Bellona Europa

Bellona Europa welcomes the European Commissions forthcoming proposal for a Circular Economy Act (CEA) under the Clean Industrial Deal. We strongly support its goal to remove barriers in the EU single market for waste and secondary raw materials and to enable sustainable, competitive business models for circularity.

Bellona welcomes the revision of the EU Public Procurement Directives as a unique opportunity to transform public procurement into a strategic tool for achieving EU climate, circular economy, and industrial objectives.

The Industrial Accelerator Act (IAA) is a welcome and necessary step. Decarbonising Europes most emissions-intensive industries steel, cement, aluminium, and chemicals requires a transformation in how public money is spent and how markets are shaped. The IAA has the potential to be the instrument that drives that transformation, by sending a clear, credible demand signal for genuinely low-carbon products.

Please find attached Bellona Europa's full response and recommendations to the Roadmap Consultation "EU renewable energy rules - review" as well as our recommendations for the REDII delegated acts for your reference. We are happy to contribute further to the process and offer our expertise on the topic should this be of interest to you continued work. Here is a short summary of Bellona Europa's recommendations: 1.

Bellona Europa welcomes the revision of the screening criteria under the EU Taxonomy and the opportunity to provide feedback. While we recognise the EU Taxonomy as key component of the EU sustainable finance framework, there are still two concerns about the changes proposed by the Commission, notwithstanding the effort in updating the criteria across all delegated acts.

We welcome the Commission's initiative to review the EU Taxonomy Climate and Environmental Delegated Acts, aiming to improve their clarity, usability, and cost-effectiveness. However, we must express significant concerns regarding the proposed process and the potential implications of simplification. 1.

Reduced demand and increased circularity should be the first priorities in covering the need for critical raw materials. Policies to reduce demand can include setting binding material footprint reduction targets, as described in the consultation response from the EEB. There is also a strong need to increase circularity for many CRMs.

Bellona welcomes the decision of the Commission to revise the EPBD in light of the new targets for 2030, aiming at doubling the building renovation rate by 2030. Buildings are responsible for over a third of the energy-related GHG emissions in the EU, thus the revision of the EPBD is necessary to reduce emissions by 55% by 2030.

Bellona Europa tentatively welcomes the European Commissions proposal for a European Competitiveness Fund (ECF), particularly as an instrument to support the European Unions clean transition. As an independent climate NGO, Bellona flags the following issues: - Insufficient climate action spending target: Current and planned investments are not sufficient to meet the goals set for 2030 and to keep the EU on track to…

Bellona Europa Response to the proposal for a regulation “European Climate Law – achieving climate neutrality by 2050” Bellona Europa welcomes the European Commission’s regulatory proposal for the “European Climate Law”, but warns that the current proposal fails to take into due consideration current estimates’ overreliance on the future availability of Negative Emissions Technology and Practices (NETPs) at a large…

Please see attachment for full feedback with supporting documentation and sources. The proposed “Climate Law” offers an unprecedented opportunity for Europe to become the global leader on tackling climate change. For this to become a reality, however, the “Climate Law” needs to be done right.

Bellona Europa is an independent, non-profit organisation that meets environmental and climate challenges head on. We are solutions-oriented and have a comprehensive and cross-sectoral approach to assess the economics, climate impacts and technical feasibility of necessary climate actions. To do this, we work with civil society, academia, governments, institutions, and industries.

Please find a report on the interaction between CDR and the EU ETS in attachment. Bellona recommends an interaction approach as a pragmatic and effective way to leverage the climate benefits of CDR without prematurely fully integrating removals into the ETS, while addressing current technical, accounting and policy challenges.

Bellona Europa [email removed] 42 Rue Breydel 1040, Brussels General Feedback Call for Evidence - Clean Corporate Vehicles Bellona Europa welcomes the upcoming adoption of the Clean Corporate Vehicles regulation. As noted in the call for evidence, approximately 60% of new car registrations come from the corporate sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the Sustainable Product Policy Initiative’s intention to assess the true environmental impact of products and correct existing market failures which do not take into account their externalities. The current EU policy framework needs to be amended to reflect the true cost of all products.

Bellona Europa hereby submit its consultation response, strongly supporting the European Commission efforts to establishing a CBAM. Our two main recommendations provided below, full details and supporting documentation in attachment. 1. Quicker Phase-out of Free Allocation of EU ETS Allowances is Necessary for Ensuring the Timely Success and Effect of the CBAM 2.

Response to the published Inception Impact Assessment for a Carbon Border Adjustment Mechanism Bellona Europa commends the European Commission’s ongoing efforts to ensure that climate neutrality is met by 2050 and efforts to price Greenhouse Gas (GHG) emissions.

SUMMARY: Bellona welcomes the opportunity to provide feedback on the revision of EU ETS benchmark values for free allocation in the 20262030 period. Bellona has consistently advocated for benchmark reforms that reward genuinely low-carbon production pathways based on actual carbon performance rather than production process.

Bellona Europa welcomes the ongoing efforts by the European Commission, and the invitation to provide views, feedback and recommendations on the proposal to revise the Construction Products Regulation (CPR). Buildings and the materials with which they have been constructed have a significant environmental and climate footprint.

Bellona Europa welcomes the proposed revision of the Energy Tax Directive primarily because of the weight of environmental factors in defining the level of taxation has increased. Moreover, the strive to foster the use of renewable electricity across the directive is a very positive development.

Bellona Europa welcomes the update of the renewable energy framework as it is a vital tool for accelerating the deployment of renewable energy sources (RES) in pursuit of the 90% greenhouse gas (GHG) reduction target for 2040 set in the European Climate Law.

While the reaffirmation of the 90% emission reduction target for 2040 is welcome and necessary, proposed amendments raise concerns about potential loopholes that risk undermining this ambition: the proposed use of international credits after 2036, sectoral flexibility and the possible integration of permanent removals into the EU ETS.

SUMMARY: Bellona has long supported the CBAM as a mechanism that both enables the phase-out of free allocation under the EU ETS while preventing carbon leakage and encourages decarbonisation and carbon pricing beyond the EU. Bellona supports the distinction made in the draft Regulation between the carbon price and the carbon price effectively paid.

Bellona Europa calls for the CBAM to recognise the carbon price paid in countries of origin only when it has been effectively paid, without any form of rebates or discounts nor offsets of any form. To achieve meaningful climate impact, any carbon pricing, whether ETS or carbon tax, must cover all emissions directly, disaggregated from any potential offsets or reductions elsewhere in the system.

Bellona Europa fully supports the comprehensive feedback to the Inception Impact Assessment on the Industrial Emissions Directive revision by the European Environmental Bureau and Carbon Market Watch. As the Inception Impact Assessment states, the revision of the Industrial Emissions Directive (IED) should improve its effectiveness and facilitate increased ambition in line with the policies of the Green Deal.

Bellona Response to the Batteries Roadmap Bellona welcomes the batteries roadmap as a way to improve the sustainability of batteries while still ensuring the competitiveness of the sector. Electrification is the best way to eliminate emissions from road transport; will play a role in the decarbonisation of ships and machinery; and is already contributing to addressing the challenge of energy storage; which means…

Bellona cautiously welcomes the Commissions initiative on nature credits as an important opportunity to mobilise private finance for biodiversity restoration. However, we stress that nature credits must never be used as a substitute for real nature restoration.

Bellona Europa has long supported the efforts to establish a Carbon Border Adjustment Mechanism (CBAM) as a way to strengthen the EUs carbon price signal while protecting European producers from the risk of carbon leakage caused by uneven climate ambition worldwide.

Bellona Europa welcomes the European Commissions proposal for a Net Zero Industry Act (NZIA) and its aim to support deployment of climate relevant technologies to reach Net-Zero in the EU by 2050. With the inclusion of faster permitting of the proposed net-zero technologies, the act aims to keep up with climate relevant timelines.

Bellona Europa [email removed] 42 Rue Breydel 1040, Brussels Standardisation Regulation - revision Bellona Europa welcomes the revision of the Standardisation Regulation as environmental stakeholders play a vital role in shaping standards that align with the EU’s environmental priorities and the Single Market.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bellona supports the European Commissions objective to develop a more ambitious, comprehensive, and coherent EU approach to climate resilience and preparedness. Climate risks from floods to wildfires, droughts, and sea level rise, are already impacting ecosystems, human health, and economic stability across Europe. They also pose a direct threat to the permanence of carbon stocks in forests, soils and wetlands.

The current proposal from the European Commission fails to free Europe from a fossil lock-in. This has become all the more clear with the release of the REPowerEU and a renewed dedication to reducing Europe’s dependency on fossil gas.

GRIDS PACKAGE: Ref.BRIEFING Ares(2025)6386529 - 05/08/2025 2 // 5 POLICY RECOMMENDATIONS FOR A GRID THAT DELIVERS DECARBONISATION & COMPETITIVENESS Europe is at a pivotal moment, striving to balance energy security, affordability, and decarbonisation. Central to achieving the goals of the Clean Industrial Deal and the Action Plan for Affordable Energy is the rapid modernisation and expansion of electricity grids.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bellona is an independent non-profit organisation founded in 1986, working to solve climate and environmental problems through technology-oriented, solution-driven analysis and advocacy. We welcome this consultation on updating the Aviation Strategy for Europe. Our contribution focuses on aviation fuels and the decarbonisation of the sector.

Bellona considers that the Refuel EU strategy fails to ensure that the aviation sector pull its weight when it comes to climate action. In fact, the proposed solutions for the sector to decarbonise are likely to increase emissions since there are no safeguards in place to prevent perverse outcomes.

Reducing greenhouse gas emissions in a growing sector such as aviation is becoming increasingly important. While some advanced biofuels (renewable and waste derived) and electro-fuels can reduce emissions in the aviation sector, their use can also lead to an adverse effect.

Bellona hereby replies to the open consultation and call for evidence on the EU Arctic Policy, the full feedback and supporting information is attached in the PDF, specifically addressing recommendations on how an EU strategy and policy on the Arctic should: - Seize the moment to strengthen EU leadership in the Arctic - Ensure that climate mitigation, adaptation and environmental protection remain a core of EU…

Bellona Europa supports the Commission's efforts to prepare an Electrification Action Plan and a Heating and Cooling Strategy, which will promote decarbonisation by encouraging the use of clean electricity. Clean electrification is one of the most effective and cost-efficient ways to reduce industry's carbon footprint while boosting its competitiveness and reducing its reliance on volatile fossil fuel markets.

Bellona Europa [email removed] 42 Rue Breydel 1040, Brussels Call for evidence - CO2 transport infrastructure and markets in the EU Bellona welcomes the opportunity to provide input on the initiative to establish a wellfunctioning, EU, market-driven value chain for CO2.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Bellona Europa supports the Commission's efforts to prepare an Electrification Action Plan and a Heating and Cooling Strategy, which will promote decarbonisation by encouraging the use of clean electricity. Clean electrification is one of the most effective and cost-efficient ways to reduce industry's carbon footprint while boosting its competitiveness and reducing its reliance on volatile fossil fuel markets.

Bellona Europa provided an earlier version of its feedback on the 22/02/2021. We ask that you disregard that version and rather see the updated one below. The TEN-E Regulation has since its creation in 2013 contributed greatly to its set objectives and aims.

The TEN-E Regulation has since its creation in 2013 contributed greatly to its set objectives and aims. A much-needed revision is now underway to ensure alignment of these aims with the European Green Deal, shifting the TEN-E's focus from security of supply to security of sustainable supply in line with the Union’s decarbonization targets.

Response to the Published Roadmap for Revision of the “Trans-European Energy Infrastructure” (TEN-E) Regulation Bellona Europa strongly supports the EU’s commitment to climate neutrality by 2050, and the need to revise regulation (EU) No 347/2013 “Guidelines for Trans-European Energy Infrastructure” (TEN-E).

You can find below Bellona Europa's recommendations. Use credits as a strategic reserve/ emergency exit, separate from domestic compliance pillars Establish centralised EU-level management (e.g., via the European Commission) Ensure that spending on credits is not counted towards international climate finance or development aid commitments Preserve the integrity of the ETS by excluding international credits from…

Bellona Europa welcomes the new initiative to establish the post-2030 framework of the Energy Efficiency Directive (EED), as it is an essential pillar of European energy policy. The aim of our position paper is to highlight the key principles that should inform the design of the new initiative and help to pave the way towards climate neutrality.

Bellona welcomes the Commissions initiative to provide guidance on designating renewable acceleration areas. The proposal holds significant promise in accelerating the deployment of renewable energy to meet the EU targets. The renewable acceleration areas outlined in Article 15c of RED hold significant promise as instrumental mechanisms for expediting the deployment of renewable energy sources within the EU.

Bellona strongly supports the phase-out of EU ETS free allowances in line with the introduction of CBAM. The timeline and rate of the phase-out must remain consistent, without changes or extensions. Free allowances were introduced as a temporary measure to mitigate carbon leakage risks and have persisted for nearly two decades, undermining the long-term signal for emissions reductions and delaying industrial…

Bellona welcomes the initiative of the Commission to revise the European electricity market design. The recent spike in prices, led by the current geopolitical circumstances, as well as the massive transformation required by the energy transition, make this reform timely and needed.

Bellona Europa welcomes the revision of the Governance Regulation as a vital chance to reaffirm the EUs commitment to its climate and energy goals. We welcome the Commissions evaluation report and the supporting analyses, which together provide a comprehensive overview of the Regulation's current implementation status and improvement needs.

The Connecting Europe Facility (CEF) plays a crucial role in supporting the development of interconnectors, a key infrastructure for achieving a well-integrated and resilient energy system across the European Union. Interconnectors, which link energy grids between EU Member States, are vital for enhancing the cross-border exchange of renewable electricity.

You can find below Bellona Europa's recommendations. On the design of the post-2030 climate package: Design the post-2030 package, including national targets, to achieve 90% net domestic emission reductions by 2040 Keep the separation between the reduction of fossil fuel and industrial process emissions (ETS & ESR) and the management of land sinks (LULUCF).

Bellona sincerely welcomes the taking into account of the points expressed in the previous contribution, including the recognition that current air quality standards were largely missing the WHO recommendations. However, it’s important to aim at a full alignment with WHO recommendation, rather than just a closer alignment.

The revision of the MSFD represents a historic opportunity for the EU to bridge the gap between ambitious climate rhetoric and the ecological threats facing our ocean. The failures of the past two decades have not been for a lack of scientific understanding, but rather a lack of environmental management that sufficiently understands the requirements of ecological protection and recovery.

Bellona Europa comes out in strong support of the aims underlying the proposed regulation 2020/0006 (COD) establishing the Just Transition Fund (JTF). For the transition towards a climate-neutral economy to be successful, it must be a just transition for all.

The current proposal from the European Commission fails to free Europe from a fossil lock-in. This has become all the more clear with the release of the REPowerEU and a renewed dedication to reducing Europe’s dependency on fossil gas.

Bellona welcomes the opportunity to submit feedback on the ecodesign requirements for iron and steel,under the Ecodesign for Sustainable Products Regulation. This delegated act matters far beyond the steel sector: iron and steel is the first intermediate product group to complete the ESPR process, so its methodology will set the precedent for following products, and will define "low-carbon steel" for the purposes of…

Bellona welcomes the Commission's decision to undertake an evaluation of the EU's energy security architecture and the opportunity to provide feedback. We believe it is important to emphasise that greater energy security goes hand in hand with the climate challenges that must be addressed to combat climate change.

Following the Fit for 55 package and the revision of the ETS Directive, several regulatory acts must be revised, Bellona Europa welcomes to opportunity to provide feedback to the Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council and amending Commission Regulation (EU) No…

Bellona Europa welcomes the European Commissions Draft Implementing Act introducing minimum environmental sustainability requirements for public procurement of clean technologies under the Net-Zero Industry Act (NZIA). This initiative is a key opportunity to align industrial decarbonisation with the EUs climate and competitiveness goals.

Bellona welcomes a review of the directive on the deployment of alternative fuel infrastructure. The directive, while well-intentioned, currently risks promoting the deployment of fuel infrastructure which is not compatible with the long-term goal of a net-zero transport sector and wider economy.

Bellona Europa welcomes the ongoing efforts by the European Commission and the opportunity to provide recommendations on the REPowerEU update to the Recovery and Resilience plans. We welcome the REPowerEU initiative of the EU to reduce its dependence on fossil gas, finally moving towards both climate goals and energy security.