NGO · France · EU Transparency Register 562109933357-60
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Among the 1518 trade and business associations on this site, they rank #141 by legislative files engaged, a count of participation, not a measure of influence.
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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EdEn (Equilibre des Energies) filed 25 positions between 7 Apr 2020 and 18 Jun 2026, across 21 of the 665 legislative files tracked here, attaching a full position paper 19 times.
Position Paper Industrial Accelerator Act Ref. Ares(2026)6198059 - 18/06/2026 29 May 2026 The Industrial Accelerator Act is an important initiative that reflects the EU’s shift in focus towards strategic autonomy and competitiveness, in particular in the sectors that play a key role in the energy transition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EdEn welcomes the strategy of the new European mandate focusing on competitiveness and industrial development in view for the EU to strengthen its autonomy and to decarbonise its industry. Achieving this objective will require structural transformations and significant investments.
With energy efficiency and nuclear energy, renewables are crucial for achieving the transition to a carbon-neutral economy in the EU. For this reason, their development should be an important goal of the Fit for 55 package, and EdEn welcomes the proposal published by the Commission in July to revise the RED.
EdEn welcomes the draft recast of the directive on the energy performance of buildings (EPBD) proposed by the Commission. The proposal introduces important evolutions in the EPBD, notably as regards GHG emissions in the EU building sector.
In the context of the Green Deal, the European Commission has announced that the EU would soon be raising its carbon emission reduction target for 2030 from 40% to at least 55% in view of achieving climate neutrality in 2050.
EdEn (Equilibre des Energies) recommends that the EU Climate Law should integrate the following provisions: - It should be specified that the trajectory mentioned in article 3 paragraph 1 is a trajectory for greenhouse gas emission reduction. It is necessary to specify that the trajectory that shall be set out is a GHG emission reduction trajectory.
EdEn welcomes the European Commissions public consultation in view of EU Emissions Trading System (ETS)s upcoming revision in 2026. In our response, EdEn presents recommendations as regards to how the EU-ETS could better support the decarbonisation of the aviation and maritime transport sectors in view to achieve the following objectives: 1) Earmarking revenues from the EU-ETS towards the production of sustainable…
Position Paper Clean Corporate Vehicles Ref. Ares(2025)7476257 - 09/09/2025 September 8th, 2025 EdEn welcomes the European Commission’s intention to propose a directive supporting the greening of corporate fleets.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Improving energy efficiency is a key part of achieving the EU's climate objectives for 2030 and 2050, which is why EdEn supports the European Commission's proposal to recast the Energy Efficiency Directive (EED).
EdEn strongly believes, as the Commission does, that the energy efficiency legislation can play a key part in addressing both of the challenges the EU is currently facing: • Climate change - Energy efficiency requirements can lead to significant reductions in fossil fuels consumption and thus contribute to GHG-emission reductions; • Economic crisis - Energy efficiency requirements also contribute to fostering…
Position Paper Setting a renewable Energy Framework for the decade ahead Ref. Ares(2026)3959127 - 16/04/2026 16th April 2026 General considerations EdEn welcomes the Commission’s initiative to open consultations on potential revisions to the Renewable Energy Directive.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Position Paper EU climate target for 2040 September 15th, 2025 EdEn welcomes the EU public consultation in view of establishing a 2040 climate target. As regards the proposed objective for 90% of GHG emission reduction by 2040, EdEn would like to point out the very high level of ambition that such an objective would represent.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EdEn welcomes the Commission’s proposal for a Regulation on batteries and waste batteries. We believe this proposal is an important step in reducing the environmental footprint of batteries throughout their whole life-cycle.
In order to modernise EU rules on batteries, we recommend the following measures be integrated in the legislation: A) Introducing a strong carbon criterion in the batteries legislative framework Batteries are an essential part of the development of low-carbon mobility in the EU but if the production and use of batteries result in a high level of CO2 emissions, their entire purpose is defeated.
EdEn welcomes the objective set by the Commission to reduce the GHG emissions associated with the use of HFCs. It is however essential that the revision of F Gas Regulation 517/2014 does not hinder the deployment of heat pumps, which is a key aspect of the Commission’s strategy to decarbonise the EU building sector.
The current text of the Regulation on CO2 emissions for cars and vans focuses on reducing tailpipe emissions as it is the source of most CO2 emissions related to internal combustion vehicles. Such a focus however has led to unintended consequences that can increase the GHG emissions related to the cars sector.
The European Unions electricity system is a key comparative advantage to progress towards decarbonisation, reindustrialisation, and economic and social development. Investing in European electricity grids is a strategic necessity to support electrification objectives. This development must be closely synchronised with the deployment and strengthening of electricity generation infrastructure.
Substituting fossil kerosene for Sustainable Aviation Fuels (SAF) can lead to significant GHG emission reductions in the relatively short term but the development of SAF is hampered by several obstacles: • Insufficient maturity in terms of industrial development, lack of investment in production and improvements needed in process efficiency and SAF competitiveness; • limited availability of resources; • Uncertainty…
Position Paper Electrification Action Plan October 9th, 2025 Electricity is now widely recognised as the fastest and most impactful lever for reaching climate neutrality. This can be attributed to three main factors: 1. Low-carbon supply at scale: Electricity can be generated in large volumes from lowcarbon sources (solar, wind, nuclear, hydro, sustainable biomass). 2.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EdEn believes CO2 capture and storage will be needed to offset residual emissions from hard-to-abate industrial sectors. Industrial carbon removals from biogenic and possibly from atmospheric sources will also be an essential component in the manufacture of chemicals, plastic products and synthetic fuels.
EdEn recommends the Regulation as regards strengthening the CO emission performance standards for new heavy-duty vehicles be aligned with the Regulation as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles and introduce the following provision in order to make it possible for manufacturers to develop vehicules running exclusively on CO2 neutral…
The European Commission is planning to merge the energy labels for local space heaters (products from Lot 20) and air-air heat pumps (products from Lot 10). Conversely, energy balance considers that these two lots must retain differentiated labels in order to guide industry and consumers towards the most relevant solutions depending on the architectural constraints of the dwellings.
Filed in French · English published by the European Commission
EdEn believes that this regulation should strongly incentivise consumers to choose heat pumps. To achieve this objective, the energy labelling framework for heat pumps should be clearly and visibly differentiated from that of fuel-fired boilers, which are intended to be phased out.
a) EdEn believes that this regulation should actively incentivise manufacturers to place high-performance equipment on the market, with a clear and unambiguous differentiation from fuel-fired boilers, which should be phased out as rapidly as possible.
During the Consultation Forum held on 24 June 2022 in Brussels, the Commission’s intention to bring together in a single energy label all room heaters, including electric room heaters, was confirmed. Several participants emphasized that this merger would result in: ● having all heat pumps at the top of the energy scale; ● having all electric room heaters (i.e using the Joule effect) at the bottom of the energy…
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