EnBW Energie Baden-Württemberg AG

Europe currently faces extreme geopolitical uncertainty, making energy security, decarbonisation, and lower energy costs top priorities to secure energy supply for its citizens & industry & restoring its competitiveness. Achieving these goals will require a massive expansion of renewable energy & the modernization of electricity grids, demanding hundreds of bn. of Euros in investment.

Decarbonisation of the transport sector: An urgent mandate for the EU to act The transport sector remains one of the main challenges on the path to climate neutrality in the European Union. Despite ambitious targets under the European Green Deal, emissions in this sector have not yet been sufficiently reduced.

Filed in German · English published by the European Commission

We broadly support the EU Taxonomy framework for the energy sector and consider the existing technical screening criteria largely appropriate. We particularly welcome the simplifications introduced in July 2025 and the recent amendments in the Climate Delegated Act, notably with regard to life-cycle emissions for geothermal energy.

EnBW is one of Germanys largest utilities (30.000 employees, 50 billion investments in the energy transition until 2030) and active physical producer and marketer of biogas and biomethane in the EU. We highly appreciate the Commissions continued efforts to strengthen the sustainability framework for renewable fuels. Please find our analysis and feedback in the attached file.

Design of the guide: In the view of the EnBW, the guide should not be sufficiently detailed in terms of bureaucracy to delay transposition in the Member States. It should therefore not stand in the way of detailed rules, which are already in the process of being implemented, which are already in the process of being implemented. The most important is the rapid designation of areas and the acceleration of permits.

Filed in German · English published by the European Commission

At EnBW, we are actively transforming infrastructure to support data centre development and related services. Decommissioned power plant sites within our portfolio are particularly well suited for this purpose, as they already provide ample space, reliable water access for cooling, and, crucially, strong grid connections at scale.

We represent a European asset-backed energy trading firm, active on the wholesale energy markets predominantly to hedge our risks arising from our commercial business (e.g. power generation, retail business). We are therefore an active participant also in the commodity derivatives markets and thus subject to a wide range of financial market laws and regulations, including MIFID and EMIR among others.

EnBW Energie Baden-Württemberg AG welcomes the opportunity to comment on the draft REMIT II Implementing Regulation. While we fully support efforts to strengthen market transparency and integrity, we are concerned that the current draft of the IR will increase burden on market participants without real benefit on market functioning and integrity.

EnBW welcomes the European Commissions draft delegated act under Article 25 of the Net-Zero Industry Act (NZIA), particularly for its balanced and feasible approach to integrating sustainability criteria into public procurement for net-zero technologies. With regard to the listed requirements for PV in Article 2 there are no objections.