The Dirty Thirty - 30 most heavily polluting industrial installations in Germany

Posted on 12 September 2023

A WWF analysis conducted by the Öko-Institut has found that the 30 most CO2-polluting industrial installations in Germany are responsible for a total of 58 million tonnes of CO2 in 2022. This equals around 8% of Germany's greenhouse gas emissions and around one third of the total industrial sector emissions defined in the German Climate Change Act (Klimaschutzgesetz, KSG) for 2022. The findings are based on publicly available data from the European Emission Trading System (EU ETS).
The first 13 ranks in the Dirty 30 are accounted for by iron and steel production. This makes iron and steel production the largest sub-sector, by far, with 51 million tonnes of CO2 emissions. In second place are emissions from cement and lime production, which caused 27 million tonnes in 2022. In third place we find the chemical industry, which emitted 14 million tonnes of CO2 in 2022.
The energy sector has, quite rightly, been at the heart of German climate policy for many years now and it is still the largest source of greenhouse gas emissions. However, with the phasing out of coal and the development of renewable energy, the energy sector was the only sector to be able to significantly reduce its emissions: by approximately 36% between 2013 and 2021.

On the contrary, industry, the sector with the second highest emissions in Germany, remained at a largely constant level of emissions for much longer than was deemed reasonable from a climate protection perspective.

WWF Germany’s policy recommendations:
  • Free permits to pollute allocated to industry should end before 2034. An earlier phase out would have already led to a faster decarbonisation. 
  • Meanwhile, the allocation of those free permits to pollute must be linked to conditions such as the mandatory implementation of energy efficiency measures and transformation plans.
  • A comprehensive industry strategy is needed that strategically consolidates the individual measures in the sector.
  • Carbon Contracts for Difference (CCfDs) must not be used for subsidising fossil-based hydrogen, to avoid lock-in-effects, and to ensure a transition to renewable hydrogen is not delayed.
  • Carbon Capture and Storage (CCS) may only be applied for hard to abate process emissions in the certain industry sector, and not for energy related emissions that can already be reduced by changing to more environmentally friendly processes. 
  • More attention must be given to circular economy measures  in the industry sector. For instance, we need  binding resource targets and a tax policy that encourages investment in circular business models. 
  • The implementation of sustainable public procurement could have a profound impact on climate protection, the circular economy and the creation of green lead markets. 

A more extensive overview of WWF’s recommendations can be found here.
The 30 most heavily polluting industrial installations in Germany account for 8% of Germany's greenhouse gasses
© WWF Germany