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Assessment of Cumulative Cost Impact for the Steel and the Aluminium Industry

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Assessment of Cumulative Cost Impact for the Steel and the Aluminium Industry ASSESSMENT OF CUMULATIVE COST IMPACT FOR THE STEEL AND THE ALUMINIUM INDUSTRY FINAL REPORT ALUMINIUM CONTRACTOR Centre for European Policy Studies Prof. Dr. Andrea Renda (Project Coordinator) Prof. Dr. Jacques Pelkmans Federica Mustilli Prof. Christian Egenhofer Lorenzo Colantoni Andrei Marcu Federico Infelise Dr. Lorna Schrefler Wijnand Stoefs Dr. Giacomo Luchetta Jonas Teusch Dr. Felice Simonelli Jacopo Timini Dr. Fabio Genoese Julian Wieczorkiewicz Dr. Diego Valiante PARTNER Economisti Associati Roberto Zavatta Enrico Giannotti Giulia Maria Stecchi Done in Brussels, 31 October 2013 SPECIFIC CONTRACT NO. SI2.648823 30-CE-0558235/00-06 IMPLEMENTING THE FRAMEWORK CONTRACT NO ENTR/2008/006 LOT 4 DISCLAIMER The information and views set out in this Study are those of the authors and do not necessarily reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this Study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained therein. Page 2 of 239 ASSESSMENT OF CUMULATIVE COST IMPACT FOR THE ALUMINIUM INDUSTRY KEY FINDINGS This Study contains an assessment of the cumulative costs of EU legislation on the European aluminium industry, as well as an evaluation of how these costs affect the competitiveness of this industry from an international standpoint. Cumulative costs are compared to production costs and current margins of the European primary aluminium industry, as well as to the production costs of international primary aluminium producers. The analysis draws on a sample of 11 primary aluminium plants, representing 60% of the total EU27 primary aluminium production in 2012. The cumulative cost assessment for primary aluminium production is based on three different scenarios that take into account the uncertainty surrounding some of the elements used in the calculations. Specifically, i) the intermediate scenario, assumes that the pass-on rate in electricity prices of the EU Emissions Trading System (ETS) is 0.8 and uses the average of the lower and upper bounds for the attribution of environmental costs to EU legislation; ii) the lower bound scenario, assumes a 0.6 pass-on rate for ETS and 50% of environmental costs due to EU rules; and iii) an upper bound scenario, built on a pass-on rate of 1 for ETS and 80% of environmental costs due to EU rules. For the entire sample, cumulative regulatory costs range from 114 €/tonne to 149 €/tonne, with an intermediate estimate of 132 €/tonne. In the intermediate scenario, ETS indirect costs represent about 45% of total costs, followed by costs due to EU energy policies (about 41%) and environmental costs (about 13%). To improve the accuracy of the analysis, two subsamples of plants were identified. The first (hereinafter subsample 1) includes plants that are procuring electricity via old long term contracts or through self-generation. The second (subsample 2) includes plants that procure electricity on the market. The difference between subsamples is substantial. Regulatory costs for plants in subsample 1 amount to some 20 €/tonne in the lower bound scenario and 27 €/tonne in the upper bound, with an intermediate estimate of 24 €/tonne. Environmental regulation is responsible for the largest share (72%) of total costs in the intermediate scenario for plants included in subsample 1. As old long-term contracts and self-generation shielded these plants from ETS indirect costs, expenses to comply with energy policy regulation are the second cost item in order of magnitude (23%). In subsample 2, cumulative regulatory costs range from 179 €/tonne to 228 €/tonne, with a value for the intermediate scenario equivalent to 203 €/tonne. For plants procuring electricity in the market, costs linked to energy policies account for about 47% of total costs, ETS for 45%, and environmental outlays for about 8%. Page 3 of 239 These results highlight the role of electricity as a crucial input for the competitiveness of the EU primary aluminium industry. Old long-term contracts and self-generation by carbon free power sources shielded plants included in subsample 1 from ETS indirect costs and transmission costs. Moreover, purchasing electricity at low price considerably reduced their costs and improved their margins. Nonetheless, as soon as long-term contracts will expire, figures are likely to get closer to those of subsample 2. After a moderate reduction in 2003, production costs grew steadily between 2003 and 2008. The decline experienced in 2009 was followed by a new upward trend. While in 2006 margins reached an all-time high, 2009 and 2012 were low points. The costs generated by EU rules represented on average 8% - and never more than 10% - of total production costs over the entire period (2002-2012). Regulatory costs were in the area of 16% in 2006 (an exceptionally good year) to 39% of Earnings Before Interest, Taxes, Depreciation, and Amortization (EBITDA) and even higher than this margin in times of crisis (2009 and 2012). The impact on price-cost margin was more significant, not only when considering the losses registered in 2009 and 2012, but also in profitable years. Cumulative costs represented about 23% of profits in 2006 (the most profitable year) and 242% in 2011 (the year with the lowest positive profit value) and were constantly higher than this margin from 2008 onward. EU primary aluminium plants incur very large business costs of production, followed by those installed in the US, China, and Australasia. While selected EU plants included in subsample 2 are estimated to be the highest cost producers globally, smelters in subsample 1 have a significant competitive advantage. Only Middle Eastern and Asian plants are currently more cost-efficient than subsample 1. The analysis of cost differentials with the least cost producers (primary aluminium smelters in the Middle-East) shows that EU regulatory costs represented about one third of this competitive gap in 2012 (and one fifth for smelters included in subsample 1). EU regulatory costs are only one of the drivers behind the challenges currently faced by primary aluminium producers. Other factors, including the implementation of rules at the national level, have a direct impact on industry competitiveness of the industry. EU regulatory costs reduced the profitability of the EU primary aluminium industry not only in time of crisis, when the impact of any cost item is amplified, but also in the boom years, when they still represent a rather high share of industry margins. However, as this Study focuses only on the cost side of EU rules, the benefits of operating in the EU, such as proximity to high-added value customers should be borne in mind when reading our findings. Page 4 of 239 ASSESSMENT OF CUMULATIVE COST IMPACT FOR THE ALUMINIUM INDUSTRY EXECUTIVE SUMMARY A. Aims and scope of the Study This Study contains an assessment of the cumulative costs of EU legislation on the European aluminium industry, as well as an evaluation of how these costs affect the competitiveness of this industry from an international standpoint. Cumulative costs are compared to production costs and current margins of the European aluminium industry, as well as to the production costs of international aluminium competitors located in i) Africa; ii) Asia; iii) Australasia; iv) Canada; v) China; vi) the Commonwealth of Independent States (CIS); vii) European Union; viii) Iceland; ix) Latin America; x) Middle East; xi) Norway; and xii) the United States. This Study, however, is not an assessment of both the costs and the benefits generated by the relevant EU legislation. As a result, it contains no evaluation of the efficiency, consistency and proportionality of the rules analyzed. Our research question – as resulting from the terms of reference given to us by the European Commission, DG ENTR – is limited to an assessment the cost generated for the aluminium industry by the relevant legislation. As such, our Study differs noticeably from a full-fledged “fitness check”, which aims at evaluating the efficiency, effectiveness, burdensomeness and coherence of a corpus of EU legislation in a given policy domain (not a single economic sector). In particular, an assessment of the appropriateness, effectiveness and efficiency of the relevant legislation falls outside of the scope of this Study. The following types of regulatory costs are considered to be relevant for the scope of the Study: 1. Administrative costs: costs incurred by firms due to the legal obligation to provide information to public authorities and third parties, as measured with the EU Standard Cost Model; 2. Compliance costs: costs incurred by a firm as a direct consequence of the need to comply with a legal act; 3. Indirect costs: costs of regulation which have an impact on aluminium producers not as direct addressees, but as counterparts of direct addressees. This Study estimates, in particular, the cumulative costs generated by the following areas of legislation on the European aluminium industry: i) general policies; ii) the commodity Page 5 of 239 markets regulation; iii) legislation related to climate change; iv) competition policy; v) energy policy; vi) environmental legislation; vii) trade policy; viii) product regulation and life-cycle assessment (LCA). In terms of industry coverage, the Study focuses on firms falling within class 24.42 of the NACEv2 classification. More specifically, we have focused our analysis on primary aluminium production; secondary aluminium production (both remelting and refining); and a selection of downstream activities (rolling and extrusion). The following entities are excluded: upstream, alumina production; and downstream, the companies that transform intermediate and semi-finished aluminium products into finished manufactures. Focusing on this class allows the Study to treat similar entities, thereby increasing the degree of accuracy of the findings. The analysis is based on a sample of 11 primary aluminium plants out of the 16 plants that were still active in the EU27 at the end of 2012.
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