Energy Traders Europe

RED II revision brings opportunities to consolidate a Europe-wide approach to developing standards and harmonising national arrangements for the issuance, use and cancellation of Guarantees of Origin (GoOs) in the gas sector as well as the power sector. The AIB has already developed a standardised system: the European Energy Certificate System - "EECS".

A credible, reinforced and expanded EU ETS is instrumental in achieving the European 2030 climate targets and the 2050 climate neutrality objective in a cost-effective way. Any revision of the EU ETS should be made with the objectives of preserving market confidence, establishing clear and simple market rules, developing reliable standards and ensuring a stable and predictable investment framework through an EU-wide…

Overall, we support the proposal. The development of a robust certification system across the EU is an indispensable first step in achieving a net contribution from carbon removals in support of the EU climate-neutrality objective. We also share the Commissions view that strong action to reduce emissions should not be undermined by shifting focus to carbon removals.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the roadmap on the future EU Commission proposal for a regulatory framework on certification of carbon removals. We have five main recommendations: 1. Standardisation of national certification approaches and monitoring, reporting and verifying (MRV) methodologies will help to expand the voluntary carbon market 2.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on strengthening the carbon border adjustment mechanism (CBAM). We believe that the CBAM should be linked with the EU ETS by way of matching the price of import certificates with the price of emission allowances.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on updating the EU emissions trading system (ETS ). Our main messages are: 1. Reinforcing the role of the EU ETS as a key driver of a cost-effective decarbonisation of the EU economy. 2. Creating a pathway for a gradual expansion of the EU ETS. 3.

We support the overall objective of CBAM as a tool to put a fair price on the carbon emitted during the production of carbon-intensive goods imported into the EU, to avoid carbon leakage, and to encourage cleaner industrial production in non-EU countries.

CONSULTATION RESPONSE Energy Traders Europe Response to Call for Evidence on legal framework for RES after 2030 Brussels, 15 April 2026 A well-functioning and integrated internal energy market is Europe’s most valuable asset in delivering a cost-efficient, secure, and competitive energy transition in line with EU decarbonisation objectives.

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

2040 target - We fully support the EUs ambition to remain a driving force in global decarbonisation efforts and to reduce net greenhouse gas emissions by 90% by 2040 compared to 1990 levels. Sticking to these commitments is essential to provide a strong and credible signal for current and planned investments in low-carbon technologies.

Key messages: 1. Publish default carbon prices as soon as possible - The Commission should publish the methodology and timeline for default carbon prices as soon as possible, especially for electricity imports that will largely rely on default values.

We ask the European Commission to: 1) Provide clarity on the carbon prices effectively paid in other countries before January 2026; 2) Apply CBAM discount to all electricity traded in a country with an existing carbon pricing mechanism; 3) Recognise complementary third countries carbon pricing mechanisms

EFET acknowledges the necessity for strengthening the Non-financial Reporting Directive reporting requirements on sustainability and increasing corporate reporting transparency in order to underpin the transition towards a sustainable paradigm.

We support the overall objective of CBAM as a tool to put a fair price on the carbon emitted during the production of carbon-intensive goods imported into the EU, to avoid carbon leakage, and to encourage cleaner industrial production in non-EU countries.

EFET welcomes the publication of initial ideas on how to establish a suitable market framework for hydrogen and gas to support achievement of EU climate ambitions, and strongly endorses that this should be a central part of the Fit for 55 package. The following is an extract from the more detailed response attached. It is increasingly accepted that net zero emissions by 2050 will be impossible without molecules.

We underline the critical importance of Annex VI in unlocking the full potential of bioLNG in the EU. BioLNG represents one of the most, if not the most credible solution for decarbonising key hard-to-abate sectors, namely heavy and maritime transports.

The European Federation of Energy Traders (EFET) welcomes the publication of the draft Regulation to improve the Unions electricity market design. The European Commissions proposals are a good basis for targeted evolutions of the European electricity market design.

Ensuring a Resilient and Market-Driven EU Energy Security Framework Brussels, 13 October 2025 - Energy Traders Europe welcomes the opportunity to participate in the revision of the EUs Security of Supply Framework. The revision represents an opportunity to strengthen Europes approach to the energy trilemma balancing security of supply, sustainability, and affordability.

Energy Traders Europe welcomes the opportunity to provide feedback on the delegated act on energy efficiency in data centres. We support the objective of improving transparency and contributing to the decarbonisation of electricity consumption.

EFET response to the Hydrogen and Gas Markets Decarbonisation Package Recent exceptional events have obscured the successes of the European gas market in the last 20 years and its ongoing importance to achievement of the Fit for 55 objectives.

Energy Traders Europe (ETE) represents more than 180 members active across European gas, electricity, carbon and associated markets. Our response below focuses on the operational workability of the CBAM platform and aims to ensure a secure, cost-efficient, transparent and predictable framework for the sale and repurchase of CBAM certificates. Key messages: 1.

Energy Traders Europe welcomes the opportunity to comment, as we have serious legal, operational, and technical concerns with the proposal. To ensure feasibility and alignment with REMIT II, we suggest several adjustments, for which detailed explanations and practical examples are included in the Annex.

The European Federation of Energy Traders (EFET) appreciates the opportunity to submit our comments to the proposal of the EU Commission revising the MRR Regulation pursuant to the revision of the EU ETS Directive.

On behalf of the European Federation of Energy Traders (EFET), we are providing this feedback to the Commission’s draft proposal for a Regulation on European green bonds. The European Federation of Energy Traders promotes and facilitates European energy trading in open, transparent and liquid wholesale markets, unhindered by national borders or other undue obstacles.

EFET welcomes the publication of the draft Regulation on Wholesale Energy Market Integrity and Transparency (REMIT II). The further development of the REMIT framework is key to enhancing confidence in the integrity and transparency of EU wholesale energy markets. Still, certain areas of the proposal require changes to meet this objective: 1.

EFET warmly supports the European Commissions proposal to amend EMIR. The EMIR 3.0 proposal facilitates the energy market participants efforts to achieve the aims of the EU internal energy market and helps them to manage the challenges of the current energy crisis, whilst safeguarding transparent and safe financial markets. Energy market participants face numerous challenges caused by the EU energy crisis.

EFET welcomes this opportunity for feedback on the EMIR Review/Clearing Strategy and proposes the following recommendations: Extend the list of eligible collateral. CCP should extend to a wider range the non-cash collateral demanded, not only for clearing members, but also for their clients (e.g., letters of credit, EUAs). EFET members do not dispose of same access to money market as clearing members.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide our comments to the Commission consultation on strengthening the market stability mechanism (Market Stability Reserve). Having entered into force in 2019, the MSR has proven to be an effective instrument.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide feedback on the roadmap to the review of the regulatory framework for investment firms and market operators (Review of the MiFID II/MiFIR framework).