CEE Bankwatch Network

CEE Bankwatch Network supports amending the RED II to further align it with the European Green Deal, and raising the ambition of the RED II targets. However, such an increase in ambition must be accompanied by a tightening of the Directive’s sustainability provisions – for all technologies, not only biomass – if it is to truly contribute to the Green Deal.

Bankwatch supports a combination of non-regulatory measures, amending the RED II to accommodate for the new measures foreseen in the European Green Deal (EGD), and raising the ambition of the RED II targets and subtargets (option 5). However, such an increase in ambition should not be done without tightening the Directive’s sustainability provisions.

The introduction, which describes the political context of the initiative, quotes an excerpt from Enrico Lettas report. It states that if left unaddressed, regional and territorial differences could lead to a new geography of discontent where people feel left behind.

In addition to comments submitted by CEE Bankwatch Network on the climate delegated act, the following suggestions are made for improving the technical screening criteria in the environmental delegated act with respect to the circular economy goals: 1.

CEE Bankwatch Networks main priorities to increase the effectiveness of the EU ETS are: 1) Inclusion of waste incinerators in the EU ETS from 2028, in order to promote economically efficient greenhouse gas (GHG) emissions reduction and increase the circular management of materials in the waste sector.

CEE Bankwatch Network welcomes the proposal for the EU's planned CBAM. Our responses to this consultation concentrate specifically on the power sector, based on our experience in southeast Europe, where a CBAM is much-needed.

Bankwatch strongly supports a carbon border tax for the electricity sector. The EU is not predicted to be a net importer of electricity in the coming years, but it does import electricity from, and exchange electricity with, countries on its borders such as Bosnia and Herzegovina, Serbia, Ukraine, Belarus and Russia, whose electricity sectors are heavily dependent on coal.

EED consultation – November 2021 Bankwatch supports the revision of the Energy Efficiency Directive (EED) to further align it with the European Green Deal and raising the ambition of the EED target. As the EU is setting higher decarbonisation goals, reducing the energy consumption will be crucial to ensure greenhouse gas emission reductions.

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

Bankwatch supports the revision of the Energy Efficiency Directive (EED) and welcomes the opportunity to react to its roadmap. As regards to the options put forward by the European Commission, Bankwatch also supports a stronger implementation of “energy efficiency first” principle, especially in the planning of the EU funds and their spending.

We agree that it is needed to include downstream steel and aluminium products in CBAM, but also to include other measures to track the ultimate origin of aluminium and steel, as there is scope for producers on the EU's borders using renewable electricity such as Aluminij Mostar to resell or reshape high carbon-intensity products from elsewhere, undermining CBAM and wasting energy.

April 2026 CEE Bankwatch Network input for the EU Call for Evidence on renewable energy - legal framework after 2030 CEE Bankwatch Network welcomes the Call for Evidence on the post-2030 legal framework for renewable energy and agrees that the EU’s resilience would be greatly strengthened by securing reliable, homegrown, affordable, and decarbonised energy for European people, industry and businesses and ensuring…

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

May 2026 Comments on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on speeding-up environmental assessments Introduction The ‘Environmental Simplification Package’ – as well as the proposed Directive on accelerating permitting under the Grids Package, which reopens the permitting provisions of RED III yet again – should not go forward as they are not based on a real and demonstrated…

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

We have read with interest the Commissions Roadmap towards Nature Credits and welcome the opportunity to provide our input. Nevertheless, our analysis of the concept (see attached briefing) does not show a useful role for nature credits, and pursuing them is likely to distract from higher-priority and more proven solutions for biodiversity financing.

CEE Bankwatch Network welcomes the opportunity to comment on the EU Grids Package legislative initiative. The feedback is available in the attached document. Comments are provided on permitting acceleration, grids funding and TEN-E revision. On permitting, we stress the need for consistent application of existing environmental legislation and upholding established standards.

For our full input, see attachment. Our recommendations are as follows: The Commission needs to step up environmental enforcement for all activities, not only EU-funded ones. The proposed guidance needs to clearly spell out the role of the do no significant harm assessment, clearly distinguishing its purpose and methodology from existing permitting procedures, as done under the RRF guidance but with more details on…

CEE Bankwatch Network firmly believes that a strong and ambitious EU energy efficiency framework remains essential to address the multiple crises facing Europe, especially in Central and Eastern Europe. Energy efficiency is not optional: it is the fastest and most cost-effective way to tackle acute energy poverty, lower household energy bills, reduce dependence on fossil fuel imports, accelerate a just transition…

CEE Bankwatch Network welcomes the improvement in spatial planning and the clarity that acceleration areas have the potential to bring for investors as the EU strives to ramp up its renewable energy share. But we remain highly concerned about the rollback of environmental safeguards and public participation provisions in the latest updates to the Renewable Energy Directive.

CEE Bankwatch Network is the largest network of grassroots, environmental and human rights groups in central and eastern Europe, working on monitoring public finance institutions that are responsible for hundreds of billions of investments across the globe.

The Aarhus Convention recognizes, among other things, the importance of fully integrating environmental considerations in governmental decision-making - a goal which has recently received renewed emphasis in the EU, via the EU Green Deal.

CEE Bankwatch Network contribution to Social Climate Fund consultation We welcome the positive steps in the EED and the Social Climate Fund to address energy poverty, particularly the article to protect vulnerable consumers, to renovate public social housing and dedicated energy savings programmes for energy poor households.

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