Professionals in the member firms of KPMG International (“KPMG”) welcome the opportunity to comment on two public consultations from the European Commission (EC) entitled “EU Green Deal (carbon border adjustment mechanism)” and “EU Green Deal – Revision of the Energy Taxation Directive,” both released on 22 July 2020 for public comment.

KPMG’s comments on both Consultation Document can be found below, along with an overview of KPMG’s response to ESG issues through KPMG IMPACT.

The European Green Deal

The European Green Deal, adopted by the Commission on 11 December 2019, with the aim of transforming the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy with no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use.

KPMG response to consultations on the Energy Tax Directive (ETD) and Carbon Border Adjustment Mechanism (CBAM

Pursuant to the Green Deal, in July 2020 the European Commission (EC) issued two public consultations. The first was on revising the ETD as part of rethinking “policies for clean energy supply across the economy, industry, production and consumption, large-scale infrastructure, transport, food and agriculture, construction, taxation and social benefits.”1The second was on a possible CBAM to apply to certain sectors to address the risk of carbon leakage should other parts of the world not follow the EU’s increase climate ambitions.2

KPMG3 responded to both consultations. Our covering letters can be found here (ETD) and here (CBAM)

KPMG’s approach to environmental, social and governance (ESG) issues: KPMG IMPACT

KPMG strongly supports the need to reduce global carbon emissions sharply if the planet is to avoid catastrophic climate change. We have been passionate advocates for action on climate change for well over a decade, including at the 21st Conference of the Parties (COP21) in Paris in 2015, and KPMG firms have been proactively reducing our own collective emissions since 2007. We support the use of effective carbon pricing systems that reduce emissions efficiently and cost-effectively.

In order to address the pressing need for environmental, social and governance issues by business, KPMG has created KPMG IMPACT, a platform which brings together experienced professionals from KPMG firms across the globe to deliver industry leading practices, research and solutions to address the biggest issues facing our world. KPMG IMPACT aims to help clients fulfill their purpose and deliver against the Sustainable Development Goals (SDGs) so that all of our communities can thrive and prosper. All of which helps to give KPMG a transparent and consistent voice across five propositions that address ESG and Sustainability; Economic and Social Development; Sustainable Finance; Climate Change and Decarbonization; and IMPACT Measurement, Assurance and Reporting.