E3G

Summary of E3G's recommendations for the Circular Economy Act - for the full feedback, please see the attached document: 1) Set overarching EU targets on resource use, accompanied by a comprehensive monitoring framework to create long-term predictability.

The long-term competitiveness of Europes energy-intensive industries depends on their ability to decarbonise. While many low-carbon projects have already been announced, investors are currently struggling to reach final investment decisions due to a lack of investment certainty and the right enabling conditions.

Accounting for 14% of EU GDP, public procurement holds significant potential to drive the EUs policy objectives, including its climate targets, but remains underutilised. E3G supports a review of the Public Procurement Directives to ensure public spending supports strategic objectives, such as decarbonisation, resilience and social responsibility.

E3G welcomes the new proposal to revise the Energy Performance of Buildings Directive, which broadly goes in the right direction. The text represents an opportunity to accelerate the clean and fair transition for buildings in Europe, and presents a number of useful tools to achieve the vision of a decarbonised, affordable and comfortable EU building stock.

E3G welcomes the European Commissions decision to broadly align the draft revised European Sustainability Reporting Standards (ESRS) Delegated Act (DA) with EFRAGs final advice on the simplified reporting standards. Nonetheless, certain elements within the draft ESRS DA risk undermining the data quality and comparability of sustainability disclosures.

The upcoming EU climate law will help closing some of the gaps of the current European governance framework. The law should enshrine the objective of reaching climate neutrality by 2050 at the latest EU-wide, and a trajectory to reach it. It should complement the Energy and Climate Governance regulation. The law should precise the legal status and governance context of the national long-term strategies.

E3G welcomes the Commission’s proposal for the Corporate Sustainability Due Diligence Directive (CSDDD) as an important step to incorporate sustainability considerations in corporate due diligence practices and directors’ accountability to stakeholders.

E3G welcomes the opportunity to respond to the European Commission's Call for Evidence for the review of the EU ETS Directive and the Market Stability Reserve (MSR) Decision. This consultation is crucial for aligning the EU ETS with the upcoming 2040 climate target and ensuring its effectiveness in driving decarbonisation beyond the power sector. Please find attached our full response.

E3G welcomes the update of the Energy Efficiency Directive (EED) to align it with the Climate Law and the need to limit global warming to 1.5˚C. While E3G is generally supportive of the direction of the proposal, the directive needs to be improved to meet European climate targets and ambition. The draft recast contains useful provisions that need to be safeguarded, and others that need strengthening.

E3G welcomes the European Commissions proposal for 2040 intermediate net reduction in greenhouse gas emissions -90% relative to 1990 levels. This interim milestone will put the EU on course towards climate neutrality by 2050 and gives predictability on the way forward.

THE EUROPEAN CLIMATE RESILIENCE AND RISK MANAGEMENT INITIATIVE E3G Submission to the Call to Evidence The EU stands at a pivotal moment. The European Commission can design a climate resilience and risk management initiative that is comprehensive, coherent, and ambitiousmatching the scale of the challenge. This submission highlights five key areas: 1. Definition of climate resilience 2.

The EU needs to deliver markets that are ‘fit for 55’ by 2030 and ensure that the needs of energy consumers are met in a world in which a variety of new energy solutions become available. These imply a reduction of 29-37% in fossil gas consumption by 2030. This dynamic will fundamentally transform the shape of the gas market.

The EU energy system must evolve rapidly to deliver a secure, decarbonised, and competitive economy. Electrification is central to this goal, and Europes electricity grids must be transformed to support the integration of renewables, meet rising demand, and enhance resilience.

The publication of the EUs Electrification Action Plan, together with the Heating and Cooling Strategy and the Citizens Energy Package, is a key political moment to ensure the energy transition delivers real tangible benefits for citizens and industry in Europe.

When the first Heating and Cooling (H&C) strategy was published in 2016, European buildings had an efficiency rate below 60% and renewable energy in the sector was under 10%. Progress is being made: the share of renewables in heating and cooling reached the highest share of 26.2% in 2023 and between 2005 and 2022, total ghg emissions in the EU building sector fell by 34%, driven in large part by progress in…

Context: The EU has committed to achieving climate neutrality by 2050 but is currently falling short in meeting its energy and climate targets already for 2030. Despite that, energy infrastructure is rightly recognized as a key enabler for the transition.

Since its adoption in 2018, the Governance Regulation of the Energy Union and Climate Action has given member states the tools to plan for a clean transition that delivers on shared targets. The five dimensions of the Energy Union strategy decarbonisation, energy efficiency, the internal energy market, energy security, and competitiveness and innovation have provided the framing for the work that has been…

The European Commissions upcoming revision of the energy security framework can serve as an opportunity to both embed lessons from previous energy crises, update tools to reflect evolving needs and go beyond traditional security approaches to deliver a safe and resilient clean energy system. A clean, European-powered energy system is fundamentally different, and more complex, than a fossil-based one.

E3G welcomes the possibility to respond to the open consultation launched by the European Commission on the postponement of sector-specific ESRS. We acknowledge the European Commissions commitment to establish a balanced regulatory framework for corporate sustainability reporting, targeted at achieving transparent, high-quality sustainability information while avoiding unnecessary burdens for companies.

ASSESSMENT CEF’s overall envelope for energy has been increased to €8.7 billion. The new text contains some significant improvements: • The inclusion of 10% of funding dedicated to cross-border renewable energy projects has the potential to address barriers to important projects such as offshore wind hubs in the North and Baltic seas and renewable energy cooperation in Southeast Europe.