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.

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.

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.

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.

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)

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 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.

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 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 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.

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 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.

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 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).

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 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.

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.