ZVO Presents Position Papers on the BEHG and the Circular Economy

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The ZVO has published two new position papers on national CO₂ pricing and the circular economy. In these papers, the association calls for competitive energy prices, the elimination of special national taxes, and greater political recognition of electroplating and surface engineering as a key technology.

The Central Association for Surface Technology (ZVO) has presented two position papers on current industrial policy issues. The focus is on the Fuel Emissions Trading Act (BEHG) and the role of electroplating and surface technology in the circular economy. In doing so, the association combines energy and climate policy demands with an emphasis on the importance of durable, repairable, and reusable products.

CO₂ Pricing and Competitiveness

With regard to national CO₂ pricing, the ZVO criticizes the ongoing additional burden on energy-intensive small and medium-sized enterprises. High energy costs are already limiting investment flexibility; CO₂ pricing further increases the cost of using fossil fuels and, consequently, the supply of process heat in the electroplating and surface treatment industry. Many companies have only limited ability to pass these costs on in the face of international competition. As a result, funds are lacking for modernization, energy efficiency, and climate-friendly technologies.

The association is therefore calling for a fundamental reassessment of the BEHG. The background to this is the postponement of the European Emissions Trading System for Buildings and Transportation, the EU-ETS II. From the ZVO’s perspective, the extended transition phase must not lead to “a permanent entrenchment of a special national burden.” Stabilizing the CO₂ price corridor alone is not sufficient to ensure competitive energy prices.

The ZVO advocates for a European-coordinated, market-based climate policy. Should the European system be further delayed or undergo fundamental changes, preparations must be made to phase out the national fuel emissions trading system. As long as the BEHG remains in effect, the association demands a complete, transparent, and unbureaucratic return of revenues to industry, small and medium-sized businesses, and citizens.

Circular Economy and Durability

In its second position paper, the ZVO places greater emphasis on the lifespan of products within the circular economy. The association argues that a component that can be used for a longer period of time does not need to be replaced as soon, thereby saving raw materials, energy, and reducing emissions. However, the political debate has so far often centered on recycling rates and waste recovery.

In the ZVO’s view, electroplating and surface treatment technologies make a significant contribution to the circular economy. Coatings protect against corrosion and wear, extend the service life of high-quality components, and enable repair and remanufacturing. These benefits extend to numerous fields of application, ranging from mechanical engineering and power generation to medical technology and critical infrastructure. The association therefore calls for the industry to be explicitly recognized as a key technology for the circular economy.

At the same time, the ZVO advocates for mandatory life-cycle assessments, technology-neutral regulation, and less bureaucracy. Substance restrictions must also take into account a process’s contribution to a product’s service life and resource efficiency. If proven coatings are phased out without equivalent alternatives, the association sees conflicts of interest with resource conservation. From this perspective, the circular economy is not only environmental policy but also industrial and raw materials policy, intended to strengthen security of supply and value creation in Europe.

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