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.

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.

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.

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.

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.

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.