Eurelectric

Eurelectric welcomes the evaluation and upcoming review of the existing Public Procurement Directives. The review can, if designed appropriately, be useful to support the electricity sector in enabling the energy transition.

Eurelectric welcomes the opportunity to respond to the consultation and supports the objective of simplification. The electricity sector acts both as contracting entities (e.g. grids, publicly owned power producers) and as bidders for renewables for public entities. Assessment: For grid operators, procurement delays the speed of modernisation and expansion.

It is essential that revisions do not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of the Taxonomy by simplifying and clarifying the current criteria where needed. On horizontal issues, TSC should be made less detailed, hence more interpretable, also for investors. Some TSC also go beyond the current regulatory environment.

It is essential that revisions do not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of the Taxonomy by simplifying and clarifying the current criteria where needed. On horizontal issues, TSC should be made less detailed, hence more interpretable, also for investors. Some TSC also go beyond the current regulatory environment.

An EU Regulation to Electrify Corporate Fleets Eurelectric position paper September 2025 Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector. Our members represent the electricity industry in over 30 European countries. We cover the entire industry from electricity generation and markets to distribution networks and customer issues.

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

Eurelectric supports the European Commissions revision of the Cybersecurity Act and its work on harmonising cybersecurity frameworks across the Union and within the power sector. We welcome the opportunity to provide views on the revised EU Cybersecurity Act and supports its efforts to strengthen cyber resilience while improving harmonisation across the EU.

Eurelectric welcomes the evaluation and upcoming review of the existing EU Cybersecurity Act. The review can, if designed appropriately, be useful to support the electricity sector in reinforcing energy security in Europe. ENISA plays a vital role in coordinating cybersecurity measures across the electricity sector, particularly in ensuring the resilience and security for the European grid.

A Post-2030 Framework Fit for the Electric Age Eurelectric discussion paper March 202 6 EURELECTRIC is the voice of the electricity industry in Europe. We speak for more than 3,500 companies in power generation, distribution, and supply. We Stand For: Carbon-neutral electricity in Europe well before mid-century We have committed to making Europe’s electricity cleaner.

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

Eurelectric appreciates and supports the Commissions effort to streamline the Taxonomy. The priority should be on improving the clarity, usability and consistent interpretation of the existing criteria to ensure effective implementation and steer investments towards the clean transition. In the support attachment, we provide recommendations for further improvements.

Eurelectric supports the Commissions work to enhance the usability of the Sustainable Finance Disclosure Regulation (SFDR). Towards this end, we wish to contribute targeted recommendations to improve the new SFDR proposal.

The categorization of funds under the SFRD should be streamlined including clear definitions and linkages with products available in the markets as well as clearly aligned with ESG strategies of Financial Market Participants To this end, it is key to ensure consistency with performance indicators, ideally to be assessed by means of both voluntary and mandatory standards.

Eurelectric welcomes the opportunity to respond this call. Ensuring Europes climate resilience and adequate risk management remains fundamental to addressing the greatest challenge of our time, particularly for the fastest-warming continent. As Europe moves towards an electrified economy, a resilient power system will be crucial to protect citizens and safeguard competitiveness.

Call for Evidence on the Grids Package A Eurelectric consultation response paper July 2025 Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector. Our members represent the electricity industry in over 30 European countries. We cover the entire industry from electricity generation and markets to distribution networks and customer issues.

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

While we agree with the principle of consistency with the EU Taxonomy (Art. 5), we warn that the DNSH rule in its current form could be difficult to interpret and apply, hence counterproductive. We recommend that the DNSH rule and the related Technical Screening Criteria should be simplified to increase their usability, while also avoiding inconsistent duplicates with the EU Taxonomy or unnecessary reporting burdens…

We welcome this call for feedback on the legal framework for the energy efficiency directive post-2030. Attached is Eurelectric's position on A Post-2030 Framework Fit for the Electric Age. Importantly, electrification and energy efficiency reinforce each other: clean electricity enduses are much more energy efficient than their fossil-based counterparts.

Europes energy security must evolve beyond the traditional focus on fuel supply to address resilience, flexibility, and the reliability of infrastructure in an increasingly electrified and renewable-based energy system.

Eurelectric response on Network code on requirements for grid connection of generators – revision August 2026 Eurelectric welcomes the launch of the public consultation process by the EC for the adoption of the revised network code on requirements for Generators (NC RfG) as new challenges emerge on the European electricity system triggering the needs on stable and clear regulatory frameworks to contribute to its…

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

Eurelectric response to the Public Consultation on the Draft Delegated Act establishing the methodology for the calculation and verification of the carbon footprint of EV Batteries. Eurelectric, representing the European electricity sector, welcomes the opportunity to comment on the draft delegated act establishing Product Carbon footprint (PCF) requirements for EV batteries.

The following response relates to the aspect 'untapping the potential of the cross-border dimension of the retail energy market to allow citizens to benefit from simplified and consistent consumer right rules in energy throughout the EU.' In general, it is the job of Member States to ensure that consumer rights become concrete by transposing and implementing EU legislation, in particular the Clean Energy Package and…

Overall, we are concerned that the draft increases reporting burden without commensurate surveillance benefit. Exposure reporting is the clearest example. The notion of flagging prima facie unjustified trading behaviour implies a de facto hedge benchmark and the sanctioning of deviations from it.

Enclosed please find an accompanying document to our response to the questionnaire, outlining the need for Europe to update its security of supply strategy and highlighting the key elements that should be considered. Eurelectric is currently working on a flagship study, titled Redefining Energy Security, set for launch in February 2025.

We appreciate the Commissions proposal of a streamlined Performance Framework to track the EU Budget expenditure. Particularly, we welcome the rationale of a harmonised Framework to create transparency and a level playing field across various funding and financing programmes. The Single Gateway will also foster simplification by centralising access to information about calls for the various programmes.

Eurelectric key messages (please refer to our position paper for our entire position) As the complexity and relevance of electricity market integration increases, Eurelectric supports ACERs role in promoting electricity policy coherence in the common European interest and providing transparent information about market functioning.