Ørsted A/S

Thank you for the opportunity to provide additional input to the Circular Economy Act. Ørsted supports the Commissions efforts to boost the circular economy as circularity can be a powerful tool towards decarbonization, environmental protection, competitiveness and supply chain resilience.

EU public procurement law plays an important role in fostering fair competition, ensuring transparency, and promoting efficiency in the use of public funds. By establishing a harmonized legal framework, it facilitates cross-border market access and enhances value in public sector contracting.

Ørsted's response to the Call for Evidence is based on an in-depth analysis of policy measures. The attached analysis portrays demand side measures that can complement supply side policies, enabling a competitive and resilient electrified European industry and economy. Please refer to the attached document for illustrations, analysis, data, and more information.

Ørsted is encouraged by the proposal for the revision of the Renewable Energy Directive 2018/2001, which was put forward by the European Commission on the 14th of July. While there is some room for small improvements, we want to underline that we believe the proposal is very well suited to help cost-effectively decarbonise the European energy system.

The Ørsted vision is to create a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions as well as providing smart energy products to our customers. We are also entering the market for renewable hydrogen production.

Thank you for the opportunity to respond to proposed changes to the Climate and Environment Delegated Act to the EU Taxonomy. Ørsted considers the Taxonomy a powerful tool for the EU, Member States and private investors to align their financing with core sustainability objectives.

On 6 May 2026, the EU Commission posted the draft delegated acts amending the reporting requirements in the ESRS after EFRAG's recommendations earlier this year. Ørsted would like to provide feedback to the proposed ESRS through the comments attached.

Ørsted warmly welcomes the EU Commission's initiative to develop a common EU certification scheme for projects that deliver carbon removals. The company views this as a significant step towards enhancing market credibility by establishing a common and ambitious regulation, which is crucial for carbon removals to become an integral part of the solution to climate change.

Ørsted welcomes the ongoing consultation and call for evidence on a Post-2030 Renewable Energy Framework as well as the continued commitment of the European Commission to renewables-based electrification of the EU economy.

Thank you for the opportunity to respond to proposed changes to the Climate and Environment Delegated Act to the EU Taxonomy. Ørsted considers the Taxonomy a powerful tool for the EU, Member States and private investors to align their financing with core sustainability objectives.

CSRD for large companies is complementary to the SFDR in that it provides (part of) the information for investment funds to report under SFDR. In this way, the SFDR can also help reduce the administrative burden for companies reporting under CSRD through standardization of information requests made to these companies by fund managers.

Ørsted welcomes the opportunity to provide feedback on the draft Implementing Regulation on the carbon price paid in third countries under CBAM. Ørsted welcomes the intent of article 6(2), to evaluate carbon prices at the same granularity, in this case yearly.

CERTAINTY IS NEEDED BEFORE 2026 ON HOW CARBON PRICES EFFECTIVELY PAID IN OTHER COUNTRIES BE CONSIDERED - PARTICULARLY FOR ELECTRICITY Orsted would like to thank for the opportunity to provide input to this important part of the CBAM regulation. It is very positive that CBAM will take into account carbon prices effectively paid in other countries, cf. article 9.3a in the proposed regulation 2025/0039.

Ørsted looks forward to cooperating with the European Commission towards a Marine Spatial Planning approach that ensures long-term strategic and internationally coordinated management of increasing usage of marine environments. MSPs should ensure a sufficient level of environmental protection while allowing for the necessary and efficient deployment of offshore renewable energies.

Ørsted appreciates the opportunity to provide feedback on the proposal of the revised TEN-E Regulation and welcomes that the Commission has presented a proposal that is further aligned with the EU climate targets.

The Ørsted vision is a world that runs entirely on green energy. Ørsted develops, constructs and operates offshore wind farms, associated infrastructure and innovative waste-to-energy solutions, and provides smart energy products to its customers; we are also entering the market for renewable hydrogen production. Headquartered in Denmark, Ørsted employs 5,600 people across its locations in Europe and overseas.

International credits should not be included in the EU ETS, instead focus should be in linking with similar cap and trade systems Certified international carbon credits were part of the ETS system from 2005 to 2020 but removed due to their negative impact on long-term decarbonisation and innovation, and with questionable efficacy as quality was hardly assessed in a robust way.

The two main goals of Ørsteds use of circularity in our (offshore) wind projects are to ensure availability of critical raw materials, and to help minimise the adverse environmental impacts that are related to extraction and processing of virgin resources. Today we estimate that 90-95% of all materials in our windfarms are recyclable.

Thank you for the opportunity to provide input to the draft Implementing Act concerning sustainability criteria for public procurement of clean technologies, specifically a blade recyclability requirement for wind. Ørsted welcomes the Commissions efforts to drive decarbonization and supply chain resilience in the sector.