Policy
21.10.2025

Cautionary tale or model for Europe? How member states should react to Germany’s new electricity subsidy

The EU’s updated state-aid rules now permit direct industrial electricity subsidies (IESs), allowing Germany to introduce its planned ‘Industriestrompreis’. This policy brief presents new data on subsidies for industry in major EU member states, showing that the competitiveness threat of the planned German IES is limited. As industrial policy tools, however, IESs are argued to be blunt and fiscally expensive, compared to narrower instruments targeted either at decarbonisation, EU resilience or economic objectives. Other member states should hence refrain from simply copying the German IES. Ultimately, national subsidies like an IES can only help industry if swift and substantial progress is made towards a more durable policy framework characterised by a strong EU dimension.

  1. Introduction

For the first time, the European Commission allows national governments to directly subsidize electricity prices for industry. Lowering electricity prices has been a top priority for the EU for several years, in order to facilitate industrial competitiveness, decarbonise, and ensure resilience (cf. Draghi report, Competitiveness Compass, Affordable Energy Action Plan). So far, these efforts had been mostly restricted to lowering the structural cost of electricity, for instance by expanding electricity supply – which, however, takes time and does not provide much relief to struggling industry today. Following pressure especially from the German government, the Commission has therefore now changed state aid rules, allowing governments to directly subsidise electricity prices for certain industry sectors. The German government is set to introduce such a subsidy, its Industriestrompreis, soon.

While highly controversial, new calculations in this paper show that the planned German subsidy is not a large threat to the competitiveness of other member states. The reason direct electricity subsidies for industry were prohibited is their potential for distortions in the Single Market. German industry already benefits from generous energy subsidies via reduced costs for levies and network tariffs, and the new subsidy will come on top. Several other member states have therefore raised concerns that the German electricity subsidy could put their industry at a competitive disadvantage. However, German electricity prices are comparatively high to start with, and the volume of subsidies is restricted by the EU state aid rules. Therefore, the German Industriestrompreis is unlikely to pose a competitive threat to companies in most other member states.

Industrial Electricity Subsidies (IESs), as planned in Germany, are far from optimal policy, and should not be emulated by other member states.  IESs help industrial decarbonisation, but they have high fiscal costs and weaken important price signals. But most importantly, their long-term benefits for the economy and resilience are very limited. For many eligible companies, electricity subsidies are either not needed - or would be needed permanently, which is economically unsustainable. Regarding economic resilience, IESs are unnecessarily expensive by being national instead of an EU-wide scheme. Moreover, IESs do not target geopolitically important products, and ultimately, they do not provide a big enough incentive to ensure that manufacturing capacity actually stays in the EU. Overall, other EU countries should therefore refrain from introducing an IES such as the one Germany plans to.

Instead, other member states should adopt more targeted support schemes, delineated by objective. EU governments should be clear about the economic, climate and resilience objectives they want to pursue with certain (sub)sectors of their industry. Based on this, governments can design support schemes that are both cheaper and more effective than the comparatively blunt IESs. Moreover, in the medium term, support should increasingly be anchored at the EU level, to increase efficiency and avoid subsidy races. However, such a common EU-level approach is politically complicated and will take substantial time to agree. National-level schemes – especially if they avoid the drawbacks of the German IES - are hence an acceptable temporary fix, since they buy time until an EU-level solution can be agreed upon.

Without progress on clean competitiveness policy and lowering structural energy costs, national IES won’t help at all. Subsidising electricity prices temporarily will only help industry in the medium term if the EU’s Clean Industrial Deal is implemented, including with strong lead markets, an improved CBAM, strategic trade defense measures, and a predictable regulatory framework  (see previous JDC paper). Finally, as argued previously (e.g. here, here, and here), much of the commoditized energy-intensive industries in the EU will need to manufacture in the EU’s cheapest locations if they are to be internationally competitive. This will require at least some relocation of certain industry segments. Yet the discussion around relocation, and its positive effects for profitability, emissions and EU jobs, is woefully underdeveloped, and must be started in Brussels and other capitals as a matter of urgency.

 

  1. Possible scope of industrial electricity subsidies under EU state aid rules

The EU Commission has now allowed direct electricity price subsidies under certain conditions. Electricity prices in many EU countries remain substantially higher than in competitor regions – for industry about twice as high as in the US and China. Consequently, the EU and member states have been actively trying to lower electricity costs, to avoid further de-industrialisation and improve the international competitiveness of EU producers. Until now, policy efforts have mostly been restricted to reducing structural costs by expanding energy supply, as well as to lowering taxes, levies and network costs. In contrast, directly lowering the cost of procured electricity had not been permitted in the EU (with some important exceptions), to avoid a subsidy race and distortions in the single market. The EU state-aid framework from June 2025 (CISAF) now allows national governments to do this for electricity-intensive and trade-exposed sectors, although under relatively restrictive conditions, as listed in Box 1.

Box 1: CISAF conditions for industrial electricity subsidy (IES) schemes

  • Only electricity-intensive and trade-intensive sectors (as defined in the EU CEEAG Annex 1) are eligible.
  • The subsidy can only cover 50% of a company’s electricity consumption.
  • The wholesale price for the subsidised electricity may be reduced by no more than 50%.
  • The wholesale electricity price for the subsidised electricity may not fall below 50€/MWh.
  • An eligible company must invest in measures that facilitate the energy transition, amounting to at least 50% of the subsidy amount.
  • The subsidy amount can be increased by 10% as long as the company invests 75% of that amount in measures that facilitate the energy transition.
  • Aid can be granted for up to three years; payments must stop by the end of 2030.

 

The maximum IES under CISAF is substantial, but smaller than the German government aimed for. German policymakers had initially aimed at lowering prices to around 50€/MWh. However, with the restrictions listed above, CISAF does not allow reductions to this extent. At a wholesale electricity price of 80€/MWh (which was around the average price in Germany in 2024), a company could receive a maximum subsidy of ~15€/MWh with an IES under CISAF (ignoring other subsidies for now), i.e. reducing the wholesale price to ~65€/MWh (see Figure 1 below). Moreover, companies must invest half of the subsidy in the energy transition, leaving less money available for lowering product prices in order to compete internationally. By contrast, the forecast wholesale price in the US for 2025 is only ~34€/MWh.

Figure 1: Industrial Electricity Subsidy under CISAF by wholesale prices

Companies that already receive the indirect emission costs subsidy typically will not benefit from an IES. Companies in about 15 highly electro-intensive (sub)sectors can get reimbursed for the CO2 price that they pay indirectly via the price of electricity they procure, a subsidy known as “indirect emission cost” compensation in the EU (“Strompreiskompensation” in Germany). These include many of the largest electricity consumers, like steel, chemicals, copper, or paper manufacturing. These sectors would technically also be eligible for a new IES. However, companies cannot receive both subsidies fully; aid must stay below the highest of the two aid ceilings – which typically will be the indirect emission cost compensation. In other words, an IES scheme under CISAF would be a substantial alleviation for some electricity-intensive companies – but it would change nothing for sectors that already receive the indirect emission cost subsidy (for details and numerical examples, see Box 2).

Box 2: Indirect Emission Cost compensation versus IES under CISAF

Member states can compensate their most electricity-intensive industries for a part of the CO2 costs passed on via electricity prices, to mitigate the risk of carbon leakage. 16 member states have deployed this subsidy; the highest amounts in 2023 were spent by Germany with ~€1600 million, France with ~€604 million, and Poland with ~€373 million. The aid ceiling per MWh differs between member states as it depends on the average CO2-intensiveness of each country’s electricity generation.

At a price of €84 per ton of CO2 (about the EUA forward price for 2024), the maximum Indirect Emission Cost subsidy amounts to ~46€/MWh in Romania, ~34€/MWh in Germany, and ~22€/MWh in Italy, for instance (note that these figures depend on further parameters explained in the accompanying online chart, and do not include the possible so-called ‘super-cap’). Absent crisis-level wholesale prices, these aid volumes are higher than the IES subsidy under CISAF, i.e. governments cannot provide any extra subsidies for companies already benefitting from the maximum indirect emission cost subsidy. In cases when wholesale electricity prices rise or CO2 prices fall, CISAF may allow higher subsidies (see Figure 2 below), but the hope is that such scenarios can be avoided in future.

Note that the parameters for the indirect emission cost compensation (currently based on electricity-intensiveness data from ~2017), will be updated later this year, likely reducing the maximum aid limit. The Commission also plans to expand the number of eligible sector (which is currently the subject of much industry lobbying).

 

Figure 2: Indirect Emission Cost compensation versus IES under CISAF

Figure 2 depicts the situation for Germany; the accompanying online tool shows the subsidies and data for all other member states

 

Figure 3: Sectors eligible for IES and for Indirect Emission Cost subsidy

 

The maximum annual cost of IESs would be sizeable for member states with a strong industrial base, but typically smaller than for the indirect emissions subsidy. Maximum annual aid volumes of an IES, and hence fiscal cost, would naturally depend on the industrial electricity consumption profile of each member state. In Germany, for instance, a rough estimation suggests that the IES would cover about 50 TWh and cost ~€0.8bn per year[1] at current wholesale prices. For comparison, the indirect emission cost subsidy amounted to ~€1.6bn in 2023. Overall, the maximum IES support volume is lower than what the German government had hoped for. The scheme initially envisioned by the Ministry of Economics, without the restrictions now imposed by CISAF, was budgeted at around €10 billion until 2030. With the new restrictions, the Ministry reportedly revised the cost estimate to about €4 billion until 2030. Nonetheless, the IES remains a substantial subsidy, and given the relatively small group of beneficiaries, the average aid per German company is set to exceed half a million euros per year.

3. With the planned IES, what will the final electricity cost be for eligible German companies?

Other member states are concerned that the planned German IES could disadvantage them. Germany already provides larger subsidies than many member states for a variety of industrial policy objectives. Germany’s plan to introduce an IES are therefore critically observed by other capitals. The planned German IES, combined with other subsidies, is indeed set to lower the electricity cost for German industry substantially. Moreover, the IES cannot be viewed in isolation, since electricity costs broadly consist of three elements: cost for electricity itself, network cost, and taxes and levies. The IES (and the indirect emission cost subsidy) tackles the first element – but network costs, as well as taxes and levies, are also currently subsidised heavily in Germany. Taken together, these amount to substantial alleviations for industry.

In Germany, all industry pays little in taxes and levies, compared to households. And electricity-intensive industry pays almost nothing. Germany has lowered electricity taxes for all industry to the EU minimum and started financing the sizeable ‘renewables surcharge’ from the national budget instead of charging consumers. In 2024, general industry paid ~15€/MWh in levies and taxes (which is expected to increase in 2025 to 22€/MWh though). However, electricity-intensive industry can get additional alleviations: for companies eligible for the planned IES, the total tax and levy burden can be lowered to about ~4€/MWh (author’s own estimation), merely around 3% of what households pay. Notably, one side effect of this burden-shifting from industry to households consists in slower electrification of households (such as adoption of heat pumps and EVs).

Figure 4: Electricity taxes and levies in Germany for industry, with households shown for comparison
 

 

Source: BDEW June 2025, author’s own calculations. Note: does not depict network costs, which are covered in the section below. Assumptions for alleviations for electricity-intensive companies: ~85% discount on offshore and combined heat and power (CHP (KWKG)) levies, and a >90% reduction for financing the network cost subsidy.

Network costs are likewise heavily subsidised for German industry, and for some companies even by 90%. Network costs are sizeable and growing in the EU, given the costly investments needed to build and reinforce grids. However, as with taxes and levies, these are heavily subsidised for industry in Germany (albeit in myriad and complex ways). About 400 highly electricity-intensive German companies get a whopping 90% subsidy for their network costs (“Bandlastprivileg”), financed by all other consumers. While this subsidy, at €1.4bn per year, provides wrong incentives  and is under review by the German grid regulator, the government has vowed to keep high network subsidies for these companies in place. For German companies not eligible for this massive subsidy, network costs are substantial, but additional alleviation is planned, with the goal of subsidising half of all network costs. To this effect, the government is aiming to spend €6.5 billion per year to lower network tariffs over the coming years for all consumers, which will also benefit industry.

Together with subsidies for network costs and levies, the German IES would decrease electricity prices by about a third. As shown in figure 5, with the targeted 50% cut in network tariffs and the ~80% cut in taxes, the IES would bring the German electricity cost to below the level of the EU average (EU considered without subsidies). This alleviation is less than what is received by the smaller number of German companies eligible for the indirect emission cost compensation and the ‘Bandlastprivileg’, for which prices are lowered by almost 50% (also shown in Figure 5). Nonetheless, a >30% alleviation represents a substantial reduction in energy cost.

Figure 5: Effect of German subsidies on final electricity prices

Note: Source: Eurostat (in 2023 prices) and author’s own calculations. Data for consumption band 70-150 GWh.

  1. Is the German IES a threat to companies in other member states?

With the IES, German subsidies for wholesale prices are set to be larger than those provided by other member states. Unfortunately, data on electricity costs and subsidies is not readily available in the EU (see Box 3). Therefore, this paper conducts some back-of-the-envelope estimations for Germany, France, Italy and Spain (the four biggest economies in the EU, which also have the largest energy-intensive sectors). Looking solely at subsidies for energy supply,[2] ermany’s planned IES is expected to be larger than the subsidies in Italy and France (Spain is not planning to subsidise wholesale prices at the moment), as shown in figure 6 below. However, given high German wholesale prices to begin with, costs in Germany will likely remain higher than in Spain and France next year.

Figure 6: Spot market electricity prices and subsidy-adjusted values

Note: For Germany, the IES subsidy is calculated as explained in Box 1. For France, it is assumed that under ARENH (Accès Régulé à l'Électricité Nucléaire Historique), companies procured 60% of their energy at 42€/MWh, the rest at spot prices. For Italy, it is assumed that eligible companies can procure ~30% of electricity at ~65€/MWh under the ‘Energy Release 2.0’ scheme. Future prices for 2026 are from EEX for Cal-26 (03.09.2025), spot prices from Fraunhofer ISE (energy-charts.info), and for Italy the PUN Index GME is used to aggregate prices over bidding zones.

In France, the main vehicle for subsidies are tweaks to the price of nuclear electricity. Each year, the ‘ARENH’ system obliged the state-owned company EDF (which owns the nuclear fleet) to sell 100 TWh, about a fifth of total French electricity production, at just 42€/MWh, incurring a significant loss borne ultimately by taxpayers. This substantially reduced electricity costs for all French companies. ARENH, however, will be replaced by the end of 2025 with a more market-oriented system, which will result in significantly lower subsidies.[3] Yet, despite lower subsidies, France is in a comfortable position for 2026 compared to other EU countries, given its low predicted wholesale prices (enabled by previous subsidies for building nuclear capacity via EDF). However, it should be noted that uncertainty is higher now, and if French wholesale prices unexpectedly increase – as they did in 2023 because of nuclear power outages and low hydro power – the burden on companies could be high. 

For Italy, the EU Commission recently approved the subsidy scheme ‘Energy Release 2.0’. This offers a fixed volume of electricity at ~65€/MWh to about 3400 electricity-intensive companiesI. The 23 TWh is estimated to cover about 30% of these companies’ electricity consumption, which corresponds to a subsidy of ~12€/MWh. However, this is of only marginal help, given predicted wholesale prices of a whopping 104€/MWh for 2026. Moreover, companies must ‘pay back’ the electricity volumes they receive, by financing renewable energy projects, which reduces the effective alleviation for companies further (this dampening effect is not shown in Figure 7). Italian electricity-intensive companies that compete with German ones are therefore potentially quite vulnerable to the introduction of IESs in Germany.

In Spain, there are no subsidies for wholesale prices in place or planned. In contrast, in 2022 and 2023, Spain massively intervened in wholesale markets, on the basis of the so-called Iberian exception: Spain (and Portugal) had capped the price of natural gas used for electricity generation (and reimbursed gas power plants), substantially lowering electricity bills for all consumers. In non-crisis times, such schemes are disallowed by the EU’s rules state aid rules. But this absence of subsidies is not a major setback for Spain, which enjoys comparatively cheap electricity thanks to its high solar and wind power potential, at forecasted wholesale prices of around €60/MWh.

By volume of value added in manufacturing, these four countries are followed by Ireland, Poland, the Netherlands, Sweden, Austria, Belgium, and Czechia. Poland is set to introduce a similar scheme to Italy (but covering only about 6.2 TWh), but details are still scarce. To the author’s knowledge, no other member state in this list has so far announced its intention to implement an IES under the CISAF provisions.

Overall, given high German wholesale prices, the planned IES does not pose a competitiveness threat for other member states – with some exceptions. Wholesale prices are high in Germany to start with, so even with the IES, they will stay higher than in many other member states. However, for countries with high wholesale prices – such as Italy – the potential threat from a German IES is more acute, especially if they are not planning large-scale subsidies of their own. For Italy, the planned German IES might make a tough situation for industry even tougher. Given limited fiscal space, it will be crucial for countries like Italy to opt for cost-effective mechanisms, if any, when lowering electricity prices with additional subsidies.

Box 3: Data shortages complicate cross-country comparison for electricity-intensive industry

Obtaining reliable data on companies’ electricity costs in the EU is surprisingly difficult. The EU Commission and the Draghi report rely on Eurostat data, for instance. However, the Eurostat data set does not fully capture subsidies like emission cost compensation, nor (all) subsidies on network cost – seemingly only those that appear on companies’ electricity invoices. Moreover, different data sets appear to indicate different figures on costs: levies and taxes for German industry, as reported by the BDEW (see above) are almost 50% lower than the figures reported by Eurostat. As we have argued in previous papers, the EU needs improved data capacities to enable the effective design and evaluation of industrial policies.

 

Figure 7: Electricity prices according to Eurostat, i.e. without many subsidies

Source: Eurostat. Inflation adjusted, base year 2023. Consumption band >150GWh.

5. What would the impact of IESs be on climate, EU resilience and the economy?

IESs are not especially distortive for the competitiveness of other member states - but still a weak policy choice. While the IES has clear (but modest) upsides for industrial decarbonisation, its economic and resilience benefits are limited for both the implementing country and the EU as a whole. 

An IES has, overall, a positive effect for industrial decarbonisation. Over the scheme’s short, three-year horizon, clean electricity supply is largely fixed. Since an IES can raise industrial electricity demand without immediately expanding low-carbon generation, fossil-fired electricity generation and hence emissions can increase. Against this, however, three drivers push in the other direction:

First, cheaper electricity can nudge firms that still rely on fossil fuels to electrify processes. This typically cuts emissions, even if the electricity mix is still partly fossil-based. However, it should be noted that this positive effect is somewhat reduced given that the subsidy is only available for three years, while electrifying production typically requires capital investments of a magnitude that needs to be recouped over a much longer time span.

Second, the EU’s electricity mix is cleaner than those of many countries outside the bloc. To the extent that the IES keeps production within the EU and prevents an increase in production in these third countries, it lowers emissions.

Third, IES facilitates pioneering decarbonisation projects Europe. The EU is a global leader for industrial decarbonisation projects, and the conditions for decarbonising industrial production are better in the EU than almost anywhere – except for energy costs. By easing the energy-cost bottleneck, the IES facilitates the scale up of clean production in first-of-a-kind projects. This creates learning effects that ultimately lower global cost curves and consequently emissions (similar to how early German subsidies for solar PV lowered global costs for the technology).

Fourth, beneficiaries must reinvest half the subsidy they receive in climate-friendly measures. These investments include, for instance, energy storage and demand-side flexibility, and reduce the cost of the electricity system (while adding some administrative burden, however). Taken together, these four drivers result in – at least a modest - climate benefit.  

The economic case for an IES, however, is weak. First, higher consumption by subsidised producers can increase electricity prices paid by other firms and households (and to a limited extent also in other member states). Second, subsidies only make sense economy-wide if they generate sizeable spillovers or are strictly temporary until competitiveness returns. Neither seems to apply here. Evidence for spillovers and cluster effects is weak; most energy-intensive goods can likely be imported without disrupting downstream value chains. Where importing is not possible, because a domestically produced good is truly essential (like some specialised steels for instance), producers should be able to pass on higher electricity costs to buyers  - rather than requiring subsidies.  

Second, the IES is not a bridge to lower prices; it’s a pause. Therefore, for many companies, subsidies would be needed permanently. The CISAF communication claims that the three-year subsidies it permits are only needed “[u]ntil the decarbonisation of the Union’s electricity system fully translates into lower electricity prices.” For firms in some regions, this may well be true – for these, the IES is an effective tool for buying time until prices are lower and the regulatory environment has improved. However, in many EU regions that currently harbour heavy industry, electricity prices in three (and even 5-10) years are unlikely to be markedly lower than today. That’s because many of these regions are characterised by mediocre renewable potential, high population density, costly measures to increase flexibility in the electricity system and rising costs for electricity grids. Moreover, even if prices do drop in current industrial hubs, prices will likely drop faster in other regions (as argued here, here or here, for instance).

The competitiveness problem in countries like Germany due to the cost of clean electricity will therefore persist and possibly even intensify in future - and only be put on pause by an IES. Many energy-intensive plants that are struggling today would hence need permanent support to remain viable – an unsustainable use of public funds, and one that also ultimately fails as a durable jobs policy.

As a resilience instrument, IESs are blunt and incomplete. All sectors with high electricity- and trade-intensiveness are eligible for IESs, as defined in the CEEAG Annex. This happens to include some sectors with geopolitical importance, such as certain chemical and some metal production, for which the EU should retain at least a base capacity in manufacturing. However, the list omits certain strategically important products and also includes sectors that are not, ranging from biscuits and fruit juice to woven textiles and leather clothes to the manufacture of ceramic tiles (see Figure 3). The IES is therefore a blunt, incomplete and overly expensive instrument for improving resilience.

6. How to move forward

Member states should refrain from simply emulating the planned German IES. While IESs have positive effects on industrial decarbonisation, they are by no means optimal. Their blunt, undifferentiated support also reflects a lack of clarity about long-term policy objectives. Other governments should, instead, clearly define the objectives for their various industrial (sub)sectors, with a coherent perspective for 2030 and beyond. Based on this, mechanisms and targeted subsidies (if any) can be introduced that are better suited to reach these objectives, compared to the IES. Different mechanisms are needed, depending on the objective:

For supporting the economy, member states should direct support to worthwhile (sub)sectors. Subsiding energy-intensive industries only makes sense if there is a realistic chance that these companies will regain international competitiveness soon, or if they have clear positive spillovers (see section above). Governments should objectively assess whether this is the case for their various (sub)sectors, given changing world markets and the energy transition. For sectors where this is not the case, there is no point in supporting them with an IES. Public funds should instead be used to support affected regions to transition to more profitable activities and provide new opportunities for workers. One promising strategy for struggling energy-intensive industry (which we argued for here) consists in importing particularly highly energy-intensive intermediate products, while keeping downstream industry. For example: keep your steel industry, but start importing clean iron sponge.

For decarbonisation of industry, member states should strengthen their climate-focused industrial subsidies. For sectors that still have to electrify, this can take the form of Carbon Contracts for Difference. By relying on an auction system, CCfDs give more bang for the buck, and their 15+ years’ duration provide much more planning predictability than with the three-year IESs. Other effective support channels include, for instance, lowering the cost of clean hydrogen via the national window of the EU Hydrogen Bank, or absorbing higher costs for green base materials in public procurement.

Member states should act jointly on a narrow list of sectors to strengthen resilience. First, supply-chain diversification should be incentivised more, which is often sufficient to ensure resilience (one channel to do this are resilience provisions in public procurement, as piloted in the Net-Zero-Industry-Act for clean tech). For cases where this doesn’t suffice, the EU Commission should propose a dedicated resilience mechanism. This would entail that an independent body (which is more immune to lobbying) should identify geopolitically important products for which manufacturing is at risk of leaving the EU. By providing subsidies at the EU level for a clearly defined and narrow set of products, a base manufacturing capacity can be ensured in the EU, while avoiding national duplications and subsidy races. To keep efficiency high and select those manufacturers that can offer production at the lowest price, subsidies should be allocated via a competitive process such as auctions.

Most importantly, national subsidies will only help if progress is made towards a more durable policy framework with a strong EU dimension. The overarching objective must be for EU industry to be decarbonised and internationally competitive, ultimately without subsidies. This requires speedy delivery of the actions outlined in the Clean Industrial Deal across the EU. These include structurally lowering energy costs, cutting red tape, trade measures like improving CBAM and dealing with global overcapacities, and creating a conducive regulatory framework with clean lead markets. The EU runs the risk of not implementing these measures forcefully enough. Upcoming legislative files, especially the Industrial Decarbonisation Accelerator Act, need to have a level of ambition commensurate to the challenges industry faces.

Finally, in the medium term, national and EU policy for energy-intensive industry must reckon with the new economic geography induced by the clean energy transition. Some foreign regions are sunnier, windier and less densely populated, like Australia and parts of Africa. Even if the Clean Industrial Deal is fully implemented, international competition for highly energy-intensive industry will remain very tough for the EU. Some parts of EU industry will therefore only survive in the long term if they manufacture in the EU’s best, i.e. cheapest, locations. The specifics of the EU framework that enables such relocation should be developed now. A central element will be to anchor the allocation of subsidies – like CCfDs – at the EU level (if not their financing). A strong role for the planned “EU Industrial Decarbonisation Bank” in the next EU budget will be a key step in that direction.

  1. Conclusion

Energy price subsidies are often depicted as less intrusive and interventionist than other forms of industrial policy. But IESs are, in fact, also highly interventionist, in that they allocate substantial amounts of the public purse to a small group of beneficiaries. They should therefore be subject to as much scrutiny as other industrial policy measures. The analysis in this Policy Brief suggests that IESs are not particularly effective, compared to tools that are specifically targeted at either economic, resilience or decarbonisation objectives. But regardless of whether national subsidies are implemented, swift action at the EU level to advance the clean competitiveness agenda will be indispensable.

 

[1] The total electricity volume of German companies covered by the CISAF sectors (i.e. those listed for example in the CEEAG annex) can be roughly approximated by the volume covered by the German “Besondere Ausgleichsregelung” (special equalization scheme), which was ~106 TWh in 2023. However, at a wholesale price of 80€/MWh, only German companies covered by the CEEAG list that are not eligible for the indirect emission costs would benefit from the ISP (see discussion above). Subtracting these volumes, which were  ~55 TWH in 2023, yields ~51 TWh of electricity. With an IES-CISAF subsidy of ~15€/MWh (corresponding to a wholesale price of 80€/MWh), the yearly cost for the German IES would be ~€0.8bn per year, equivalent to ~€2.4bn over three years (note that these figures do not include the indirect emission cost compensation subsidy). With increasing wholesale prices, the CISAF subsidy increases, naturally. Eventually, companies benefitting from indirect emission cost compensation would also start to benefit from the CISAF-style subsidy, substantially increasing the support volume. For instance, at wholesale prices of 120€/MWh, this would put the German IES at ~€2.2bn per year.

[2] For the sake of simplicity and due to the limited amount of harmonised data available, as discussed in Box 3, this comparison disregards taxes and levies as well as network costs. Moreover, the indirect emission cost subsidy is disregarded here, since it only affects a small set of companies, and all four depicted countries have schemes in place that are tightly governed by a single set of EU rules.

[3] The ARENH ‘replacement’ consists of two elements. From 2026, France’s new Versement Nucléaire Universel scheme will capture and redistribute the profits of EDF above certain thresholds. If wholesale prices stay low, EDF will not generate much profit, and there will consequently be only a slight alleviation. Additionally, EDF has started to offer long-term contracts at a price of ~70€/MWh. However, take-up is low, given that markets predict wholesale prices of only around 60€/MWh for next year.

CC Photo: Nikola Johnny Mirkovic, Source: Unsplash