Objective: Carbon neutrality

In our last article on the carbon market we explained the different phases of the ETS since its inception in 2000. In June 2021, the European Commission published the “Fit for 55” package, which targets the reduction of greenhouse gases by 55% (compared to 1990 levels) by 2030. This legislative package sets out the road map towards the final objective: achieving carbon neutrality by 2050. As the price of carbon continues to rise, exceeding 60€/T (EUA Dec21) at the end of August, the European Commission is submitting new proposals to achieve its objectives. In this article, we will look at the main measures that will be examined by the European Council and the European Parliament between now and 2023, and the consequences they could have on the strategies of member states, companies and consumers.

The carbon market is constantly changing and very uncertain. The targets to be achieved are clear, the means to achieve them not so much. Since the establishment of the ETS, the obligations on Member States have been constantly evolving and becoming more complex. In July 2021, as part of the “Fit for 55” package, the European Commission proposed an ambitious legislation with binding emissions targets. For the time being, the reception of these changes seem to be favourable and, by 2023, the European Council will examine the legislative acts of this package and will start negotiations with the European Parliament to finally reach a common agreement that will take into account the different economic situations of each member state.

Let us now look at the measures that seem to be becoming more complex for some actors, as well as the new measures envisaged.

  • ETS market

The ETS market will see a decrease in the number of emission allowances put into circulation as soon as the new legislation comes into force. The Commission is proposing to lower the cap on allowances from the current 2.2% to 4.2% per year. The stability reserve, which was put in place to avoid a surplus of allowances and to increase the price of carbon from 2019, will also be strengthened. The aim is to avoid a new shock and or to end up with a price per tonne of carbon that is too low… These initiatives will contribute to keeping the carbon price high and stable, and even increasing it in the years to come.

Inclusion of the maritime sector into the ETS: A major first as, to date, the emissions of this sector are not covered by any regulation.

From 2027, the aviation sector would see its free allowances abolished. Currently, airlines operating intra-European flights are benefitting from 80% free allowances since their entry into the market in 2012.

  • Reform of the energy system

Reform of the energy system is a key issue in the ‘Fit for 55’ package. Energy production and utilization accounts for 75% of emissions in the EU. Renewable energies will have to reach a share of 40% in the European energy mix compared to 32.5% currently. Renewable energies will have to be present in all sectors and not only in the electricity sector; for example, in the building sector, renewable energies will have to represent 49% of the energy used in the building sector. This energy system reform aims to accelerate the deployment of renewable energy.

  • Parallel market for emissions in the road transport and building sectors

A second carbon market would be created for the road transport and building sectors, as bringing them into the current market would not provide sufficient incentive to reduce their emissions in view of the price per tonne of carbon (€60/Tn). By creating this parallel market which targets suppliers of fuel for road transport as well as suppliers of fuel oil for heating buildings, the price of a tonne of carbon could exceed €200/Tn. No free allowances will be granted but a mechanism will be put in place to avoid price peaks. This new measure is not unanimously supported: there could be serious consequences for households, and some even fear public outrage. Indeed, consumers would see a rise in petrol prices, as well as an increase in their heating bills.

  • Carbon border adjustment mechanism

From 2026, there will be a carbon tax mechanism at the borders. The principle is to impose a carbon price on certain products imported from outside the EU. With this mechanism, the EU is trying to avoid carbon leakage (i.e., companies relocating their production outside the EU) to preserve European competitiveness and to encourage third world countries to reduce greenhouse emissions.

Concrete, steel, iron, aluminium, fertiliser and electricity sectors will be the target of this carbon border adjustment mechanism. Each year, these sectors import 170 million tonnes of CO2. To date, some of these activities benefit from free quotas. There are plans to phase these out over ten years, as the carbon border tax mechanism comes into force. Both mechanisms protect industries, and in the eyes of WTO law, it would not be possible to maintain them simultaneously. The aim is for these industries to switch to less carbon intensive production.

The carbon tax mechanism at the borders will inevitably have an impact on the ETS market.

Measures that evolve within a framework that must be coherent and balanced for the EU member states. Some stakeholders doubt the effectiveness of the border mechanism, not to mention those who fear a revolt by households and SMEs, which are in the front line. The European Commission is already proposing putting in place a Social Climate Fund for those most affected. With the upward trend and high liquidity of the ETS market, hedge funds are increasingly present in the ETS market; large electricity consumers blame them for the soaring CO2 price and call for the law to introduce a limit on extreme position taking.

In the eyes of the Third World, it would appear that awareness of greenhouse emissions reduction is beginning to have some effect. China is launching its own carbon market, and this is bound to have implications for Europe, the pioneer of the carbon market.

Finally, EU member states are taking the climate threat seriously and developed countries are moving seriously towards decarbonising their economies. Consumers will have to design supply strategies that take into account the rising carbon market. Producers will have to integrate these emission limitations into their long-term strategies, and retailers will have to align themselves with the sensitivity of the carbon market. The world is changing…

Ana Haya Sauvage

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Each month, one of our experts publishes an article describing his view on a specific topic of the constant changes taking place in the energy market, with special focus on the French market.

Profesional Experience & Education

Diego graduated in Political Economy at King’s College University (London – 2021). He started his professional career in a family business in Madrid as an operations manager. Diego then studied a Master in Management and Master in Computer Science at IE University (Madrid – 2022), during which he participated as an Information Technology (IT) intern in a startup. In May 2023, Diego joined the HES team as an intern specialised in programming models. In his first project, he developed a software tool for modelling the unavailability of the French nuclear fleet. Afterwards, Diego has also participated in the development of new software tools for modelling price curves, generation asset performance and other topics related to the energy market. 

Diego Marroquin

Junior Consultant

Diego Marroquín

Profesional Experience

Céline joined Haya Energy Solutions in November 2021 as marketing and administration manager. She had a first professional experience in the tourism sector as a social media manager. At HES, her activities are focused on the development of the company’s visibility at European level through: commercial actions, content marketing and development of brand strategy. Céline is also involved in the management of the company’s communication: optimisation of the website (WordPress & Elementor), LinkedIn, publication of the monthly newsletter and the organisation of conferences. Céline participates in energy projects with the clients and acts as coordinator and project manager. Finally, she is in charge of administration (accounting, expenses management, invoicing).   


Céline graduated in Spanish and English Philology at La Sorbonne (France – 2018) and holds a Master’s degree in Project Management and Cultural Tourism (Clermont-Ferrand/ Buenos Aires – 2021). 

Céline Haya Sauvage

Marketing Responsible

Céline Sauvage

Investment Advice

“Decarbonization of the Energy and Transport sectors is arguably today’s main economic driver for the industry.”

Profesional Experience

His career started in civil engineering as a Project Manager in France, Martinique and Australia. Afterwards, he became the General Manager of a subsidiary in Venezuela. In 1992, he established Dalkia in Germany (district heating, cogeneration, and partnerships) and represented Véolia in Thailand. In 2000, he opened the commercial office of Endesa in France to take advantage of the liberalized retail market. From 2006, as a development Manager at Endesa France, he led Endesa’s plan for Combined Cycle generation in France and developed the wind and PV portfolio of Snet at the same time. Philippe Boulanger worked for 3 years at E.ON’s headquarters coordinating the company´s activities in France. He was strongly involved in the French hydro concession renewal project. As a Senior Vice President – Project Director at Solvay Energy Services from April 2012 to February 2014 he was in charge of the H2/Power to gas and European direct market access deployment projects. Philippe has been an HES expert since 2014.


Philippe Boulanger holds engineering degrees both from the Ecole Polytechnique and the Ecole Nationale des Ponts & Chaussées (France) and has a combined experience of more than 25 years in energy and infrastructure. In addition to English, Mr. Boulanger is fluent in French, German & Spanish.

Philippe Boulanger

Electricity Expert


“The world is changing. New investors pay particular attention to the energy sector while historical actors adapt their position to the market.”

Profesional Experience

Antonio started his career in the electricity sector in 1991 working as a member of the General Manager’s team at Sevillana de Electricidad (Spain). In 1997, he was appointed head of commercial regulation at Endesa Distribución. In 2000, he joined the mergers and acquisitions (M&A) department of Endesa Europe. He was appointed Managing Director of Endesa Power Trading Ltd (UK) in 2003. A year later, he became responsible for energy management at SNET (France). In 2008, he was appointed Managing Director of SNET (France). In 2009, he became Director of Corporate Development at E.ON France. In 2011, he founded Haya Energy Solutions (HES), a consulting firm focused on optimising the energy management of consumers, producers and retailers of gas and electricity. From 2015 to 2018, Antonio combined the consulting activity at HES with the general management of 2 production facilities in France (2 CCGTs x 410MW), owned by KKR. At the end of 2018, he joined Asterion Industrial Partners, an infrastructure investment fund, as an operating partner. Antonio currently devotes most of his efforts to the Asterion Portfolio, while advising through HES companies in the energy sector in France, Italy, Germany, UK and Spain. 


Antonio graduated from the Escuela Técnica Superior de Ingenieros of Seville (Spain) and holds an MBA degree from Deusto University (Spain). 

Antonio Haya