Material Techno-Economics
Position · EU Investment Booster consultation · 20 October 2026

The Competitive Decarbonisation Ladder

Europe will not have enough cheap clean electricity or sustainable carbon for every route. The Investment Booster should fund each green MWh and each tonne of renewable carbon where it creates the most value, and only where it passes the competitiveness test.

5–15×more CO₂ abated, and imported gas displaced, per euro on the first rungs than on electrolytic hydrogen
€88/MWhgas today (TTF, 19 October): at that price industrial heat pumps barely need a premium; their barriers are capital, grid and risk
15 → 30of 39 rungs competitive in Europe today, and at €40/MWh power
What the Booster gets right

A real step forward

We welcome the Investment Booster: €30bn of ETS resources mobilised fast, a simple fixed premium paid only on verified tonnes through a mechanism already proven for aviation, a solidarity ring-fence for lower-income Member States, infrastructure costs covered, a preference for clusters, and no hydrogen for medium-temperature heat. Our principles aim to help it deliver on its own goals: competitiveness and resilience.

The proposed design at a glance

Pay for what creates most value, not what arrives first

1. Rank before the queue. Rank each use case once, in the Terms and Conditions, on four currencies: cost, carbon abated, value created and water used. Set envelopes by rung, keep first-come-first-served within each, review the ranking every year and let routes graduate from the Innovation Fund.

2. PillarHow support is paidKey condition
Electrification & clean heat (incl. hydrogen)Premium indexed to the power-to-gas price ratio; CAPEX support where the gap is smallClean power for low-abatement routes
Circular renewable carbon (waste, bio, CO₂)Premium per tonne of fossil carbon displaced, product-level MRVSustainable feedstock and demand
CCS for unavoidable emissionsPremium per tonne, also indexed to the power priceCO₂ transport and storage, in clusters
3. TierUse cases
Fund firstIndustrial heat pumps and site heat in chemical plants; circular materials; scrap-based steel; cement and lime CCS in CO₂ clusters
With conditionsE-glass and high-temperature heat; e-cracking and electric boilers (clean power); H₂-DRI steel (clean power below ~€80–100/MWh); cracker CCS; chemical recycling and gasification; bio-based chemicals
Last rungElectrolytic hydrogen on grid power, e-methanol, e-SAF and maritime e-fuels: import the molecules, keep conversion in the EU

4. Close the demand side with lead markets: renewable and low-carbon content in public procurement, a renewable-carbon quota for chemicals, product labels. 5. Allocate risks fairly: stop the clock for grid and CO₂-network delays, penalise project failure rather than power-price exposure, pooled guarantees for SMEs, an optional cash route for allowances.

Key principles

Seven principles

  1. Speed is not competitivenessFirst come, first served rewards whoever queues first. Without a competitiveness test before the queue, the Booster can fund projects that close when the premium ends and never scale. Its goal is competitiveness and resilience.
  2. Price the electronFor electrification and hydrogen the gap is OPEX, not only CAPEX. A premium fixed in euros cannot close a gap that moves with the power bill.
  3. Highest value per green MWh firstThe same MWh abates three to four times more CO₂ in a heat pump than in hydrogen, and up to six times more than in e-fuels.
  4. Carbon where it is irreplaceableElectrons where they can do the job; renewable carbon where it stays in the product.
  5. Fund the first rungs, import the lastHeat pumps, circular materials, scrap and CCS for cement first. Hydrogen derivatives and e-fuels on the last rung, or imported as molecules.
  6. One ladder across ETS1 and ETS2Industry, buildings and road transport compete for the same green electrons and renewable carbon.
  7. A model, not a queueSet premia with a transparent multi-region techno-economic model, reviewed every year as routes climb the ladder.
Suggestions to DG CLIMA

What should change in the design

The ranked ladder · ETS1 and ETS2

Sixteen use cases, ranked by value per green MWh

Rungs at the top should be tackled first. Ratio = electricity price ÷ (gas price + carbon cost).

Fund first: competitive now, highest valueFund with conditions: power-price indexation, CO₂ network, offtakeLast rung: import, off-grid or Innovation Fund
#Use caseSystemElectrification & clean heatRenewable carbon & circularCCStCO₂ per green MWhCompetitive pointResilience gain
1Industrial process heat up to 400°CETS1Heat pumps; e-boilers + storage——0.6–0.7Ratio <2.5–3Gas imports, energy demand
2Heating in buildingsETS2Heat pumps; district heatingBiomethane: better used elsewhere—0.6–0.7Ratio <2.5–3, helped by ETS2Gas and heating-oil imports
3Process heat in small industryETS2Heat pumps; e-boilers + storage——0.6–0.7As row 1, with ETS2Gas imports
4Road freightETS2E-trucks and charging hubsBiofuels: last rung—~0.6Cost parity on high-mileage routesOil imports
5Passenger cars and vansETS2Battery-electric vehiclesBiofuels: last rung—0.7–0.8Cost parity in many segmentsOil imports
6Glass and ceramicsETS1Electric and hybrid meltingCullet, substitute materialsProcess emissions~0.35Cullet now; melting: ratio <1.7Gas imports
7Cement and limeETS1E-LEILAC (Innovation Fund)Substitute clinker and materialsOxyfuel or post-combustion CCS, in CO₂ clusters, low-power capturen/aSubstitutes and CCS in CO₂ clustersSubstitutes and CCS
8Olefins and aromaticsETS1
Site heat: heat pumps, e-boilers
E-cracking: with conditions
Recycled and bio feedstocksCCS on unavoidable emissions: with conditions0.6–0.7 site heat; ~0.2 e-crackingRecycled-content demand; CCS and e-cracking need cheaper powerNaphtha and gas imports
9Waste incinerationETS1——CCS; biogenic share as removalsn/aCO₂ network + removal valueNone on energy
10Industrial process heat above 400°CETS1Resistive, plasma, storage; nuclear, geothermal——0.2–0.3Ratio <1.5Gas imports, high power use
11Primary steelETS1H₂-DRI + EAF with clean power <€80–100/MWh; else imported green HBIScrap-based EAFNG-DRI + CCS (bridge)0.4–0.5, highest of the H₂ routesScrap now; H₂-DRI: clean power <€80–100/MWh (Nordics today)Scrap: high
12MethanolETS1e-methanol: import or Innovation FundBio-methanol; biogenic CO₂—~0.1Bio: feedstock costBio: medium
13Aviation and maritime fuelsETS1e-fuels: import or sub-mandateAdvanced biofuels—0.1–0.15ReFuelEU and FuelEU mandatesOil imports
14HydrogenETS1Electrolysis for feedstock H₂—Blue H₂ (SMR/ATR + CCS)0.15–0.2Power <€20–30, or importLow in Europe
15AmmoniaETS1RFNBO: import or off-grid—ATR + CCS~0.2Power <€20–30; keep EU conversionLow in Europe
16Aluminium and non-ferrousETS1Already electrified—Anode emissions (Innovation Fund)—Power price itselfDepends on power price

Why the Ladder and the Booster ranking can differ. The Ladder asks where scarce green electrons create most value; the Booster pays per tonne abated. Cement CCS stays green because process emissions have no electric alternative and capture can run on kiln waste heat. Cracker CCS is conditional because the same electron abates more in site heat. Today the Decarbonisation Bank has no prioritisation model: the Ladder offers one.

Competitiveness and resilience

What €1bn of Booster support buys

Two price cases: today (gas ~€80–88/MWh, carbon ~€88/t, industrial power ~€203/MWh) and gas normalised at €35/MWh.

RouteGap today €/tGap, gas €35 €/tCO₂ per €1bn, gas €35, MtGas displaced per €1bn, bcm
Industrial heat pumps (COP 2–3)<20, often none~80–240~4–13~2–6
Circular materials and substituteslow, often nonelowhighenergy and feedstock
CCS on cement and lime process emissions~10–70~10–70~15–100none, adds energy
High-temperature electrification~240~460~2~1
E-cracking~520~740~1.3~0.6
Electrolytic hydrogen replacing grey~860~1,080~0.9~0.4

Illustrative, order of magnitude. Gap = levelised cost of the low-carbon route minus the fossil reference including carbon, per tonne abated; ten-year contracts; capital at 8% over 15 years; CCS at €100–160 per tonne captured and stored. Each rung has a finite potential: the ladder fills the first rungs before climbing. CCS is cheap per tonne but displaces no imported energy: essential for process emissions, not a resilience lever.

Status of the ladder · today's prices

How many of the 39 rungs are competitive

Rungs that accelerate at today's prices, out of 39 processes across electrification, renewable carbon and industrial biotech, from the Ladder Lab.

Nordics28
Iberia19
France17
Germany12
Italy5
USA26
China20
At €40/MWh power30
At €25/MWh power33

Europe today: 15 of 39 rungs accelerate at an average €203/MWh power and €85/t carbon. At €40/MWh, 30 do. The binding variable of European decarbonisation is the price of the electron.

Competitive Decarbonisation Ladder, 19 October 2026: verdicts for 39 rungs by region, with olefins split into low-temperature site heat (green) and high-temperature e-cracking
The full ladder on 19 October 2026, with the Europe thresholds on the left. Olefins are split by temperature: low-temperature site heat is green across Europe; high-temperature e-cracking is conditional, waiting for clean power at €25–40/MWh. Click to enlarge.

On today's trend EU emissions fall 77% by 2050 versus 1990; with all ladders maximised, 82%. Open the Ladder Lab →

Material Techno-Economics' full response is submitted to DG CLIMA through the post-event survey. Figures are indicative engineering estimates, to be calibrated with our multi-region techno-economic model. Contact: rcv@materialtechnoeconomics.com