Vattenfall AB

Vattenfall appreciates the opportunity to respond to the public consultation informing the public procurement legislation review. In our opinion, the current EU public procurement framework has provided a robust basis for standardisation, competition, and responsible business conduct.

Vattenfall welcomes the opportunity to comment on the roadmap proposal for the Renewable Energy Directive (2018/2001) which will set the framework in which renewables will be deployed. Vattenfall is a European energy company with approx. 20,000 employees. For more than 100 years we have electrified industries, supplied energy to people's homes and modernized our way of living through innovation and cooperation.

Vattenfall is committed to net zero and see the EU taxonomy as one tool that can and should support this transition (in 2024 Vattenfall had 88% aligned Capex) All fossil free energy sources play vital a role in the transition together with distribution, storage and flexibility solutions. The taxonomy should be as technology neutral as possible.

It is time for stronger climate action and the opportunity is now • Vattenfall has the ambition of enabling fossil-free living within one generation. This has already led to significant changes in our portfolio. We are continuously moving out of CO2 heavy production assets, while investing largely in renewable energy and low carbon technologies.

Vattenfall welcomes the European Commissions legislative proposal on anEU-wide certification framework for carbon removals. A centralised and robust certificate framework governed by the European Commission, will increase regulatory clarity, confidence among investors and the public, and will have the best prospects of becoming a recognised and trusted instrument, thereby attracting more financing.

Vattenfall position on an EU framework for industrial carbon removals Last update: 2nd May 2022 ▪ Vattenfall fully supports the EU’s goals of becoming a climate-neutral economy by 2050 and achieving at least -55 % reductions of the EU’s net-GHG emissions by 2030. The ‘Fit-for-55’ package is a crucial initiative to align the EU’s 2030 policy framework with these goals.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Vattenfall welcomes the EU Commission’s ambition to increase the quality and validation of environmentally green claims. There is a strong need to streamline and concretize claims on environmental performance. We firmly believe this leads to better grounds for decision-making, both in terms of end-customer consumption and in terms of addressing environmental impact throughout the product lifecycle.

Vattenfall strongly supports the EU’s target of becoming a climate-neutral economy by 2050. To reach the Paris Agreement’s 1.5 °C goal, other regions must move in the same direction, though we recognise that it will be done in different pace and by different policies.

Vattenfall strongly welcomes the European Commission’s initiative to further improve and strengthen the EU ETS in line with the EU’s increased climate ambitions for 2030 and 2050. Most importantly, the new LRF (4.2 %) should take effect as early as possible to promote early action and investor certainty.

Vattenfall input to European Commission’s Inception Impact Assessment roadmap on the revision of the EU ETS directive. Vattenfall believes that the EU Emissions Trading System (EU ETS) needs to play a central role in achieving the EU’s ambitious climate objectives with regards to the sectors that it covers.

1. Downstream Scope Extension Should CBAM apply to more products? What would the impact be? While we recognize that the proposed extension may contribute to a more level playing field and support efforts to reduce CO emissions, it appears to be primarily targeted at steel and metals. In the context of offshore wind, the most significant impact would concern foundation structures.

Vattenfall fully supports the proposed EU 2040 climate target of -90 % net reduction of the GHG emissions by 2040 (vs. 1990 levels) as a necessary milestone along the EUs journey towards climate-neutrality by 2050.

Electrification and sector integration play an essential role in Europe’s ambition achieving climate neutrality by 2050. Vattenfall believes in a future where electrification is an efficient tool to realise the decarbonisation of, for instance, the transport and industrial processes to the greatest extent possible.

E-mobility will not take off without charging infrastructure. Vattenfall therefore welcomes the initiative of the European Commission to evaluate the Directive 2014/94/EU on the deployment of Alternative Fuels Infrastructure. Vattenfall is convinced that e-mobility will play a key role to help the EU economy to reach carbon neutrality by 2050, by progressively reducing GHG emissions.

Vattenfall is a European energy company. For more than 100 years, we have electrified industries, supplied energy to people's homes and modernized our way of living, through innovation and cooperation. Our goal is to make fossil-free living possible within one generation. Everything we do and the decisions we take shall lead to this goal.

Vattenfall welcomes the opportunity to comment on the draft proposal: 1) Vattenfall welcomes the overall direction of RfG 2.0 and its ambition to support a more resilient electricity system through a harmonised and future-oriented connection framework. 2) Our primary concern relates to the treatment of existing assets (Art. 4 par. 3 as well as Art. 45).

Vattenfall welcomes the opportunity to share our views on the European Commissions draft Delegated Act Green-listing certain waste for the purposes of shipments to recovery between Member States. Vattenfall is committed to transforming to a more circular business.

Vattenfall is a leading European energy company with 12 million customers and 21,000 employees. Were convinced theres a way to build a future where everyone can choose fossil free ways to move, make and live. In the context of the datacentre labelling framework under the Energy Efficiency Directive, we believe the focus should be on clear, comparable and practical disclosure, rather than on imposing strict technical…

The issue I find within e-invoicing today is when working with many companies in different countries are not the formats themselves but the medium in which they are sent. For example with it being allowed for an XML-file sent by e-mail in Germany which requires an additional way of extracting information than regular e-invoices (between VAN-operators).