EDF - Electricité de France

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.

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)

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.

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.

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 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'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 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.

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…

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.

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.

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 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.

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 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.

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.

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…

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.

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 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.

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 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.