Fortum

1 (2) Ref. Ares(2026)884935 - 26/01/2026 26 January 2026 FORTUM’S COMMENTS ON THE REVISION OF THE EU PUBLIC PROCUREMENT DIRECTIVES Background The European Commission will propose a revision of the EU rules on public procurement in Q2 2026.

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

1 (3) Ref. Ares(2026)5969276 - 11/06/2026 10.6.2026 FORTUM’S COMMENTS ON THE INDUSTRIAL ACCELERATOR ACT Background The EU’s Industrial Accelerator Act (IAA) is intended to be the flagship industrial pillar of the Clean Industrial Deal.

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

In line with the European Green Deal, and the urgent need for a stronger action against climate change, we strongly support the EU’s climate neutrality goal for 2050 and the recent Commission’s proposal to increase the EU 2030 greenhouse gas emission reduction target at least 55% from 1990 level.

We appreciate the opportunity to provide feedback on the Public Procurement Act, which is crucial to making the procurement process more accessible and efficient. The current system is overly bureaucratic and costly, particularly for SMEs. Complex tendering procedures and excessive documentation discourage participation, creating a market dominated by large corporations.

30th March 2022 FORTUM VIEWS ON THE PROPOSAL FOR THE REVISION OF THE ENERGY PERFORMANCE OF THE BUILDINGS DIRECTIVE (‘EPBD’ RECAST) 15/12/2021 1. PREFACE Fortum welcomes the recast proposal for the EPBD which targets to align the contribution from the buildings sector with the overall FF55 targets.

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

Fortum appreciates the work done by EFRAG and the Commission to simplify the European Sustainability Reporting Standards (ESRS). We support the aim to cut administrative burden for EU businesses while preserving the quality of sustainability disclosures. Fortum mainly supports the draft final versions, however, we still see a need for some clarifications and amendments. Please find our feedback attached.

Fortum would like to see a regulatory framework for AI based on the following principles: Accountability should be the key element when creating an AI regulatory framework instead of creating exhaustive lists of sectors and critical use with demands of prior conformity assessments and approval.

Please find attached Fortum's feedback to the consultation on the Environmental impact of waste management - revision of EU waste framework. The same information can also be found here: https://www.fortum.com/about-us/public-affairs/our-views-and-positions

Fortum welcomes the initiative to revise the waste directive with the aim to improve waste management to move further up in the waste hierarchy. Regarding incineration of residual waste, currently new techniques are developed and residues from incineration of waste that historically has been disposed of may be recovered for valuable minerals and metals, which in turn can be recycled into recycled raw materials.

Key messages of Fortum, one of the leading energy companies in Europe: - Fortum welcomes the EU initiative and the aim to create a level playing field for companies and avoid a fragmentation of due diligence obligations - Legal certainty for companies and reasonable administrative burden must be ensured - Clear definitions and obligations are needed - Regarding the obligations, a clear distinction between direct and…

Position paper attached. Summary below Introduction Every year, Europeans generate nearly 100 million tonnes of unrecycled waste that is turned into energy. Incineration is an important part of the current waste management system. We at Fortum believe that all carbon belongs in circulation. This means that also emissions are turned into new raw materials. To do this at scale, we need to rethink CO2 in recycling.

Risk for carbon leakage to be addressed in the context of higher climate ambition Fortum as a major European utility recognises the need to address the increasing carbon leakage risk for the European industries in the context of higher climate ambition and supports the Commission’s initiative to investigate measures in mitigating carbon leakage and establishing a carbon border adjustment (CBA) mechanism in the EU.

Monik Ref. Ares(2020)4931943 - 21/09/2020 1 (2) 21st September 2020 Public Affairs, Harri-Pekka Korhonen FORTUM VIEWS ON THE INCEPTION IMPACT ASSESSMENT OF EU’S ENERGY EFFICIENCY ROADMAP – REVISION OF ENERGY EFFICIENCY DIRECTIVE (EED 2012/2018) We support the EU Commission’s aim to reduce the greenhouse gas emissions by 55 % by 2030.

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

Fortum wants to highlight the following issues as the key in the upcoming revision of the Emissions Trading Directive and related Impact Assessment. More detailed feedback is available in the attached file. Allocation of the revised 2030 target between the ETS and non-ETS sectors Following the adoption of the new 2030 emissions reduction target, the Commission needs to prepare a holistic analysis on the most…

ENERGY TAXATION DIRECTIVE 2003/96/EC - INCEPTION IMPACT ASSESMENT Fortum welcomes the revision of the Energy Taxation Directive (ETD) 2003/96/EC and Commission’s roadmap for it. Revision of the Energy Taxation Directive is an integral part of the European Green Deal and should therefore focus on environmental issues according to the Inception Impact Assessment.

Fortum appreciates the work done by the Commission to streamline the taxonomy criteria. We strongly support the goal of the revision to make the framework simpler and easier to use. Fortum agrees with the conclusion that the EU Taxonomy Regulation is a cornerstone of the EUs sustainable finance framework, steering investments towards sustainable projects.

Fortum’s feedback on the Inception Impact Assessment for the EU nature restoration targets Fortum supports the EU Biodiversity Strategy and its aim to protect and restore species and habitats. Biodiversity loss and the degradation of ecosystems are a severe global concern that has to be tackled.

Fortum welcomes the European Commission´s proposal COM(2020) 798 for a regulation concerning batteries and waste batteries, which sets minimum sustainability requirements for batteries in the entire value chain. Having a strong battery value chain is of strategic value and importance for Europe as well as for our industry.

Fortums feedback on establishing a framework of measures for strengthening Europes net-zero technology products manufacturing ecosystem Fortum welcomes the objectives of the Commission proposal for strengthening Europes net-zero technology products manufacturing ecosystem, the Net Zero Industry Act (NZIA).

Fortum welcomes the European Commissions Electrification Action Plan as a milestone to make clean electricity Europes next growth engine. Our contribution outlines how clear demand signals, predictable prices and efficient grids can unlock investment and accelerate industrial decarbonisation.

As part of Fortum corporation, the Fortum recycling & waste business area support the objectives of the proposal for a revised Waste Shipment Regulation. Fortum submitted a reply to EC's Public Consultation on the WSR in June 2020 and is pleased to see that several of the company's policy objectives have been addressed in the EC's proposal.

H&C strategy should ensure, enable and accelerate the de-carbonization, energy security, energy efficiency and affordability in the heating and cooling and its potential to integrate with the low carbon electricity system. This will require to effectively and imperatively phase out the use of fossil fuels in buildings and industries.

Fortum supports a separate target for greenhouse gas emission reductions and carbon removals. The proposal for at least 55% emission reductions should be absolute and it should not include carbon sinks. Also the use of flexibilities from the LULUCF sink should be limited to the current level until there is a robust and trustworthy enough MRV system in place.

In todays complex geopolitical landscape, energy security has become a cornerstone of Europes resilience. Fortums contribution highlights how clean, reliable energy underpins economic stability, public safety, and national preparedness.

Fortum has submitted a response to the European Commission's public consultation on the draft Delegated Regulation establishing a Common Union Rating Scheme for Data Centres (Ares(2026)3247482). Our position covers key issues including the granularity of Guarantees of Origin, the 10-year asset age requirement, the role of firm low-carbon baseload such as nuclear, and the proportionality of the waste heat reuse ready…

Fortum welcome and appreciate the opportunity to give feedback on the REMIT II Implementing Regulation on Data Reporting. Generally, Fortum is concerned that the draft regulation increases the reporting burden without providing a corresponding surveillance benefit.

Fortum has submitted a response to the European Commission's public consultation on the review of the Radioactive Waste Directive (2011/70/Euratom) and the Shipments Directive (2006/117/Euratom). Drawing on nearly five decades of nuclear operations at the Loviisa Nuclear Power Plant, our position supports a targeted, evidence-based approach to any future amendments and highlights a specific definitional gap…