GENERAL COMMENTS: • The effects of raising the contribution of the ETS towards a higher emissions reduction target will not be felt equally across the EU. Some MS will be more affected than others. • Required investment in Polish energy sector in the years 2021-2040 (according to the Polish government), are estimated at over PLN 560 bln (about EUR 125 bln). • PGNiG is concerned whether additional resources (2,5 p.p.
PS
PGNiG SA
Company · Poland · EU Transparency Register 70816716119-36not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 2 Sept 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
6
positions filed
in the 583 files tracked
5
legislative files
of 583 tracked
6
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
PGNiG SA filed 6 positions between 26 Nov 2020 and 21 Apr 2022, across 5 of the 583 legislative files tracked here, attaching a full position paper 6 times.
2020 · 1 filed2021 · 4 filed2022 · 1 filed
What they argued
GENERAL COMMENTS: • Extension of EU ETS should not be considered as most effective solution across all sectors. Individual approach in specific sectors should be applied in order to maximize environmental benefits. • As regards waste sector, one of the main identified sources of methane are uncontrolled emissions of landfill gas in landfill sites.
GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units.
PGNiG welcomes the possibility to comment on the proposal for a regulation amending Regulation 2019/631 as regards strengthening the CO2 emission performance standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate ambition (Cars Regulation).
General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions.
Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) welcomes the opportunity to comment on the proposal for a directive on the protection of the environment through criminal law (COM (2021) 851 final). PGNiG recommends extending the scope of Article 9 so that it includes additional circumstances that may be regarded as mitigating circumstances.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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