Finnish Energy

Finnish Energy represents Finnish energy sector companies and employers that produce and distribute electricity, district heating and cooling and of otherwise connected to energy industry. Our members play a key role in enabling energy solutions for society and industry, and in promoting a sustainable, competitive, and low-emission energy system. We see the advancement of the circular economy as highly desirable.

STATEMENT 1 (2) 22.1.2026 Statement on the Revision of the Public Procurement Directives Finnish Energy, representing the Finnish energy industries, welcomes the opportunity to respond to the consultation and wishes to highlight the following issues regarding the revision of the public procurement directives: Simplification of the rules Finnish Energy supports the objective of simplification to ensure the continuity…

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

Made in EU criteria is applied on nuclear energy, including both power and heat. Nuclear technologies are highly plant supplier specific. IAA should not limit the availability of nuclear OEM components. Nuclear heat is undeveloped sector with highly plant-specific key components. Finnish Energy considers it necessary to promote low-carbon products based on new technologies through demand-creating instruments.

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.

Finnish Energy’s comments on on public consultation on EU renewable energy rules Finnish Energy supports commissions target to make Europe the first climate neutral continent in the world by 2050 and agrees on the role of renewable energy on helping to achieve the target and to make our energy supply more affordable and secure by reducing the EU’s dependency on imported fossil fuels.

Finnish Energy, representing the Finnish energy industries, would like to highlight the following three issues regarding the public procurement directive (2014/25/EU): 1) Simplification and flexibility of rules Simplifying and allowing adequate flexibility in public procurement procedures is necessary in order to ensure the continuity of supply of critical assets essential to the energy infrastructures.

Finnish Energy supports the Commissions aim to improve the usability and clarity of Taxonomy. Revisions must not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of Taxonomy by simplifying and clarifying the current criteria where needed. We do not support tightening existing greenhouse gas (GHG) thresholds.

About Finnish Energy Finnish Energy represents the Finnish electricity, gas, and heating sectors, and we have 270 members. We strongly support the Commission’s proposal for the EU’s climate targets for 2030 and 2050. We are also committed to Finland’s carbon neutrality target for 2035.

Finnish Energy (FE) believes that the revision of the EPBD should be coherently implemented within the “Fit for 55 Package”. A cost-efficient and technology neutral climate framework based on the EU ETS will prioritise climate action and bring transitions costs down. EU ETS is certain and efficient way to ensure emission reductions and would also minimise the costs for citizens.

We welcome the proposal for the new European Competitiveness Fund (ECF), particularly the Clean Transition and Industrial Decarbonisation policy window. A competitive and innovative EU can continue to be a major player, creating prosperity for its citizens. There is fierce international competition for clean transition investments.

Finnish Energy broadly welcomes the proposed revisions to the European Sustainability Reporting Standards (ESRS). The direction towards simplification, improved usability, and a stronger focus on material information is positive and aligns with the objective of reducing unnecessary reporting burden for companies. However, we still see a need for some clarifications and amendments. Please find our feedback attached.

Finnish Energy is in favor of setting intermediary targets to lay a linear path towards net-zero emissions by 2050. For us, the most important elements of the climate framework are the clarity and certainty of the 2050 carbon neutrality target as well as confidence in the Emissions Trading System to remain a central policy.

Certification of carbon removals – Call for Evidence Finnish Energy, branch organisation for the industrial and labour market policy of the energy sector, welcomes the call for evidence for an impact assessment regarding certification of carbon removals. A framework for carbon removals is needed swiftly Finnish Energy calls for a swift establishment of a framework for the certification of carbon removals.

Taking care of competitiveness and avoiding emissions to slip outside of Europe are relevant concerns. Carbon leakage takes place also in the electricity sector, for example between Finland and Russia, as imported electricity carries no cost of carbon. One option is to introduce a Carbon Border Adjustment to place a carbon price also on imported products.

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.

Finnish Energy, the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, thanks for the possibility to give feedback to the roadmap for the impact assessment on the review of EED.

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality.

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment for the EU ETS revision. We would like to highlight the following points to consider: 1. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report). The revision of the climate policy framework is a great opportunity to clarify incentives for CRT.

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.

Finnish Energy (FE) thanks for the possibility to give feedback to the Inception Impact Assessment. FE supports the EU to restructure the Community framework for the taxation of energy products and electricity. The existing directive is in many ways outdated as it is from the year 2003 and does not recognize the current climate and energy policy objectives and measures.

In general, Finnish Energy supports the objective of Digital Fairness Act to ensure a fair digital environment for both consumers and businesses. However, we emphasize that there is no need for new EU-level regulations to ensure consumer protection online.

Finnish Energy is the main industry association representing Finlands energy sector. It represents companies that produce, acquire, transmit, and sell electricity, gas, district heating, and district cooling, as well as related services.

Finnish Energy represents companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related services. Finnish Energy welcomes the opportunity to comment on the European Commissions review of the EU Taxonomy Climate Delegated Act.

FEEDBACK 1(1) Marja Rankila Heidi Lettojärvi 22nd August 2022 Nature Restoration Law 25.000km free flowing rivers The Proposal aims to restore at least 25,000 km of free-flowing rivers by 2030 through the removal of obsolete barriers. Finnish Energy welcomes the clear wording that removal of obsolete barriers is not aimed at barriers used for generating low-carbon energy, such as hydropower.

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

Finnish Energy (ET) welcomes the Commissions proposal to achieve 90% net emission reductions by 2040 compared to emissions level in 1990. Finlands own goal is to achieve carbon neutrality by 2035. Achieving this goal requires all zero and low carbon energy solutions, including renewables, nuclear, energy efficiency, storage, CCS, CCU, natural carbon removals, geothermal, hydro-energy, and other current and future…

Finnish Energy represents the Finnish electricity, gas, and heating sectors, and we have 270 members. We strongly support the EU’s climate targets for 2030 and 2050. We are also committed to Finland’s carbon neutrality target for 2035.

Finnish Energy welcomes the update of the heating and cooling strategy as a top-down strategy to decarbonise heating as to ensure cost efficient transition to climate neutral future. Finland showcases as a great example how to phase out fossil fuels whilst simultaneously building our capabilities for sector integration and district heat electrification.

Finnish Energy’s views on the revision of the TEN‐E Regulations Finnish Energy (ET), the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, welcomes the revision of Guidelines Trans‐European Energy Networks.

Finnish Energy, representing around 270 Finnish companies active in the production, acquisition, transmission and sale of electricity, gas, district heating and district cooling (and related services), supports the Digital Fitness Check objective of creating a simpler, clearer and more coherent EU legal framework for digitalisation.

Finnish Energy, representing the energy sector in Finland, appreciates the opportunity to contribute to the consultation on the proposed revision of the Greenhouse Gas (GHG) emission saving methodology under Annex V and VI of the Renewable Energy Directive (REDIII).

Finnish Energy welcomes the Commission’s preliminary thoughts on the content of the impact assessment and policy options. In addition to those, Finnish Energy calls for the market creation for carbon removals and clarification the use of international units. Carbon removal technologies (CRT) are important in a post-Paris world (IEA 2016 CCS report).

The permanence of international credits should match the target they are used for. When used for to meet the targets in the LULUCF-sector, they could be from either permanent carbon capture or from nature-based solutions. When used to meet the targets of ESR-sector, they should be from permanent carbon capture and follow the same logic as when benefiting domestic carbon capture.

Finnish Energy (ET) is the main industry association representing Finlands energy sector. It represents companies involved in the production, transmission, distribution, and sale of electricity, gas, district heating and cooling, as well as related services. Finnish Energy promotes a clean, secure, and competitive energy system through policy advocacy, analysis, statistics, and guidance at national and EU level.

Finnish Energy (ET) welcomes the EUs decision to achieve 90% net emission reductions by 2040 compared to emissions level in 1990. Finlands own goal is to achieve carbon neutrality by 2035. Achieving this goal requires all zero and low carbon energy solutions, including renewables, nuclear, energy efficiency, storage, CCS, CCU, natural carbon removals, geothermal, hydro-energy, and other current and future net-zero…

Finnish Energy considers the Rating scheme for data centres in the EU, for the most part, comprehensive and well-designed. Finnish Energy recommends changes to the Annex III requirements regarding PPAs. The current proposal is unfeasible and risks investments and fragmentation of the current market.

We appreciate the opportunity to comment on the proposal for the Measuring Instruments Directive COM(2024) 561 final (hereinafter also referred to as the proposal) and state the following: Regarding electricity meters, we believe that the requirement in section 10.5 of Annex I of the MID to equip the electricity meter with an integrated display is not necessary in locations where smart metering is used.

In general, it is the responsibility of Member States to ensure that consumer rights are effectively realised in practice by transposing and implementing EU legislation. This includes energy related legislation, including the revised Electricity Market Directive, together with the consumer protection regime.

Finnish Energy thanks you for the opportunity to comment on the implementing regulation concerning switching electricity suppliers. Attached, we present our detailed feedback. We support the goal of seamless switching. We emphasize that this regulation shall purely focus on the data exchange and it shall not restrict contractual possibilities.

Measuring Instruments Directive ̶ evaluation 11.9.2025 9.10.2025 Statement We appreciate the opportunity to comment on the proposal for the Measuring Instruments Directive and state the following: Suitability of the Measuring Instruments Directive for all meters: The Measuring Instruments Directive (MID) regulates all meters, including advanced smart meters for measuring energy, weighing instruments, and exhaust gas…