| 06.10.2025 | ENERGY COST REBALANCING This EIUG position paper sets out the cost of various levies and obligations on electricity suppliers and various stakeholder views on how to ‘rebalance’ them. The EIUG’s position is for the Government to rebalance these costs to the Exchequer, and not on to gas prices. | |
| 06.08.2025 | Two-Way Contract-for-Difference to Reduce Wholesale Electricity Prices The EIUG has published a position paper addressing the wholesale electricity price differential between Great Britain and European countries that is putting GB energy intensive industries (EIIs) at a competitive disadvantage. It proposes a Two-Way Contract-for-Difference (CfD) to resolve this issue. The Two-Way CfD reduces EIIs exposure to wholesale electricity prices by providing them with an agreed wholesale price achieving parity with the lowest wholesale electricity prices in relevant European countries. | |
| 15.04.2025 | EIUG Response to the Review of OFGEM The EIUG recommends including whether its regulatory changes have impacted specific consumer groups disproportionally, in particular energy intensive industries (EIIs), instead of a welfare economic approach only, into Ofgem’s KPIs, Parliament to introduce regular scrutiny by Parliament of Ofgem’s performance and including those EIIs exposed to the risk of carbon leakage in the Ofgem duty to protect the interest of certain customers. | |
| 09.04.2025 | Response to the Consultation on the proposed Gas Shipper Obligation As the gas shipper obligation is essentially a mechanism to raise finance for the hydrogen production business model, the EIUG believes it would be more appropriate and efficient for this model to be funded directly through the Exchequer, rather than an obligation on gas shippers. The EIUG considers that the GSO will put gas-intensive industries at risk of carbon leakage and Government must therefore exempt gas quantities shipped to these industries from its charges. The EIUG strongly considers that the GSO poses a serious risk of carbon leakage by increasing energy costs for gas-intensive industries, thereby undermining their global competitiveness. it is essential that gas volumes supplied to such industries are fully exempted from GSO-related charges. Without such an exemption, there is a clear risk of production moving abroad, investments going elsewhere and job losses, weakening further the UK’s industrial base. | |
| 03.10.2025 | Response to the Consultation on Carbon Leakage The majority of EIUG members prefer to continue to use the existing Carbon Leakage List, this is because they consider the quality of the UK data for their sectors – in terms of accuracy and reliability – too poor to justify a change to a carbon leakage list based on UK data. Those who prefer a list based on UK data, such as the cement and lime sector, find their sectoral data used to determine their risk of carbon leakage generally accurate. The EIUG fundamentally disagrees with the Authority’s arguments not to make an adjustment to CLI values for CBAM sectors and recalculate Free Allocations from 2027 on this new basis. | |
| 07.02.2025 | Response to the House of Lords Industry and Regulators Committee’s Call for Evidence into The Energy Grid and Grid Connections The EIUG’s main point is that access to adequate electricity grid infrastructure represents a major constraint for industry to decarbonise and Government to reach Net Zero. New or upgraded transmission or distribution network connections are required to enable industrial users to deploy a range of technologies, such as electrification, hydrogen and CCUS, critical for reducing greenhouse gas emissions in industrial and manufacturing sectors. The UK risks that companies decide to put their investments in industrial decarbonisation in other countries because the network operators cannot provide the connection in time. | |
| 29.11.2024 | Modern Industrial Strategy green paper The EIUG does not believe the Industrial Strategy green paper’s approach and focus on the eight sectors selected adresses the relative slowdown in UK productivity compared to other countries. More horizontal policies to create a pro-business environment, such as people & skills, innovation, planning policy and especially energy policy reform can better address it, but do need a targeted focus. | |
| 12.09.2024 | EIUG Autumn Budget and Spending Review Submission 2024 The EIUG has sent its submission to the autumn budget 2024 to Treasury. The submission proposes changes to the network charges compensation scheme, continuation of the compensation scheme for the indirect emission costs due to the UK ETS and carbon price support support mechanism, abolishing the latter, changes to the CBAM proposals and establishment of an UK ETS Innovation Fund. | |
| 17.06.2024 | EIUG Response to the CBAM Consultation The EIUG has submitted its response to the consultation on the Introduction of a UK carbon border adjustment mechanism from January 2027. It fully agrees with the premise of the consultation that the objective of decarbonisation – to reduce global emissions – could be undermined by carbon leakage and that a well-designed CBAM could level the playing field in terms of carbon pricing for those energy intensive industries that manufacture these goods. However, some important issue relating to linking, sectoral scope, timing and export remain. | |
| 03.06.2024 | EIUG Response to Ofgem’s RIIO-3 Consultation The EIUG submitted in response to the Ofgem consultation on RIIO-3 Sector Specific Methodology for the Gas Distribution, Gas Transmission and Electricity Transmission Sectors. The response focuses on the points of most interest to energy intensive industries; electricity network investments and triads, FES scenarios, bespokes and industrial clusters, truth telling, future of the gas networks and hydrogen. | |
| 09.02.2024 | EIUG Response to the Consultation on Ofgem’s Forward Work Programme – 2024/25 The EIUG has submitted its response to Ofgem's consultation on its forward work programme 2024/25 and generally agrees with it, but suggests some further actions in relation to its new duties, risk of carbon leakage and network connection reforms | |
| 26.01.2024 | EIUG Spring Budget Submission The EIUG has submitted its Spring Budget submission to Treasury | |
| 15.08.2023 | Consultation Response on Extending the Growth Duty to the Economic Regulators The EIUG agrees that the economic regulators should be included in the scope of the growth duty. However, it also believes that the growth duty should not only apply to those businesses that are part of the business community, as defined in the statutory guidance under section 110(6) of the Deregulation Act 2015, but also to businesses as consumers, whose interest the regulators aim to protect. | |
| 02.08.2023 | EIUG Response to the Consultation on the Future of the Industrial Energy Transformation Fund The EIUG advocates continuation of the IETF to finance energy efficiency and decarbonisation of large energy users, particularly in light of its target to increase energy efficiency. Wider benefits that the IETF delivers are safeguarding the competitiveness of and decreasing the risk of carbon leakage for energy intensive industries. | |
| 31.07.2023 | Response to the Consultation on the draft Strategy and Policy Statement for energy policy in GB The EIUG believes that the draft strategy and policy statement (SPS) does not identify all the most strategic policy objectives and outcomes for Government, as mitigating the risk of carbon leakage is not included. To avoid (further) misalignment between Government and Ofgem, the SPS should include mitigating this risk and for Ofgem to have regard to it. | |
| 21.06.2023 | Response to the Capacity Market Consultation The EIUG strongly supports the proposal to exempt certain EIIs from the cost of the capacity market and would also like to highlight that its costs are likely to increase in the next years. An exemption from the cost of the capacity market will reduce the industrial electricity price differential between the UK and other countries. | |
| 09.03.2023 | Spring Budget Submission 2023 In its Energy Security Strategy, the government recognised that UK industrial electricity prices are higher than those of other countries and that will act to address this. In is Spring Budget Submission 2023, the EIUG therefore calls on Government to introduce other measures, besides compensation for the indirect emission cost due the carbon pricing announced in the Strategy, to support EIIs. | |
| 09.12.2022 | Review of the Energy Bill Relief Scheme This position paper sets out the EIUG’s position on the terms of reference of the review of the energy bill relief scheme (EBRS), the increase in gas and electricity prices since Spring this year and the forward energy price curves up to winter 2023, the measures other countries have taken in response to these increased energy prices, in particular for their energy intensive industries (EIIs), and the wider carbon leakage and supply chain risks if manufacturing in the UK were to become commercially unviable for EIIs if Government withdraws its current support. The EIUG calls on the UK Government to classify EIIs as vulnerable and support them beyond March 2023 with energy costs, but without relying on indefinite state support. It calls on Government to trigger article 44 of the Subsidy Control Act regarding national economic emergency and provide targeted and temporary emergency support to EIIs most exposed to the increase in energy prices. | |
| 31.10.2022 | EIUG and MCCG Response to The Net Zero Review The Energy Intensive Users Group and the Manufacturers Climate Change Group have submitted a joint response to Chris Skidmore MP's Net Zero Review. The Group call on the Government to provide financial support for and adopt supportive policies to deliver Net Zero manufacturing, minimise the risk of carbon leakage due to high industrial energy prices and ensure security of energy supply to give businesses the confidence to invest in decarbonisation. | |
| 01.10.2022 | EIUG Response to Review of Electricity Market Arrangements The EIUG agrees with the objectives of REMA but reiterates that it needs to have consumers at its heart. The group also urges Government to prioritise moving away from an electricity wholesale market where fossil fuels set the marginal price, expresses scepticism about locational pricing, especially nodal pricing, and argues that levies to support low carbon technologies should move to direct Government funding on a structural basis. | |
| 21.06.2022 | EIUG and MCCG Joint Response to the Consultation on Developing the UK Emissions Trading Scheme (UK ETS) In their joint consultation response, the EIUG and MCCG call on BEIS to postpone introducing a Net Zero consistent cap until Government has developed its policies to support industrial decarbonisation further and put in place policies to mitigate the risk of carbon leakage due to direct and indirect emission costs | |
| 24.11.2021 | Energy Prices and Energy Intensive Industries A briefing prepared for the Westminster Hall debate on 24th November 2021 |