UPEI - The Voice of Europe's Independent Energy and Mobility Suppliers

UPEI and its members, representing nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, look forward to constructively working with the EU institutions to make Europe’s renewable energy policy a success. UPEI calls upon the European Commission to give careful consideration to the following issues in the process leading to the review of REDII: 1.

UPEI supports measures to help decarbonise the heating sector, including the EPBD which contributes to higher-performance and comfortable buildings and reduced energy bills for citizens, as well as facilitates the acceptance of the energy transition.

Climate Law recommendations UPEI is fully committed to contributing to achieving carbon neutrality through the supply of carbon-neutral fuels by 2050. This monumental ambition will have to be sustained by the regulatory consistency that businesses need to successfully deliver the transition to sustainable supply chains, mobilising funding for solutions that reflect changing market realities.

UPEI, the voice of Europe’s Independent Fuel Suppliers, welcome the opportunity the provide initial feedback to the roadmap on the Energy Efficiency Directive (EED). In this context, we would like to draw your attention to the following issues: 1. We agree that energy efficiency is the number one priority in the transition towards climate neutrality.

In general, UPEI supports the EU ETS as a market-based and cost-effective tool to reduce GHG emissions, in light with the EU carbon neutrality objective. We see the ETS and ESR as complementary measures to address climate change. In principle, the ETS applies to the organisations directly responsible for the actual CO2 emissions.

UPEI recognises the need for an Energy Taxation Directive and welcomes the European Commission’s intention to update it. This is needed to ensure that the ETD remains relevant by taking account of technological developments in the energy sector, resulting in the emergence of new products which currently do not fall within the scope of the directive, and address current issues related to the functioning of the…

UPEI, the voice of Europes independent energy and mobility suppliers, has carefully read the call for evidence, published on 19 March 2026, inviting for an input on setting a renewable Energy Framework for the decade ahead. We will focus our input on the review and possible revision of RED III (EU) (Directive 2023/2413), as we see it as the main pillar of the EU policy on renewables (see document enclkosed).

UPEI, the voice of European independent energy and mobility suppliers, welcomes the opportunity to provide its comments to the proposed amendment to the European Climate law. We support the setting of an intermediary target between those set for 2030 and 2050, as it helps create a unified legal framework for Member States and economic stakeholders.

In a context of peaking energy prices, it is crucial to follow the path of the energy transition while mitigating adverse effects on consumers and businesses alike. UPEI members are committed to the EU climate objectives and have developed their own 2050 vision which outlines short and long-term recommendations for a carbon neutral society and highlights their own contribution.

UPEI, the voice of Europe’s Independent Fuel Suppliers, welcomes the opportunity the provide initial feedback to the roadmap on the Regulation setting CO2 emission standards for cars and vans. More should be done to unlock investments and trigger behavioural changes in order to achieve CO2 emission reduction in road transport, in line with Europe’s 2030 and 2050 climate targets.

UPEI, the voice of independent energy and mobility suppliers, considers that, to attempt to overcome the surge in housing costs, it is necessary to keep an open mind to all technologies that can both contribute to affordability and decarbonisation of household energy systems.

UPEI, the Voice of Europes independent energy and mobility suppliers, focuses its contribution on: - flexibility, simplification and reduction of administrative burden: we recommend the EU to systematically improve consistency of all relevant legislation, in particular definitions and methodologies) and to keep a scientifically based approach.

UPEI, the voice of Europes independent energy and mobility suppliers, has carefully read the call for evidence, published on 19 March 2026, inviting for an input on setting an Energy Efficiency Framework for the decade ahead. We will focus our input on the review and possible revision of EED - (Directive 2023/1791), as we see it as the main pillar of the EU policy on energy efficiency (see document attached).

UPEI, the Voice of Europe's Independent Energy and Mobility Suppliers, considers that the revision of the Energy Union Governance Regulation should: Require Member States to demonstrate alignment between renewable targets, infrastructure readiness, and applicable market rules. Improve forward-looking regulatory visibility within NECPs to support long-term investment planning.

Over the last years, the EU faced unprecedented situations that revealed the fragility of its current energy supplies systems. Recent crises have shown that there is an impending need to re-assess the EU framework for energy supplies in order to regain our capacity to prepare against, and respond to, potential future crises.

UPEI – Europe’s Independent Fuel Suppliers, welcomes the opportunity to provide initial comments to the Roadmap, and to be part of the preparatory process for the FuelEU Maritime initiative. UPEI embraces the European Green Deal and ambition to reach climate neutrality by 2050 and therefore supports measures that bring down fuel consumption as well as boosting the deployment of all low- and zero-carbon marine fuels…

Military mobility implies that the fuel distribution system remains permanently available. The decentralised nature of fuel supply (from the storage to the final consumer) provides some guarantees, but the following risks should be addressed: Natural disasters such as floods, major fires, or earthquakes Major electricity blackouts (depots or service stations also run on electricity), Cyber-attacks: in this context…

UPEI calls on the EU institutions to review policies having regard to the reality of markets: while the need to transition to low-carbon fuels is fully recognised, there are “around 95% of road vehicles still conventionally fuelled, including renewable biofuels blends” .