RWE AG

RWE welcomes the opportunity to provide feedback on the draft amendments to the Climate Technical Screening Criteria (TSC). We support most of the proposals that aim to improve the usability of the Taxonomy. However, we believe that the draft delegated act could be improved further. Please see our detailed feedback attached, focusing on Annex I on Climate Change Mitigation.

RWE welcomes the opportunity to provide feedback on the Commissions call for evidence regarding the implementing act on carbon price paid in a third country, as foreseen under Article 9 of the CBAM Regulation. Clear rules on the recognition of third-country carbon pricing are critical to ensuring the effectiveness, fairness and credibility of the EU CBAM, and avoiding unnecessary administrative burden.

RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 7 of the CBAM Regulation. Clear rules on the calculation of embedded emissions are essential to safeguard competitiveness and maintain the credibility of CBAM.

RWE supports the development of a CO2 network to facilitate the integration and adoption of Carbon Capture and Storage (CCS) and Carbon Capture and Usage (CCU) in hard-to-abate/decarbonise sectors, and to enable BECC(U)S or DACC(U)S projects to generate carbon removals. Regulation should be targeted to support market and infrastructure development. Please find our detailed response attached.

RWE strongly supports the establishment of a robust EU framework allowing the limited use of highquality international carbon credits toward the EUs 2040 climate target. The 90% net-reduction target is ambitious and appropriate, yet residual emissions in hardtoabate sectors cannot be appropriately eliminated domestically by 2040.

Feedback of RWE An effective implementation of renewables acceleration areas for speeding up the EUs energy transition Summary: RWE generally welcomes the revised Directive (EU) 2023/2413 on the promotion of the use of energy from renewable sources (RED), which has the potential to significantly contribute to the achievement of the EU renewable energy targets.

RWE welcomes the opportunity to provide comments on the Commissions call for evidence regarding the implementing act on the adjustment of CBAM obligations to account for free EU ETS allowances, as foreseen under Article 31 of the CBAM Regulation. Clear rules on the free allocation adjustment are essential to safeguard competitiveness and maintain the credibility of CBAM.

RWE welcomes the opportunity to provide feedback on the initiative to update the existing network code and prepare the EU power grid for the future by reflecting key developments such as the increasing deployment of renewable energy and battery storage. Our detailed comments and recommendations can be found in the attached document.

RWE welcomes the European Commissions initiative to revise national targets and flexibilities within the EU climate policy framework beyond 2030. EU-wide, market-based approaches remain the most efficient way to achieve emissions reductions and maintain a level playing field across Member States.

We welcome the European Commissions Market Integration and Supervision Package proposal and support efforts to increase legal certainty, harmonisation, and efficient supervision in the EU. In our comprehensive response which we attached as pdf, we highlight key areas for improvement and suggest targeted simplifications to reduce regulatory burdens and foster better market integration.

We welcome the opportunity to provide feedback on the proposed changes. We recognise the need to update the current REMIT legislation, including the Delegated Act and the Implementing Regulation, as well as their respective annexes. We appreciate the effort put in from the European Commission and ACER to dialogue with market participants.