EDF

EDF welcomes the European Commission initiative to propose a Circular Economy Act to facilitate the free movement of circular products, secondary raw materials and waste. We share the belief that it will enhance the EUs economic security and competitiveness, while promoting more sustainable production, circular economy business models and decarbonisation.

As a contracting entity that is confronted on a daily basis with the implementation of Directive 2014/25/EU and Directive 2014/23/EU, the EDF Group welcomes the revision and simplification announced by the European Commission.

EDF Position Paper on the European Industrial Accelerator Act EDF welcomes the European Commission’s ambition to reinforce Europe’s industrial resilience, decarbonise energy-intensive sectors, and strengthen the EU strategic autonomy in clean technologies.

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

Please finalise the position from EDF (Electricite de France) on the proposal to amend REDII. In short: For EDF welcome: • the increased RES target of 40 % at EU level by 2030, in line with the new 2030 climate objective (Article 3); • the new provisions on e-mobility: Bidirectional loading stations and data sharing on batteries to develop flexibility and storage solutions for the growing share of RES (Article 20a)…

Filed in French · English published by the European Commission

EDF welcomes the opportunity to comment on the Roadmap related to the review of the EU’s renewable energy rules. As the European leader of carbon free electricity with a close to 90 % decarbonized generation mix, EDF strongly supports the target of net zero emissions by 2050 and an increased GHG emission reduction target by ‘at least 55%’ in 2030.

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

The EDF Group thanks the European Commission for this public evaluation and consultation on the framework of public procurement. The upcoming review announced for 2026 is particularly relevant given the content and objectives set out in the Clean Industrial Deal, as we believe public procurement will be an essential building block in the implementation and success of the Clean Industrial Deal.

EDF fully supports the EPBD revision. This is an opportunity to ensure that the EPBD is fully aligned with Green Deal climate objectives and coherent with other legislations. Taking into account the target of at least -55% of GHG emission reduction by 2030, a full decarbonised building stock has to be the primary target : this proposal goes into the right direction.

EDF fully supports the EPBD revision as part of the Fit for 55 Package. This is an opportunity to ensure that the EPBD is fully aligned with Green Deal climate objectives and coherent with other strategies or legislations. To that end, the option 3 of the roadmap is fully appropriate.

[See details and proposals in the paper attached] The ECs Clean Industrial Deal highlights the need to accelerate decarbonisation, reindustrialisation, and innovation, combining climate action, competitiveness, and security under one overarching growth strategy. Energy, particularly electrification, is central to these objectives. Therefore, the 2028-2034 MFF must allocate sufficient resources to this sector.

EDF welcomes the proposed changes to sustainability reporting standards, as the current proposal strikes the right balance between the usefulness of the information for decision-making and the burden placed on those preparing the reports. EDF would like to thank the Commission for the progress made in this regard.

Electricité de France (EDF) welcomes the European Commission’s proposition for a Climate Law enshrining a legally binding climate neutrality target for Europe by 2050. As the European leader of carbon free electricity with a close to 90% decarbonized generation mix, EDF intends to put all its efforts in the European Green Deal and supports this ambitious climate commitment.

Feedback on the Roadmap on the European Climate Law EDF welcomes the draft climate law creating a net zero emissions 2050 target for the EU. This long term orientation is key to the future of Europe. Not only does the EU set an example to the rest of the world, but it also creates the conditions of a de-carbonised growth that will create leaders in new technologies and foster job creation in Europe.

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

POSITION PAPER Comments on Sustainable corporate governance directive Answer to the public consultation - 23/05/2022 GENERAL COMMENTS EDF is fully aware of the importance of acting in favour of the environment and people and has long been committed to integrating human rights and environmental issues into its governance and in the frame of the implementation of its activities.

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

EDF group is pleased to contribute to the ETS review consultation and to share its feedback. Please find enclosed our feedback document. In a nutshell, we particularly welcome the upcoming ETS Review (EU ETS 1) as a key opportunity to strengthen the framework for an EU Emissions Trading System that supports a competitive and effective decarbonization pathway at the EU level, in line with the goal of climate…

Please find attached our feedback on the call for evidence for corporate fleets. EDF operates a fleet of more than 48 000 light-vehicles and is committed to electrify all of its fleet by 2030. We are supporting this EU initiative that will contribute to decarbonize the transport sector, provide a strong demand push for electric vehicles (EVs) and enhance the second-hand market of EVs.

EDF’s feedback on the Commission Proposal of a Carbon Border Adjustment Mechanism European Commission ex post consultation • • • • • • EDF welcomes the Commission Proposal of a Carbon Border Adjustment Mechanism. This climate tool sets the smart principle of an incentive for importers to decarbonize products entering the European Union.

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

EU Green Deal – Carbon Border Adjustment mechanism EDF Contribution The Climate Law, published by the Commission on 4 March 2020, includes the goal of climate neutrality for the EU by 2050 and suggests an increased climate ambition to reduce GHG emissions by 50-55% by 2030 from 1990 levels. Reaching these targets is likely to involve a significant increase in EU ETS carbon price that can lead to carbon leakages.

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

EDF welcomes the revision of the EED, which is an opportunity to ensure that it is fully aligned with Green Deal objectives and coherent with the EU ETS, the RED, the EPBD, the ETD, the Energy System Integration Strategy, and the Renovation Wave strategy. Nevertheless, these legislative works have to be done with a focus on affordability, taking into account the most cost effective way to reach the climate targets.

The Directive 2012/27/EU on energy efficiency (EED) revised in 2018 is a key element to achieve the European Green Deal objectives, with the Renewable Energy Directive (RED) and the European Emissions Trading System (EU ETS).

In short below and for details please find enclosed EDF(Electricité de France)'s contribution EDF welcomes the ambitious revision of the EU-ETS to align it with the new 2030 target. A meaningful carbon price will drive cost-effective energy transition by promoting investments in renewable and low-carbon technologies.

EDF welcomes the opportunity to comment on the proposed Cybersecurity Act revision, to outline its concerns and structural needs as an organization that uses digital services. (1) The lack of relevance of the distinction between technical and non-technical risks.

EDF’s position paper on the Carbon Border Adjustment Mechanism (CBAM) Feedback to the European Commission The EU’s Carbon Border Adjustment Mechanism (CBAM) is set to be implemented in the coming months (beginning of 2026). The CBAM represents a key pillar of the EU’s climate ambition, aiming to reduce carbon leakage, support a more sustainable European industrial base, and ensure fair carbon pricing on imports.

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

EDF welcomes the intention of the Commission to review the Energy Taxation Directive (ETD). The current Energy Taxation Directive does not contribute to the EU’s climate and energy policy goals: there is no link between minimum tax rates and their energy content and CO2 emissions. The ETD does not provide preferential tax treatment for low-carbon energy final consumption.

EDF's feedback on the Renewable energy legal framework after 2030 The post‑2030 period will determine the conditions under which Europe can secure its energy independence while achieving climate neutrality, reinforcing competitiveness, and ensuring a resilient energy system.

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

EDF welcomes this initiative as the proposed amendments move towards greater alignment with the requirements of existing legislation. Indeed, as a general principle, the Taxonomy should rely on and refer to existing legislation and avoid adding more stringent requirements.

As a major player in Europes energy transition, EDF reaffirms its commitment to low-carbon energy production and the electrification of the energy uses. With over 700 million invested annually in Research and Innovation (R&I), EDF is one of the European leaders in research for the energy sector and historically a strong contributor to collaborative projects in the European Research Framework Programs.

EDF welcomes the publication of the Data Act and its objective to fulfil the ambition set out by the Data Strategy: to make the EU a leader in a data-driven economy. The focus on data sharing and availability, data interoperability, portability, and sovereignty are highly relevant.

EDF welcome the Commission’s ambition in its proposal for regulation on nature protection. EDF shares the view that this action is imperative and supports binding targets to ensure the retoration of ecosystems at European level. We also acknowledge the fact that each habitat has its own particularities and received the differentiated approach within the criteria defined for each ecosystem.

Filed in French · English published by the European Commission

15th September 2025 EDF's position paper on the European Climate Law amendment EDF fully supports the European Union’s climate ambition and is committed to achieving net-zero emissions by 2050. As the world’s largest producer of electricity with zero direct CO₂ emissions 1 - thanks to its nuclear and renewable assets - EDF advocates for a strong 2040 climate target aligned with the EU’s 2050 neutrality goal.

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

EDF group welcomes the opportunity to provide a feedback on the carbon price paid in a third country. EDF groups main concern relates to how electricity is treated under the current framework. Due to its unique characteristics, an effective implementation of the Carbon Border Adjustment Mechanism (CBAM) for the electricity sector poses challenges.

EDF strongly supports the overall ambition of the EU Green Deal: to reach climate neutrality by 2050, as well as a 55% cut in GHG emissions by 2030. To implement this, the Group can build on an existing 90% decarbonized energy mix, thanks to the synergy between renewables and nuclear energy.

A LEADING ROLE FOR THE FINANCIAL SECTOR The financial sector financial must first recognize that the priority of sustainable finance is to harmonize financial flows with a pathway to lower greenhouse gases and more climate-resilient development, according to the Paris agreement and social expectations. Secondly, the sector must recognize the urgency of the climate change challenge.

EDF welcomes the proposal for the new Battery Regulation as an opportunity to create a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy and Circular Economy Action Plan. See the full position paper attached

EDF welcomes the proposal by the European Commission to modernize the EU’s battery legislation. This review provides the opportunity to create a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy and Circular Economy Action Plan.

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

EDF position paper on the revision of the F-gas Regulation EDF strongly supports the Commission ambition to reach climate neutrality by 2050, as well as a 55% cut in GHG emissions by 2030. The Group can build on an existing 90% decarbonised energy mix, thanks to the synergy between renewables and nuclear energy. EDF committed itself to further reduce its CO2 emissions when adopting its “raison d’être”.

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

POSITION PAPER Comments on the proposal for a directive as regards corporate sustainability reporting Answer to the public Consultation – 14/07/2021 The Commission presented its proposal for a Corporate Sustainable Reporting Directive on 21 April.

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

The EDF Group relies on a strong presence in coastal, estuarine, and maritime zones. This dynamic is part of EDF's strategy to increase low-carbon electricity generation, notably through the launch of an industrial program for three pairs of EPR2 reactors in France, two of which could be built on the coast at Penly and Gravelines, and through the development of marine renewable energies and off shore wind power by…

As a major player in the energy transition, the EDF Group supports any initiative that could contribute to the restoration of nature on a large scale and welcomes the European Commission’s approach to building a framework for a high integrity, transparent and robust credit market.

Filed in French · English published by the European Commission

EDF group welcomes the opportunity to share its feedback on CBAM implementing act regarding emission accounting methodologies. EDF group's main concern relates to how electricity is treated under the current framework. Due to its unique characteristics, an effective implementation of the Carbon Border Adjustment Mechanism (CBAM) for the electricity sector poses challenges.

Feedback on the Net Zero Industry Act June 2023 EDF’s feedback on the Net Zero Industry Act GENERAL COMMENTS EDF welcomes the attention given by the European institutions to the subject of reindustrialization. As such, the proposal for a Regulation on a Net Zero Industry Act (NZIA) will facilitate the transition to low-carbon energy.

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

The resilience of electricity power plants is crucial for society to avoid adding an electricity crisis to the social and environmental crises caused by climate change. This call for evidence provides EDF, the world's leading investor and producer of carbon-free electricity, with the opportunity to share the experience of a major European energy utility that has recognized climate risks and subsequent adaptation…

EDF welcomes the Commissions initiative to ensure that the EU and its Member States become prepare for climate risks. The resilience of electricity power plants is crucial for society to avoid adding an electricity crisis to the social and environmental crises caused by climate change.

Low carbon and renewable (LC&R) gases will be needed to complement direct electrification and contribute to a net-zero economy, especially in hard-to-abate sectors. To support energy sector integration, it is key to compare costs, potentials and societal benefits of decarbonisation options from production to end users and avoid the sole focus on infrastructure costs.

EDF welcomes the European Commission proposal for a Regulation on the deployment of alternative fuels, as part of the “fit for 55” package. The transport sector should indeed decrease its GHG emissions drastically to reach the renewed climate objectives enshrined within the EU Green Deal and carbon neutrality by 2050.

EDF welcomes the opportunity to contribute to the development of the Electrification Action Plan and is pleased to see such initiatives acknowledging the central role of electrification in achieving carbon neutrality by 2050, enhancing competitiveness, and ensuring energy security.

11th September 2025 EDF's position paper concerning an EC legislative initiative on CO2 transportation infrastructure and markets EDF group, which operates a largely decarbonized production fleet1, would like to share its positioning as a CO₂ emitter for the residual emissions from its thermal assets and as a potential user of CO₂ infrastructure.

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

EDF welcomes the impact assessment carried out on the Waste Shipment Regulation (WSR) aimed at facilitating the re-use and recycling of waste within the EU. As a major actor in the energy transition, EDF has been committed for many years to the principle of circular economy when it comes to the preservation of natural resources - water, air, soil, raw materials - and waste management.

EDF welcomes the opportunity to contribute to the development of the EU Heating and Cooling Strategy. Together with the Electrification Action Plan, this initiative can serve as a cornerstone of Europes electrical transition. EDF strongly supports the strategic focus on decarbonising heating and cooling and emphasises that electrification must be placed at the heart of this effort.

POSITION PAPER Trans-European energy infrastructure Feedback on the proposal for a Regulation – 05/03/2021 A key player in the energy transition, the EDF Group is an integrated electricity company, active in all areas of the business: generation, transmission, distribution, energy supply and trading, energy services.

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

A key player in the energy transition, the EDF Group is an integrated electricity company, active in all areas of the business: generation, transmission, distribution, energy supply and trading, energy services. You will find EDF group's input for the possible evolutions of the TEN-E regulation in the document attached.

According to latest IEA data, there were around 70 million tons of methane emitted to the atmosphere from oil and gas operations in 2020, this is broadly equivalent to total energy-sector emissions of the entire EU. EDF would like to highlight that the impact of methane is 30 times that of C02 on a 100 year time horizon, but it is ca. 85 times that of CO2 over a 20 year time span (1) .

You can find our position paper attached. The EDF Group firmly supports the electrification of road transport and the current 2035 target prohibiting the sale of new combustion engine vehicles. Indeed, the 2035 ban for new internal combustion engines is the only way to achieve the zero-emission target by 2050.

EDF group thanks the European Commission for the opportunity to contribute to the consultation on the draft Delegated Act revising Annexes V and VI of the Renewable Energy Directive. The Group wishes to share several technical and operational observations regarding the proposed default values, the associated methodologies, and the envisaged implementation framework.

EDF welcomes the European Commission proposal for a revised Directive on Security of Network and Information Systems (NIS 2 Directive) that will improve the EU’s overall cybersecurity, including in a strategic sector such as energy.

EDF welcomes the opportunity to share its vision on the future Energy Efficiency Framework post 2030. It should be stressed that this response should be read combination to our response on the revision of the Governance regulation and the RED post 2030 framework. Here, EDF would like to stress that electrification is Energy Efficiency and that it should be better reflected in the legal framework.

Position Paper EDF – Market Design Revision The Commission's proposal to adjust the Market Design is a decisive step to enhance electricity markets in a turbulent context. Indeed, in recent years, challenges have accumulated. First, the pace of investments has been insufficient to meet the EU’s climate commitments.

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

EDF welcomes the opportunity to contribute to the consultation on the update of the Governance of the Energy Union and climate action. Europes post2030 framework will be key for reinforcing energy independence, industrial competitiveness and our pathway towards climate neutrality.

Energy security is key for EU sovereignty in a new turbulent world characterized by new threats (geopolitical instability), changes in the energy system (growing integration of variable RES and electrification) and urgent challenges (climate change). An appropriate regulatory framework must support a decarbonised, resilient, and electrified energy system.

EDF welcomes the launch of the comitology process for the adoption of the revised Delegated Regulation establishing network code on requirements for Generators (RfG) as new generation and storage capacity is massively entering the European electricity system and needs to contribute to its stable and secure operation. EDF though regrets this launch intervenes only now (i.e.

EDF group is supporting the ambitions of the public authorities in the decarbonisation of the production mix and the development of renewable energies in French Outermost Regions. We fully welcome the current strategic initiatives (communication and regulatory simplification package) dedicated to the EUs outermost regions, as the ORs possess unique characteristics that must be considered when shaping EU legislation.

EDF group is supporting the ambitions of the public authorities in the decarbonisation of the production mix and the development of renewable energies in French Outermost Regions. EDF fully welcomes the current strategic initiatives (communication and regulatory simplification package) dedicated to the EUs outermost regions, as the ORs possess unique characteristics that must be considered when shaping EU…

EDF expresses its strong support to maintain the Connecting Europe Facility in the future as this funding programme is one of the most efficient instruments at European level to support infrastructure investments.

EDF welcomes the European Commission’s FuelEU Maritime initiative aiming to reduce GHG emissions in the maritime sector. Today maritime transport is a growing source of GHG emissions and the EU needs to tackle this issue to be fully in line with the Green Deal and the carbon neutrality target by 2050.

We suggest to extend the principle of complete removal of paper-format instruction manuals to professional products in-scope of Regulation 2024/1781 (Ecodesign regulation). Indeed, while COM(2025)503 aims at achieving the complete removal of paper-format instruction manuals, the Regulation 2024/1781 (Ecodesign regulation), proposed to be modified by COM(2025)504, keeps on requiring that essential elements be…

EDF welcomes the proposal for the Batteries and Waste Batteries Delegated Regulation dedicated to establishing the methodology for the calculation and verification of carbon footprint of EV batteries. The Batteries and Waste Batteries Regulation is a major initiative to create a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy and Circular Economy Action…

EDF welcomes the opportunity to share its view on the common rating scheme for data centres and wishes to stress the following points: the need to prioritize a location based approach to measure the carbon intensity of electricity supply; the importance of more granular, transparent and harmonized carbon accounting at EU level; the necessity to preserve technological neutrality, allowing for the use of nuclear…

Acting as a utility, aggregator and charge point operator, the EDF Group welcomes this technical update of the Measuring Instrument Directive in order to notably introduce harmonized requirements for EV charging stations. We have made some comments (mainly asks for clarification/definitions) and proposals for improvements in the attached file. They cover annexes I, III, IV.

Direction des Affaires Européennes-European Affairs 12 Mars/March 2020 EDF fully supports a Just Transition Fund for that leaves nobody behind, coal regions but also isolated parts of the European Union such as islands       1 EDF is a major European electricity utility with a turnover of 71billions of Euros employing 160 000 persons and investing about 14billions of Euros per year.

Filed in French · English published by the European Commission

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

EDF recognizes that the revision of the Gas Directive & Regulation is needed to adapt the regulatory framework to the necessary changes in the gas system to progress towards a decarbonised Europe, while preserving the fundamentals of the current market structure.

Harmonised European standards (hENs) has fundamentally proven its value through the involvement of all relevant stakeholders. Yet, there may be some instances where hENs do not deliver on time and where common specifications may be appropriate to fill the gap.

With regard to Regulation (EU) 2024/573 on fluorinated greenhouse gases (F-gas Regulation), we would like to draw attention of the Commission to what we consider to be a flaw in the system: the impossibility, as the regulation currently stands, of placing HFCs on the market beyond 2050, although this would be necessary to meet safety requirements at operating industrial sites (including nuclear).

EDF Group welcomes the opportunity given to concerned stakeholders to provide feedback on the REMIT II draft implementing act. EDF Group is committed to the importance of having sector-specific regulation for the energy sector and its objective of market transparency and integrity.

EDF welcomes this opportunity to give feedback on the draft implementing regulation of the EU ETS. We would like to draw your attention to the need for consistency between the revised Directive (EU) 2018/2001 -RED- and the Implementing Regulation 2018/2066 -MRR.

Filed in French · English published by the European Commission

EDF expresses its strong support to maintain the Connecting Europe Facility in the future as this funding programme is one of the most efficient instruments at European level to support infrastructure investments.

With regard more specifically to Regulation (EU) 2024/573 on fluorinated greenhouse gases (F-gas Regulation), we would like to take advantage of this consultation to draw attention to what we consider to be a flaw in the system: the impossibility, as the regulation currently stands, of placing HFCs on the market beyond 2050, although this would be necessary to meet safety requirements at operating nuclear sites.

EDF welcomes the opportunity to provide feedbacks on the European Regional Development Fund (ERDF), Cohesion Fund (CF) and the Just Transition Fund (JFT) in the framework of this mid-term evaluation. As a key-player of the decarbonization of the French and European economy, EDF Group supports the Commissions initiative to redefine the priorities of these funds to better streamline the financial efforts for the…

We would like to draw attention to overseas territories facing specific geographical and logistical constraints that should warrant full consideration in the development of the European regulatory framework governing shipments of non-hazardous waste to third countries.

This document constitutes the position paper of the EDF Group submitted in response to the European Commissions call for evidence regarding the Radioactive Waste Directive (2011/70/Euratom) and the Shipment Directive (2006/117/Euratom).

EDF welcomes this European Commission consultation on the efficiency and effectiveness of ACER in delivering its mandate. ACER plays a central role in shedding light on the functioning of integrated European electricity and gas markets and on the economic value they create for the European Union.

EDF highlights that the decline of the use of fossil fuels in the EU energy mix is a necessity to reach the European climate objectives following different pathways and pace depending on the initial energy mix of each country.

EDF welcomes this public consultation on the evaluation of the Measuring Instruments Directive (MID), Directive 2014/32/EU. While the overall objective of the text makes sense, its scope is no longer fit for purpose. Indeed, we believe that the 2014 Directive should be adapted to the technological progress which have been made since then, as foreseen under the current technical update parallel to this consultation.

EDF considers that the overall structure of the current procedural framework is balanced and functional. The system established by Regulations No 1/2003 and No 773/2004 has enabled the effective, uniform and decentralised application of EU competition rules, while ensuring close cooperation between the Commission and the various stakeholders. We see no compelling reason to change this system.