Eurelectric

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.

Eurelectric supports the increased 2030 EU RES target of at least 40%. The key role of renewable electricity is recognised through different amendments, for example, MSs setting up RES-E frameworks, the issuance of GOs for every MWh of renewable energy produced upon request from producer independently of benefitting or not from a support scheme, the enhanced requirement for promoting PPAs, better coordination in…

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030 . While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger.

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.

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.

The energy performance of buildings is a critical issue to tackle in order to reach a climate neutral economy. With 40% of the total EU energy consumption used to heat or cool buildings, improved standard and targets are essential aspects of the task. Following the Renovation Wave Strategy, Eurelectric fully supports the revision of the Energy Performance of Building Directive (EPBD).

We welcome the proposal of the new European Competitiveness fund (ECF), and most remarkably the Clean Transition and Industrial Decarbonisation policy window. Particularly important for competitiveness are (Art. 33): electrification of industries, transport and buildings; innovation, digitalization and reinforcement of distribution grids; energy storage, demand-response; LIFE activities.

Eurelectric welcomes the European Commissions efforts to ensure the European Sustainability Reporting Standards remain both meaningful for investors and operable for reporting companies. We also appreciate the involvement of stakeholders, especially as our extensive representation of the power value chain is a decisive source of expertise in sustainability.

The EU power sector supports the ambition of net-zero greenhouse gas emissions in the European economy by 2050 – key enablers are needed Europe has a unique opportunity to establish its global leadership in clean technologies and sustainability in the fight against climate change in line with the Paris agreement.

Support a level playing field and avoid national fragmentation: Overall, Eurelectric welcomes the Commission's initiative and perceives it as a much-needed step towards a sustainable corporate governance framework. It is of particular importance that a coherent EU framework is not further delayed, as divergent national initiatives have already emerged.

On behalf of Eurelectric, the association representing the European electricity industry, I would like to submit for your consideration our views with regards to carbon removals: Eurelectric welcomes and supports the European Commission initiative to prepare a robust, EU-wide certification system for carbon removals to complement mitigation efforts and reach the net-zero ambition.

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, the sector association which represents the common interests of the electricity industry at pan-European level, thanks the European Commission for the possibility to comment on the proposal for a regulation on the Carbon Border Adjustment Mechanism (CBAM). Eurelectric’s reaction to the CBAM proposal is explained in the uploaded reaction paper. In sum, Eurelectric's key messages are: 1.

Eurelectric represents the European power sector. The association has historically advocated for a robust carbon pricing to deliver substantial GHG emissions reduction across Europe. In the context of greater climate ambitions in the European Green Deal, Eurelectric welcomes the ongoing work of the European Commission and support its investigation for a carbon border adjustment.

Eurelectric, the European electricity industry association, welcomes the chance of expressing its views on the Commission’s proposal for a more ambitious Energy Efficiency Directive. Our full feedback is attached.

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030. While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger.

Please find below a summary of the views of the power sectors on the proposal of the European Commission on the ETS. For more details, please see the document enclosed. • Increase the ambition in the EU ETS. We welcome several of the Commission’s proposals to strengthen the EU ETS in line with the increased 2030 climate target, including the increased linear reduction factor (LRF) to 4.2% in combination with a…

Eurelectric supports the ambition of net-zero greenhouse gas emissions in the European economy by 2050 and an at least 55% target of GHG emissions reduction by 2030 as proposed by the Commission. All sectors of the economy need to contribute to making the EU a climate-neutral economy.

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.

To ensure a fit-for-purpose revision of the current rules, we urge for the following points to be taken into account: 1. Convergence of fiscal rules between Member States must be achieved in order to adequately contribute to the functioning of the Internal Energy Market : The 2019 ETD Evaluation demonstrated that the rates currently applied by MS differ significantly from each other and from the minimum rates…

Digital Fairness Act Input to Call for Evidence I. General Comments Comparison tools in the form of online platforms such as websites and apps are a valuable resource for consumers to compare electricity tariffs and offers. They support informed decision-making at the pre-contractual stage of the customer journey and enhance visibility of the retail market.

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

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.

Dear Members of the European Commission, Eurelectric - the Union of the Electricity Industry - the welcomes the opportunity to provide feedback on the European Commission’s proposal for a Nature Restoration Regulation. Additionally, the European electricity sector represented by Eurelectric welcomes further initiatives jointly addressing the interlinked challenges of climate change and biodiversity loss.

Eurelectric welcomes that the European Commission will propose a new regulation to impose legally binding nature restoration targets. Beside policies aiming to protect the local environment, we will further have to reduce the pressure on our global environment, by combating climate change.

Eurelectric response to consultation August 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)

Revision of the Industrial Emissions Directive – Inception Impact Assessment A Eurelectric comments paper April 2020 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.

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

Climate change should be the first priority when addressing long term sustainable development issues; therefore it is required for the financial sector to adopt a carbon neutral approach to achieve sustainable finance. Eurelectric welcome the Commission proposal that challenges the EU financial regulation with sustainable goals. 1.

Eurelectric fully embraces the European Commission’s decarbonisation objectives and its ambition to cut F-gas emissions, which have a very high global warming potential. DSOs and electricity generation companies are committed to adopting a sustainable approach to the development and operation of their assets.

Eurelectric welcomes the publication of the combined Evaluation Roadmap and Inception Impact Assessment on Fluorinated gases (F-gases). The European power sector supports the EU commitment to reduce the global greenhouse gas emissions towards the achievement of climate neutrality by 2050, as part of the European Green Deal objectives, and is willing to commit further efforts to reduce F-gas emissions as far as…

EC consultation on the proposal for a Corporate Sustainability Reporting Directive (CSRD) A Eurelectric response paper July 2021 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.

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

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.

The European electricity industry, represented by Eurelectric, welcomes the publication of this Commission's initiative to tackle the emissions from road transport. With the proposed CO2 emission performance standards for cars and vans, the European Commission has shown a real commitment to reach carbon neutrality by 2050.

Eurelectric fully supports the targets in the Green Deal and in this sense the anticipated amendment of the Regulation setting emission standards for cars and vans is very positive. During the last review of the Regulation, our industry was already calling for higher targets and more robust mechanisms to incentivise zero- and low-emission vehicles.

The H2/Gas Markets Decarbonisation Package is necessary to prepare the energy system for the challenges posed by the decarbonisation journey. The framework should be coherent with the energy efficiency first principle and the EU’s acquis. Moreover, a pragmatic approach should be adopted regarding the contribution of a decarbonised gas sector to a carbon-neutral Europe.

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)

Eurelectric agrees with the identified problems in this Inception Impact Assessment (IIA) and generally supports the objectives, direction and policy options put forward by the Commission. Electrification of transport within an increasingly cleaner electricity mix is the most effective, efficient and sustainable way to decarbonise the sector, reduce its dependence on fossil fuels imports from outside Europe and…

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…

•Eurelectric welcomes the revision of the Trans-European Networks for Energy (TEN-E) regulation to future-proof Trans-European energy infrastructure and deliver on climate ambitions. Therefore, the TEN-E Regulation (including infrastructure planning) should be consistent with the Green Deal objectives, especially regarding the Energy Efficiency First Principle. •Overall, the proposal’s direction is correct.

Eurelectric welcomes the publication of the evaluation roadmap and inception impact assessment. A revision of the TEN-E regulation is necessary, going hand in hand with a broader access to EU funding (such as the CEF) as well as new investments, being fully in line with strengthened sustainability criteria. We would like to invite the Commission to read the enclosed paper and consider the following points: 1.

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.

Shaping a Just Transition Fund fit for purpose Eurelectric position paper March 2020 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)

The Trans-European Transport network (TEN-T) is the skeleton for zero and low emission transport across Europe. The new guidelines need to be in line with the ambitions of the Green Deal as well as reflect the ongoing revision of the EU Directive on Alternative Fuel Infrastructure and the update of CO2 emission standards for cars and vans.

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.

As part of its Sustainable Finance and Digital Finance strategies as well as of its Capital Markets Union Action Plan, the European Commission plans to establish an EU-wide mechanism offering easily accessible, comparable and digitally usable databases on the public reporting requirements of companies, including sustainability information: the European Single Access Point (ESAP).

Eurelectric, the Union of the European electricity industry, welcomes the ongoing review process of the Alternative Fuels Infrastructure Directive (AFID). As presently constructed, the Directive still includes and supports pure fossil fuels which would clearly impede a path towards decarbonising the road transport sector.

Eurelectric welcomes the proposal of the European Commission to streamline EU decision-making on certain tax issues by removing the need for unanimous agreement by all countries. The evolution towards a qualified majority voting system could contribute to build more efficient sectorial regulatory provisions, starting with a revision of the Energy taxation directive.

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.