance of the General Block Exemption Regulation (GBER) and to warn against an excessive degree of complexity.
The Confederation of Swedish Enterprise wishes to stress the importance of the State Aid Guidelines and the associated provisions of the GBER. These set the framework for the opportunities for Member States to be able to stimulate green investments and tax systems, thus enabling the combination of an ambitious climate policy and continued competitiveness for the European business community.
In its proposal, the European Commission states that it intends to apply a ”simplified approach” to the assessment of State Aid in the form of environmental taxes if these are harmonised. Here, it is important that this simplified approach does not restrict the opportunity for Member States’ to allow exceptions.
The opportunity to offer reduced taxes or parafiscal charges for industry is a prerequisite for combining ambitious climate goals with high general energy tax rates, while at the same time safeguarding the competitiveness of industry and avoiding carbon leakage. It is therefore of utmost importance that these opportunities for exemptions are not weakened or further complicated.
Concerning the use of competitive tendering, the Confederation of Swedish Enterprise views this is as a positive proposal. It is also good that the European Commission is opening up compensation models that are not based entirely on ex-ante regulation, so that Member States are allowed some flexibility in how the aid is designed.
Another important element concerns technology-neutral instruments for biofuels. The Confederation of Swedish Enterprise would like to point out the importance of biofuels continuing to have the opportunity to compete on equal terms within the internal market.
Consultation with the business community and its representatives is a matter that the Confederation of Swedish Enterprise supports in all contexts where legislation is concerned at EU level; this is also the case in this dossier. We believe that the European Commission’s requirements for mandatory consultation are at times overly rigid and do not give the Member States sufficient flexibility, which may lead to unnecessary delays in introducing measures. The most important thing is that the views of stakeholders are brought to the attention of decision makers, something that can be achieved in many ways. The ‘pursuit of the best’ must not become the ‘enemy of the good’, and there is often a strong case for keeping bureaucratic processes to a minimum.