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E.ON SE

E.ON is an international, privately owned energy company based in Germany, focusing on energy networks and infrastructure.

Lobbying Activity

Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Dec 2025 · Climate policy

Meeting with Dan Nica (Member of the European Parliament)

10 Dec 2025 · "Trust or Bust: Will Net-Zero Industries Thrive in Europe?" - debate

Meeting with Jens Geier (Member of the European Parliament)

10 Dec 2025 · Discussion on EV Charging and flexible Energy Price solutions

Meeting with Bruno Tobback (Member of the European Parliament)

9 Dec 2025 · The Espresso Connection: A Morning Policy Shot on the EU Grids Package

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

26 Nov 2025 · EU electrification, grids and flexibility

Meeting with Nicolás González Casares (Member of the European Parliament)

25 Nov 2025 · Grids and electrification

Meeting with Sigrid Friis (Member of the European Parliament)

25 Nov 2025 · Electrification

Meeting with Anna Stürgkh (Member of the European Parliament)

6 Nov 2025 · General Exchange

E.ON urges practicable AI rules and reduced bureaucracy for energy sector

5 Nov 2025
Topic — EU Strategic Roadmap on digitalisation and artificial intelligence in energy.
Message — E.ON requests a workable AI legislative framework balancing safety with innovation, opposes additional sector-specific regulations, and seeks practical guidance on high-risk AI systems. They call for clear definitions of safety components with material threshold levels and regulatory incentives for smart grid deployment.123
Why — This would reduce compliance burdens and allow faster deployment of AI-powered grid technologies.45
Impact — Consumer safety protections may be weakened through broader AI exemptions and reduced oversight requirements.6
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Meeting with Angelika Niebler (Member of the European Parliament)

4 Nov 2025 · Grids Package

E.ON urges streamlined digital rules to advance energy transition

14 Oct 2025
Topic — EU package simplifying digital regulations covering data access, AI, and cybersecurity.
Message — E.ON requests clarification of AI Act safety components and high-risk definitions, better coherence between Data Act and sector-specific energy rules, and practical GDPR guidance for grid operations. They want material thresholds for AI disruptions and protection of data holders' intellectual property.1234
Why — This would reduce compliance costs and enable faster grid digitalization investments.567
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Meeting with Andrea Wechsler (Member of the European Parliament)

10 Oct 2025 · Energy Policy

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

26 Sept 2025 · Energy policy

Meeting with Paula Rey Garcia (Head of Unit Energy) and Climate Action Network Europe and

18 Sept 2025 · Electrification, tripartites contracts, storage and flexibility, and grids

Meeting with Christian Ehler (Member of the European Parliament) and Edison Spa and WIENER STADTWERKE GmbH

17 Sept 2025 · Energy policy

E.ON Warns New Energy Data Rules Threaten Security of Supply

12 Sept 2025
Topic — A revision of EU rules for reporting wholesale energy market data to regulators.
Message — E.ON requests removing burdensome forecasts and algorithmic trading IDs. They advocate for a minimum 18-month implementation period.12
Why — This would reduce administrative complexity and prevent unfeasible operational burdens on energy companies.3
Impact — EU consumers may face higher energy costs and risks to their security of supply.4
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Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur)

2 Sept 2025 · INI Report on grids

Meeting with Bruno Tobback (Member of the European Parliament) and Eurelectric aisbl

10 Jun 2025 · European Energy Policy Priorities

Meeting with Dan Nica (Member of the European Parliament) and Eurelectric aisbl

11 May 2025 · Conference "Grids of the Future - Romani's role in Europe Energy Security and Competitiveness"

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

8 May 2025 · Electrification

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

8 May 2025 · to follow

Meeting with Dan Nica (Member of the European Parliament) and BUSINESSEUROPE and

25 Mar 2025 · Debate on The role of CEE countries and Romania in strengthening the competitiveness of the European Union

Meeting with Markus Ferber (Member of the European Parliament)

19 Mar 2025 · Energy policies

Meeting with Christian Ehler (Member of the European Parliament)

19 Mar 2025 · EU Energiepolitik

Meeting with Peter Liese (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

19 Mar 2025 · Austausch

Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur)

5 Mar 2025 · The contribution of electricity grids to the affordability of electricity and the competitiveness of the EU

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur)

5 Mar 2025 · "The Energy Playbook: an affordable strategy to net zero"-event

Meeting with Wopke Hoekstra (Commissioner) and

4 Mar 2025 · Discussion on the Clean Industrial Deal and the Affordable Energy Action Plan. The importance of electrification

Meeting with Lukasz Kolinski (Director Energy)

6 Feb 2025 · Exchange on challenges of distribution grid in the energy transition

Meeting with Sigrid Friis (Member of the European Parliament)

6 Feb 2025 · Energy policy

Meeting with Elisa Roller (Director Secretariat-General)

5 Feb 2025 · Electricity grids

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur) and EU DSO Entity

4 Feb 2025 · INI Report on grids

Meeting with Maroš Šefčovič (Commissioner) and

30 Jan 2025 · Economic and Energy Security

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Transport and Environment (European Federation for Transport and Environment) and

14 Jan 2025 · Greening corporate fleets

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

E.ON calls for flexible rules for low-carbon hydrogen ramp-up

25 Oct 2024
Topic — The EU is establishing a methodology for calculating greenhouse gas savings for low-carbon fuels.
Message — E.ON requests more flexibility and grandfathering clauses to provide security for early investments. They propose immediate hourly electricity emission calculations and reject the 40% methane emission premium.123
Why — These adjustments would help E.ON avoid high project costs and benefit from national grid decarbonization.45
Impact — Environmental groups may see these flexibilities as a way to bypass more rigorous climate standards.6
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Response to Update of minimum requirements for certification programmes for switchgear

15 Oct 2024

E.ON appreciates the opportunity to provide feedback on the European Commissions consultation on the envisaged update of the F-Gas Implementing Regulation on minimum requirements for electrical switchgear. The new F-Gas Regulation, which entered into force in March 2024, establishes new requirements for the certification of persons carrying out activities on electrical switchgear containing F-gases. Hence, it is necessary to repeal and replace the current Implementing Regulation to update the according minimum certification requirements relating to electrical switchgear. In general, E.ON welcomes that standardised requirements for the training of personnel for handling F-gases continue to be formulated throughout Europe. However, we see a need to revise the draft text of the amended Implementing Regulation concerning the practical aspect of envisaged refresher training courses. The (initial) certification of persons, who carry out work on electrical switchgear with F-gases, has rightly included a theoretical and a practical examination. This ensures that both the necessary theoretical knowledge and practical skills are available. Beyond that, the obligation to carry out refresher training courses after seven years has been added to the F-Gas Regulation, which is generally welcomed in view of the importance of avoiding emissions and continuously raising staff awareness. However, concerning these refresher training courses provided for in Article 7(1) of the draft of the amended Implementing Regulation, we believe that it is sufficient to teach only the theoretical knowledge again in suitable seminars (possibly supplemented by information on F-gases or gas mixtures newly included in the application). E.ON proposes waiving the requirement for a new practical refresher training course, as the actual activities in handling F-gases do not change. This also applies when changing to a different F-gas. Accordingly, this should be reflected in Article 7 of the amended Implementing Regulation concerning Existing certificates, refresher training courses or evaluation processes not least to avoid further substantial cost caused by such practical refresher training. In addition, we see not insignificant constraints regarding the availability of resources needed for practical refresher training, including qualified trainers.
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Meeting with András Gyürk (Member of the European Parliament)

1 Oct 2024 · Development of electricity grids

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

1 Oct 2024 · EU Energy and Industry Policy

Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and

13 Sept 2024 · Energiepolitik - allgemein

Meeting with Jens Geier (Member of the European Parliament)

20 Aug 2024 · Exchange on Low Carbon Hydrogen

Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

E.ON appreciates the opportunity to provide feedback to the European Commission regarding its assessment of the state of public funding and the capacity of EU countries to increase the uptake of private investment in energy efficiency. Energy efficiency measures yield significant potential with regard to both financial saving for a customer and CO2 reductions in the context of climate goals. Key messages: 1. The need for tailored EU & national funding for energy infrastructure, such as district heating, which delivers efficient and clean energy, is greater than ever. 2. At the same time, effective funding opportunities are not existent in the most relevant EU markets apart from Germany (BEW). 3. Best-practice funding mechanisms like the BEW should be transferred onto EU level. 4. Funding should especially be focused on closing the financial gap of (privately financed) heating grid transformation and expansion projects. 5. Public funding is necessary to boost private investment volumes and realize more efficiency projects in all sectors. The EU and the member states could boost this even more by creating a framework for fund-supported financing of efficiency projects - privately organized energy efficiency investment funds. In order to achieve better energy efficiency and carbon neutrality in the building sector, the transformation of heating networks is very important. This is difficult, in those markets where the required temperature levels in the grids are high (>100 °C) and the CO2 footprint is substantial. In most markets with high-temperature district heating systems (DHS), local and national financial support is very limited. This makes many transformation projects financially unviable and heating tariffs socially unacceptable. This is especially true in Poland and other Central and Eastern European countries. Technical solutions focus on lowering the supply temperature of the district heating network allowing efficient integration with renewable heating technologies. This requires huge investments in networks, which threatens the affordability of DHS. A well-functioning funding scheme is the German BEW ("Federal funding for efficient heating networks") which supports the retrofit and construction of heating networks on a systemic level. It is in line with the EED goals and successfully promotes energy efficiency and renewables in heating networks. It is a very reliable program and can be considered in the early stages of projects feasibility assessment. Next to grants for CAPEX, it additionally provides subsidies for higher OPEX. We recommend transferring this best-practice funding mechanisms onto the EU level making a comparable mechanism accessible in every EU member state. Funding should especially be focused on closing the financial gap of heating grid transformation projects. Ideally, a well-functioning funding system at the EU level should be predictable and reliable over the course of several years in advance. A general approach to activate more private capital for efficiency projects is to create an environment in which money is made available for efficiency projects via privately organized investment funds. Using the fund approach, portfolios can be built that combine projects with different durations of new or existing projects, technologies, industries, etc. and can also contain hedging instruments. Direct participation in project companies or the granting of external capital is conceivable. In the first case, the investments would be refinanced largely through the saved energy or CO2 costs. In this way - similar to existing (open or closed) real estate funds today - stable returns can be achieved with acceptable risk. These funds could then also be interesting for investments by insurance companies or pension companies. State development banks could support the establishment of such funds, and guarantees could also enable the use of capital from third parties.
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Meeting with Jakop G. Dalunde (Member of the European Parliament)

14 Feb 2024 · PCI and energy transition

E.ON seeks GDPR reforms to facilitate energy grid innovation

8 Feb 2024
Topic — The Commission is reporting on the application of the General Data Protection Regulation.
Message — E.ON proposes allowing pseudonymised data processing for product development and issuing binding recommendations. They advocate for extending breach notification deadlines to five working days. They also request adopting risk-based assessments for data transfers.1234
Why — This would reduce operational costs and eliminate legal barriers to smart grid development.56
Impact — Consumers may suffer from delayed transparency regarding data security incidents and reduced privacy oversight.7
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Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

12 Jan 2024 · Exchange on industrial and energy policy

Response to Network Code on Cybersecurity

17 Nov 2023

E.ON appreciates the opportunity to provide additional input on the development of sector-specific rules on cybersecurity. In general, E.ON supports the plans of the European Commission to make the EUs electricity system more resilient & secure and to address the cybersecurity aspects of cross-border electricity flows. The continuous and active exchange between the European Commission and the electricity sector during the development phase of the Network Code on Cybersecurity (NCCS) is highly welcomed by E.ON. However, the latest draft of the NCCS still has some potential for further improvement, which is highlighted in the following: The NCCS in its latest draft version is partially redundant with current European legislation and its ongoing national implementation, which will have a timelier effect on cybersecurity in the electricity sector. There is also a high risk of a partial double regulation and (as a result) bureaucratic overburdening. 1. NIS2: The national implementations of the Directive on measures for a high common level of cybersecurity across the Union (NIS2) will lead to a harmonization of security levels in the energy sector in a relatively shorter timeframe and with a clearer scope than the NCCS. Even where some national implementations might fall short in comparison to the average requirements of EU Member States, the NCCS will most likely not lead to substantial improvement nor harmonization of security levels, due to partially inconsistent requirements and provisions as well as its late implementation. 2. CRA: Regarding the security of supply chains, the Cyber Resilience Act (CRA) (with its much broader scope) will make the NCCS partially obsolete without the need for national implementation. Based on the current state of the advanced legislative process, the CRA will already be applicable earlier than NCCS, imposing requirements on the security of components and supply chains including the electricity sector. Solely defined parties shall be in scope of the NCCS (e.g. operators responsible for operating interconnectors): Despite the above-mentioned redundancy, there exists the chance for positive impact on cybersecurity of the European grid by a timely and targeted implementation of this sector-specific network code. In its current version, the scope of the NCCS is too broad and rather undefined to meet its specific objective to increase cybersecurity in cross-border electricity flows. If up to four years are needed to identify the affected entities, Europe will miss the chance to implement adequate cybersecurity for its energy transition. E.ON therefore proposes that e.g. operators of interconnectors or other suitable entities already implement and test the NCCS provisions in a first step. The gained experience could subsequently lead to an advisable differentiation of the NCCS from NIS2 and CRA. Besides the NCCS process to identify affected entities, if gained experiences from the first step will show that other entities should also be subject to the NCCS requirements, they can be included in the group of effected parties subsequently. Acceptance of existing national incidents reporting systems and established cybersecurity frameworks, which are based on international standards: Some Member States already have suitable incident reporting systems in place. These systems should be permitted and fostered in order to be used without far-reaching adaptation. With its implementation, the incident reporting according to NIS2 should be recognized, and no new or parallel incident reporting channels should be introduced. In addition, existing cybersecurity frameworks based on relevant and well-established international standards should be accepted without restriction. Conversely, this also means that the NCCS should not specify requirements that deviate from international standards.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

9 Nov 2023 · GDPR

Response to Payment services – revision of EU rules (new Regulation)

6 Oct 2023

E.ON appreciates the opportunity to provide feedback on the proposal for a revision of the Payment Services Regulation. E.ON supports the plans of the European Commission to increase the efficiency, transparency and choice of payment instruments for payment services as well as to ensure a high-level protection for payment service users. The PSD2 has managed to achieve an important increase in security for users through the Strong Customer Authentication (SCA). In line with this, E.ON welcomes that exceptions can be made for the SCA. Therefore, E.ON strongly welcomes the criteria set out in Article 85 (11) of the Payment Services Regulation, which take into account: 1. the level of risk involved in the service provided; 2. the amount, the recurrence of the transaction, or both; and 3. the payment channel used for the execution of the transaction. In this context, E.ON recommends that exemptions for cases of particular importance shall be included in the Regulation itself and not only be regulated by the European Banking Authority (EBA) through draft regulatory technical standards. On the one hand, these can be exemptions that are already excluded from the SCA, such as transport fares and parking fees. On the other hand, exceptions should also be laid down in the Regulation that have an influence on the European Green Deal and are important for the implementation of Fit-for-55 legislation. Ad-hoc payment at public charging points should be one of these exceptions. Waiving the SCA requirements - i.e. the mandatory equipment of publicly accessible recharging points with PIN entry devices- will ensure that the ramp-up of the recharging infrastructure in Europe, which is important for reducing emissions in the transport sector, is not slowed down. Electromobility will become cheaper and more user-friendly. In addition, the Payment Services Regulation will be brought in line with the Alternative Fuels Infrastructure Regulation (Article 5 1. (b)). Payment at publicly accessible recharging points also complies with the requirements of Article 85 (11) of the Payment Services Regulation: a) The level of risk involved in the service provided: The risk of fraud or misuse in an electronic payment transaction at a publicly accessible recharging point for electric vehicles can be considered relatively low, as these points are typically well-monitored. Furthermore, charging an electric car is not a process that lends itself to systematic credit card fraud. A car can only be charged once and would have to be driven several hundred kilometres before the car would have to be charged again for a relatively small amount (see below). b) The amount and/or frequency of the transaction: The costs associated with charging an electric vehicle depend on various factors but are generally not excessively high. In most cases, the amount involved in charging an electric car is less than 25 euros. The limit of 50 euros is almost never reached in public ad-hoc charging. Additionally, public charging operations are usually not very frequent (e.g. once a week or once a month), further reducing the overall risk. c) The payment channel used for the execution of the payment transaction: Publicly accessible recharging points for electric vehicles are typically equipped with technologies like Radio Frequency Identification (RFID) or Near Field Communication (NFC). These technologies are known for providing high levels of security and enable quick and efficient transaction processing. In addition, ad-hoc charging accounts for only the smallest fraction of all charging processes. Only 20% of all charging is done at public charging points. In 2022, public charging was mostly done on the basis of an existing contract and only 5 to 10% of public charging was paid for ad hoc using a payment card. An exception in the SCA would therefore only affect the smallest share of payment transactions and still guarantee security and customer friendliness.
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Meeting with Kadri Simson (Commissioner) and

6 Sept 2023 · High level dinner before the ENSTO-E grids event – discussion on the challenges for European networks and electrification.

E.ON backs EU push to double hydrogen valleys by 2025

25 Aug 2023
Topic — EU roadmap to accelerate hydrogen valley development under REPowerEU objectives.
Message — E.ON requests regulatory clarity through finalization of current legislation, simplified and fast-tracked permitting procedures, and clear legal regulations for core hydrogen networks. They emphasize the need to avoid adding new complexity like stricter unbundling rules for hydrogen network operators.123
Why — This would enable quicker and more cost-effective development of their hydrogen infrastructure investments.4
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

4 Jul 2023 · Meeting with E.ON on NZIA

Meeting with Katarina Barley (Member of the European Parliament)

4 Jul 2023 · Fit for 55, European industrial competitiveness

E.ON backs 80-90% emissions cut by 2040 if investment conditions met

23 Jun 2023
Topic — EU Commission consultation on setting 2040 climate target towards 2050 climate neutrality.
Message — E.ON supports an 80-90% net emissions reduction target for 2040. They emphasize this requires meeting enabling conditions and focusing on implementation now. Priority areas include accelerating investments in renewable generation and developing digitalized distribution networks to integrate renewables.123
Why — This pathway would minimize compliance costs by avoiding steeper abatement requirements after 2040.4
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Meeting with Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

22 Jun 2023 · Skills and Labour shortage

E.ON urges grid upgrades and lower power prices for heat pumps

26 May 2023
Topic — The Commission is developing an action plan to accelerate heat pump deployment across Europe.
Message — E.ON calls for removing taxes on electricity to make heat pumps competitive against gas-based solutions. They also propose that grid operators should be allowed to steer or dim heat pump loads during times of grid constraints.12
Why — Guaranteed returns on grid investments would secure E.ON's revenue while expanding its network infrastructure.3
Impact — Consumers may face higher network tariffs if capacity-based elements are added to their bills.4
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur) and Naturschutzbund Deutschland e.V. and Deutscher Naturschutzring, Dachverband der deutschen Natur-, Tier- und Umweltschutzverbände (DNR) e.V.

27 Apr 2023 · Exchange on the gas market directive (staff level)

Meeting with Jens Geier (Member of the European Parliament)

18 Apr 2023 · Exchange on the hydrogen bank (staff level)

Meeting with Nicolás González Casares (Member of the European Parliament, Rapporteur) and European Network of Transmission System Operators for Electricity and PGE Polska Grupa Energetyczna SA

18 Apr 2023 · Electricity Market Design

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur) and GasNet, s.r.o.

5 Apr 2023 · Methane regulation,

E.ON Urges Swift EU Carbon Removal Certification for Investors

22 Mar 2023
Topic — The Commission proposes a framework to certify carbon removals from ecosystems and industrial solutions.
Message — E.ON requests the framework becomes operational by 2025 to provide investors with foresight. They advocate for market quotas and distinct certificate sub-categories to reward permanent carbon storage solutions.12
Why — A clear certification timeline and market quotas would de-risk E.ON's large-scale industrial investments.3
Impact — Rural industrial areas could face migration if emissions from long transport routes are penalised.4
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Meeting with Christian Ehler (Member of the European Parliament)

21 Mar 2023 · Strommarktdesign

Meeting with Kadri Simson (Commissioner) and

9 Feb 2023 · Electricity market design.

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Response to Requirements for access to electricity metering and consumption data

5 Sept 2022

E.ON appreciates the opportunity to provide feedback on the draft Implementing Regulation on interoperability requirements and non-discriminatory and transparent procedures for access to metering and consumption data. E.ON would favourably consider the possibility for the EU DSO Entity to support the European Commission in monitoring the implementation and further development of the reference models. The scope of this reference model should exclude industrial customers. Retail markets’ final customers include household customers, small and medium enterprises, but also large industrial customers. This reference model is modelled for household customers and small and medium enterprises. The handling of metering and consumption data and customers protection frameworks for large industrial customers are quite different in many Member States. Smart meters are related to distributed energy sources, i.e. connected to the distribution networks. The collection of national practices (Article 11) is to be done most efficiently by DSOs. In order to be consistent with horizontal EU data legislation (GDPR, proposal on the Data Act etc.), the terminology consent instead of permission should be kept. This draft Implementing Regulation is expected to enter into force 20 days after publication in OJEU. Member States should be given the possibility to have time to consistently acknowledge the reference model. Therefore, in our opinion, it is necessary to include an implementation term in this draft Implementing Regulation. E.ON propose an implementation period of 6 months. In the context of this legal act, reference models do not set forth a general standard which the Member States environments shall adapt to. As set in previous versions of part 1, reference models intend to be used for mapping national practices and understanding significant similarities and differences as well as relationships between divergent Member State environments. This purpose should be reflected adequately in the last version of part 1.
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Meeting with Pär Holmgren (Member of the European Parliament)

26 Aug 2022 · Study visit Händelö Eco Park

E.ON Urges Delay to EU Greenhouse Gas Equipment Ban

29 Jun 2022
Topic — The EU is reviewing rules for fluorinated greenhouse gases to align with the European Green Deal.
Message — E.ON recommends extending all deadlines for bans and ensuring at least two manufacturers provide proven alternative solutions. They request exemptions for spare parts to avoid replacing entire substations instead of single components. Additionally, they suggest a higher global warming potential threshold to include promising alternative technologies.123
Why — This would reduce compliance costs and prevent the premature disposal of expensive power grid equipment.4
Impact — Environmental groups lose as high-emission gases remain in the power grid for several additional years.5
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E.ON Urges More Flexible Greenhouse Gas Calculation Rules

17 Jun 2022
Topic — EU consultation on measuring greenhouse gas savings for renewable and recycled fuels.
Message — E.ON requests clearer rules for calculating emissions from hydrogen transport and distribution. They want credits for capturing industrial carbon emissions extended until 2045. The company also suggests lowering default emission values for grid-sourced electricity.123
Why — This would protect the financial viability of long-term, capital-intensive investments in hydrogen.45
Impact — Environmental goals are weakened as prolonging fossil-based carbon use delays full decarbonization.6
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E.ON demands stronger protections for data holders in Data Act

13 May 2022
Topic — EU consultation on rules for fair access to and use of digital data.
Message — E.ON requests clarification on how the Data Act interacts with energy laws. They seek narrower definitions for public data requests and stronger trade secret protections. The company wants better recognition of the data holder’s commercial investments and rights.123
Why — This would safeguard E.ON's commercial secrets and maintain incentives for data-driven innovations.4
Impact — Public sector bodies and competitors would lose easy access to valuable energy-related datasets.56
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E.ON urges swift EU carbon removal certification framework

2 May 2022
Topic — The EU is proposing a regulatory framework to certify sustainable carbon removals.
Message — E.ON calls for a swift establishment of a framework for the certification of carbon removals. It requires a clear delimitation from carbon market allowances to avoid double counting. The company believes open access to transport and storage infrastructure is important.123
Why — Valuable carbon removals will incentivize E.ON to invest in the needed infrastructure.4
Impact — Providers of fossil fuel carbon capture face a diminishing market in the long term.5
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

29 Apr 2022 · Green Deal, hydrogen, taxonomy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

21 Apr 2022 · Discuss Hydrogen energy in general and present their position

Response to Revision of EU rules on Gas

12 Apr 2022

Overall, E.ON supports the Commission proposal to revise the current gas markets rules and establish a framework that aims to boost the hydrogen and decarbonized gas markets. We are fully committed to support the energy transition which is at the heart of Europe’s climate ambitions. By integrating hydrogen into the regulatory framework and applying many rules and principles set out for gas to hydrogen, the Commission has taken an important step in the right direction. However, there is also a variety of provisions that seem to hinder more than to spur the transition. In order to enable the transition away from natural gas, the current proposal needs to be adjusted, particularly with regards the following points: 1. Tariff discounts for renewable and low carbon gases: The Commission proposes to grant discounts of 75% on entry tariffs for renewable and low carbon gases. It is positive that the NRA can set lower discounts in line with the cost-reflectiveness principle. Considering this, we propose that even more flexibility should be provided by setting discounts ranging from 100% to 0%. Ultimately, E.ON would look at the reduction of network tariffs for injection of renewable gases to the grid as the first step to facilitate the uptake of renewable and low-carbon gases. Market mechanisms or other support schemes (e.g. subsidies) than network charges shall be considered. 2. Separation of regulated asset bases: In the long run, cost-reflectiveness and “beneficiary-pays” principles to avoid cross-subsidies among energy carriers should be applied to ensure correct price signals. We acknowledge yet that the proposed temporary financial transfers of dedicated charges mechanism might mitigate high initial unit costs in the early stage of the hydrogen market development and thus would be welcomed by E.ON. 3. Transfer of assets and residual value: In the event of a transfer of assets to another regulated fixed asset (e.g. from natural gas to hydrogen), the proposal sets out that their value must be determined and approved by the regulatory authority. ACER would then make recommendations on this value and the allocation of any resulting gains and losses every two years. From our point of view, this would create significant uncertainty about the future value of assets that could be approved until the ACER recommendations are submitted and implemented. The frequent revisions of these recommendations further exacerbate these uncertainties which would have a negative impact on investments in the existing infrastructures. It is critical to stress that the legal framework should ensure that the assets to be transferred have a positive residual value. This is needed to ensure financial viability of hydrogen networks operators and to incentivize the use of existing assets, reducing thus the risk of stranded assets and accelerating the development of the hydrogen market. 4. We think that, whilst ensuring enhanced coordination and information sharing among networks operators regarding the network development plan, national planning exercise should be separate for different energy carriers as well as differentiated at transmission and distribution level, in order to actually reflect the greater complexity of energy system. A combination of natural gas and hydrogen networks development plans would be a feasible option.
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E.ON urges flexible hydrogen unbundling rules to boost transition

12 Apr 2022
Topic — Revision of EU gas rules to facilitate market entry for hydrogen.
Message — E.ON calls for flexible unbundling rules allowing distribution operators to manage both hydrogen and gas networks. They argue for repurposing existing infrastructure rather than establishing duplicate corporate structures. Additionally, they request clear definitions for low-carbon gases that include carbon capture technologies.123
Why — Flexible rules prevent costly organizational restructuring and allow E.ON to leverage existing infrastructure.45
Impact — Low-carbon gas producers may face connection refusals if projects are deemed economically unreasonable.67
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E.ON urges mandatory rooftop solar for all new buildings

12 Apr 2022
Topic — The EU strategy aims to accelerate solar energy deployment across Europe.
Message — E.ON proposes a mandatory solar panel requirement for all new commercial and private buildings. They also suggest incentives for digital grid equipment and automated electricity trading bonuses.123
Why — These measures would increase revenue from E.ON's digital assets and energy infrastructure.4
Impact — Building owners and developers would face higher mandatory costs for solar installations.5
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and Volkswagen Aktiengesellschaft and

7 Apr 2022 · Meeting with CEO Alliance on Digitising Energy Action Plan

Meeting with Pascal Canfin (Member of the European Parliament)

4 Apr 2022 · Energy

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

E.ON appreciates the opportunity to provide feedback on the recast of the Energy Performance of Buildings Directive. E.ON supports the plans of the European Commission for a green transition of our economy. The transformation of the energy sector is at the heart of Europe’s climate ambitions. Due to the outstanding significance of the building sector for climate protection and the unmistakable need to catch up, it is important and appropriate to set ambitious goals in this area and to show a path how these goals can be achieved. In this context, it is highly important that the building stock is addressed. If an energetic renovation is pending ("worst first"), the renovation depth should be chosen correctly, because it is unlikely that a building will be renovated from the ground up several times before 2050. Therefore, if a substantial renovation is carried out, it should have a direct and strong impact on the emission performance of the building. An alternative could be a clearly defined renovation roadmap to achieve climate neutrality of a building (or district) by 2050 the latest. We also appreciate in principle the strengthening and higher liability of the energy performance certificates for buildings, which are extremely important for the uniform classification of buildings and the requirements for energy-related refurbishment of buildings. However, defining the building performance in terms of CO2 emissions would be even more in line with the expressed objective of making all buildings climate-neutral by 2050. With a general alteration to CO2 emissions as a reference value, the use of Renewable Energy Sources (RES) is directly taken into account in the building performance. The involvement of the RES is very significant to ultimately achieve climate neutrality. For this purpose, however, the requirements for the RES to generate power and heat on site may be too restrictive. That would unnecessarily restrict the use of the full renewable potentials. The possibility should be given to generate renewable energies economically and efficiently in quarters as well as to distribute them between several buildings. In general, the district approach is given too little importance in the recast of the Directive; this comprehensive consideration and calculation will also be necessary to achieve the overall climate neutrality of the building stock, even regarding buildings in line with the requirements of historic preservation. Buildings and the parking spaces within or around them will play a central role in making the sustainable mobility transition a reality. E.ON welcomes the clear expansion targets that have been proposed for the installation of smart charging points and preparatory installations in the building sector, although these targets could be even more ambitious. In a long-term perspective, there should be one installed smart charging point at every car parking space. Thus, it is important to equip as many parking spaces as possible in new buildings - both in residential and non-residential buildings - with (smart) charging infrastructure for electromobility.
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Meeting with Katarina Barley (Member of the European Parliament)

25 Jan 2022 · Exchange of Views

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur)

12 Jan 2022 · RED III

Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

E.ON appreciates the opportunity to participate in the consultation process on the Alternative Fuels Infrastructure Regulation (AFIR) and sees potential to spur the action required for the transition towards cleaner mobility. E.ON welcomes an ambitious, legally binding approach and all efforts leading to EU-wide consistency of technologies, whilst ensuring more transparent offers for customers. Nevertheless, the following provisions ought to be sharpened in the AFIR: Possible CPO price differentiations should be clearly described. Web-based payment systems instead of ad hoc payment at credit card terminals. Regulation on price information should not lead to restrictions on competition. The Commission’s proposal provides that by 2025 one publicly accessible recharging pool for light-duty vehicles with a total power of at least 300 kW is to be established every 60 km along the trans-European TEN-T core network. At least one recharging point in each pool shall have a power of 150 kW. While explicitly supporting the revision in general, E.ON does not consider these figures sufficiently ambitious and recommends a minimum of four CCS recharging points with a power of at least 150 kW for each pool. "Member State fleet based targets" ensure that one kW of recharging power is installed for each battery electric car registered in the corresponding EU Member State. From today's perspective, these values are to be an upper limit and should be monitored continuously. Higher values will only lead to a reduced occupancy rate, which in turn is counterproductive for further private business expansion. Now, fiscal incentives should follow, inviting private sector investments, e.g. the German "Fast Charging Act" could provide a blueprint for this approach. In spite of entirely different customer journeys, the current proposal of the Commission treats the recharging process in a manner similar to the classic refueling process. Following this logic, the AFIR indicates that ad hoc payment at credit card terminals would become the new standard. E.ON takes a critical stance towards this position, as the customer journey will be digital, from search, navigation, reservation, authorization to payment. Thus, a credit card terminal cannot be the singular option here; web-based solutions clearly represent the future payment method next to terminals. The proposal neglects the possibility for the customer to get access to international charging points via cross boarder roaming offers. Additionally, a big step for the customer convenience will be Plug&Charge. CPOs should decide where (additional to web-based payment) to apply credit card terminals. In addition, the PSD II should be adapted to enable pure NFC payment in the future. However, today, an obligation to install credit card terminals at all (DC) charging points will only lead to increased costs. Improved price transparency for customers is prerequisite for the attractiveness of e-mobility. Yet, the market for CPOs should not be restricted by equal treatment requirements without clear exceptions. The current wording of “objective justification” will lead to a different handling by each CPO. It should be clear under which circumstances the CPO price can be different. The price display of the EMP including the components for CPO and roaming is also problematic. This is not required for any other product or service. If EMPs must indicate all price components, this could undermine the entire EMP business model. E.ON welcomes measures leading to less discrimination, provided that different and competitive prices remain possible. Contract based payment, cross-border roaming, and Plug&Charge will be a comfortable and digital way of recharging for the customer. Regulation in the field will support even deployment of recharging infrastructure across the EU, preventing the development of a two-speed Europe, as well as ensuring that the EU meets its emissions targets and tackles the urgent climate crisis.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

E.ON welcomes the revision of the Renewable Energy Directive (REDIII) as a key policy lever to accelerate the deployment of renewables and their mainstreaming in end-use sectors. Please find attached our response to the consultation.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

E.ON welcomes the long overdue revision of the Energy Taxation Directive. To align energy taxation with the overarching requirements of the Green Deal, it is important to steer the European economy and consumer behavior patterns towards increasingly sustainable choices. Please find our response attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

E.ON welcomes the revision of the Energy Efficiency Directive as a key pillar to reach our 2030 goals. Mobilizing private investments to accelerate the energy transition is essential. In this regard, the predominantly market-oriented approach in this directive seems suitable. In E.ON’s opinion, the efficiency targets are in line with the overall 55% GHG emissions reduction target by 2030. Nevertheless, the Directive should not be over-prescriptive, which could compromise the reduction of CO2 emissions and security of supply. Please find attached E.ON's full consultation response on the revision of the Energy Efficiency Directive.
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E.ON backs new carbon pricing for transport and buildings

8 Nov 2021
Topic — Revision of EU Emissions Trading System to strengthen carbon pricing and climate targets.
Message — E.ON requests a revised hydrogen production benchmark before the next allocation period to allow electrolytic hydrogen producers to receive free allowances. They support using auction revenue entirely for climate investments, including electricity distribution networks. They want certain gas projects eligible under the Modernization Fund if convertible to hydrogen.1234
Why — This would allow their hydrogen operations to receive free allowances and gas infrastructure investments.56
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Meeting with Adina-Ioana Vălean (Commissioner) and

27 Oct 2021 · Automobiles

Response to Action plan on the digitalisation of the energy sector

10 Sept 2021

E.ON appreciates the opportunity to provide input on the development of an Action Plan on the Digitalisation of the Energy Sector. E.ON supports the plans of the European Commission for a twin green and digital transition of our economy. The transformation of the energy sector, with data and digital solutions as key enabler, is at the heart of Europe’s climate ambitions. Sufficient access to and quality of data are prerequisites for the energy system integration, i.e. linking all sectors to achieve an optimal decarbonization across the economy. With the massive roll-out of weather-reliant renewables, the irreversible trend of decentralizing generation and the increasingly active participation of consumers, flexible system management is a must. In order to guarantee a stable energy supply in the future, much more accurate forecasts are required than before. Data regarding electricity generation, storage, demand and flexibility of consumers must be collected quickly and processed fully automatically. We will rely on digital processes to make decisions, optimise and contribute to the overall stability of a system that is highly complex. E.ON therefore welcomes particular attention on the digitalisation of the energy sector. Indeed, the development of a European action plan by the Commission can define a clear pathway to capture the potential of digital services to reach energy and climate goals. The plan should lay out a legal and regulatory framework that keeps up with the pace of technological developments, is predictable and ensures efficient data sharing and access. The proposed European Data Governance Act and Artificial Intelligence Act as well as the envisaged Data Act and Implementing Acts on Data Access and Interoperability are essential to increase the use and exchange of data and shall be considered when drafting an Action Plan on Digitalisation of the Energy Sector. E.ON proposes inter alia the following: • Access to data – not limited to personal data - requires common standards and clear rules on processing of data for particular purposes, including the energy transition and climate change mitigation, in order to build the basis for successful exchange, access to, use etc. of data. • Data exchange, whether with or without the use of a neutral intermediary, can only take place on a voluntary basis between the businesses involved. The voluntary basis should equally apply to data spaces that are yet to be created, including for the energy sector. • Measures envisaged must be compatible with existing data protection regulations, while ensuring that there is no over-regulation or duplication, e.g. through legislation on Member State level. • The legal requirements for the processing of personal data should not be extended to the processing of non-personal data. This induces administrative as well as financial burdens that are potential obstacles and cause legal uncertainties to businesses. • Explicit statutory permissions for the exchange of certain data, including of personal data if and where required, for particular purposes, including the energy transition and climate change mitigation, are required in order to ensure legal certainty for businesses involved in the data exchange. • Legally secure anonymisation processes must on short notice be developed to enable effective data sharing. • Any changes in data formats need appropriate transition scenarios accompanied by adequate incentive schemes. • Cyber security is of utmost importance for all digital and data activities. Rules have to be strict enough to protect data and critical infrastructure, whilst giving enough freedom to effectively structure data exchange.
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Response to Requirements for Artificial Intelligence

5 Aug 2021

E.ON welcomes the opportunity to actively participate in the consultation process on the Artificial Intelligence (AI) Act. E.ON generally supports the plans of the European Commission to create a uniform framework for AI with the primary goal to strike a risk-based balance between the fundamental rights of European citizens and enabling competitive AI systems to develop. In order to ensure effective and fair regulation in this field, E.ON proposes inter alia the following: - The proposed definition of AI is too broad. The definition should therefore include the ability of software to self-learn. - Regulate the application, not the technology. Regarding the existence of an abstract high risk of AI, it is decisive in particular whether a decision affecting the environment it is interacting with is autonomously left to the AI itself or not. - There should be synergies with other measures already established in other areas such as data protection management systems or cyber security standards established for critical infrastructure. - Call for a priority focus on AI use cases with a benefit for climate and the environment. Please find our recommendations attached.
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Meeting with Pascal Canfin (Member of the European Parliament) and RENAULT

30 Jun 2021 · Green Deal

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

E.ON welcomes the opportunity to provide feedback to the public consultation regarding the Taxonomy Article 8 Delegated Act. Transparent reporting based on a common classification is indeed a fundamental pillar of implementing the climate goals of the Green Deal. Regarding the text published for consultation, there are several improvements that can be made to ensure transparent and meaningful disclosures, while seeking to avoid effort disproportionate to the added value. The level of granularity required by the draft DA, correlated with the short timeframe until the entry into force, make it impossible to deliver sound information for 2021. The DA must ensure adequate time for preparation. There should not be a retroactive application of any provisions should also be avoided. Please find our recommendations attached.
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Meeting with Kadri Simson (Commissioner) and

1 Jun 2021 · Fit for 55 package, as well as hydrogen infrastructure, market rules and taxonomy.

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

E.ON welcomes the opportunity to actively participate in this consultation process that will help establish the operational guidance on how to demonstrate compliance with the new sustainability criteria for forest biomass. E.ON generally supports the goals set out in the ongoing review of the Renewable Energy Directive to decarbonize the energy supply. Additionally, we support the implementation of the sustainability criteria of RED II, including the principles for the use of sustainable forest biomass. E.ON regards sustainable forest biomass as an important and necessary option in Europe’s energy transition. We see two major advantages in the use of sustainable forest biomass: First, the existing infrastructure can be used for the simultaneous generation of electricity and heat within the (existing) framework of CHP plants. Capital-intensive and lengthy conversions of the energy system could be avoided, which means that contributions can also be made in the very short-term to decarbonizing both the power and the heating sector. Secondly, the flexibility provided by controllable biomass-based CHP plants, especially when intelligently combined with heat and electricity storage systems, can make an important contribution to balancing the intermittency issue linked to RES deployment. Therefore, we welcome that sustainable biomass will no longer be considered a transitional activity, but can make a long-term contribution to the decarbonization of the energy supply. The existing stringent and risk-based sustainability criteria for solid biomass included in the RED II (Article 29) are still under implementation in the Member States and there is no evidence at this time to support the idea they are not fit for purpose to achieve EU objectives with respect to bio-diversity and climate. Hence, the criteria should not be changed under the revision of RED II, but instead be implemented without unnecessary delay in the member states. Introducing additional administrative requirements as a replacement for a risk-based approach would reduce supply and increase costs without leading to additional sustainability benefits. We strongly believe that sustainably managed forests and the use of waste wood for energy purposes as defined in RED II, can make a significant contribution in the successful decarbonization of energy supply and enhance Europe’s green energy transition.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

31 Mar 2021

E.ON welcomes the opportunity to actively participate in the consultation process on the Digital Services Act. E.ON generally supports the plans of the European Commission to deepen the internal market for digital services. The integrity and seamless functioning of the single market, especially the provision of cross-border (intermediary) digital services, is of high importance to E.ON. In order to ensure effective and fair regulation in this field, E.ON proposes inter alia the following: • Large companies, including those with a customer base within the range of Article 25 1. of the Regulation, that operate small online platforms where the range of public coverage and influence is limited (e.g. because of a marginal number of monthly active users), should be out-of-scope of the Regulation. Not only should Article 16 therefore exclude small and micro companies but also small and micro online platforms of large companies. The threshold might be a number of monthly active recipients of a service below 1 % of the Union’s population to accommodate for the fact that reach of such small online platform is limited. The introduction of an according threshold would particularly support smaller and innovative providers (and platforms) to scale up and grow. • No future applicability of the Regulation for companies other than those fulfilling the current thresholds set forth in Article 25 of the Regulation, e.g. by means of reduced thresholds. • An open, publicly available forum for information exchange predominantly by customers of a business should not be considered an “online platform” in the sense of the Regulation. The fact that such a forum is not “any service normally provided for remuneration” but is offered free of charge speaks against applicability of the Regulation. Moreover, such forum is not provided to recipients by their individual request but based on a decision of the company offering such a forum. • Neither the operation of (i) a business account on a third-party online platform nor (ii) of a social intranet available to employees of a business only shall be considered an online platform. • The availability and provision of digital services is typically transnational. Parallel and divergent legal standards, in particular where the question of potential illegality of content is concerned, by individual Member States hampers the provision of digital (intermediary) services across the EU. A reduction of legal fragmentation and compliance costs as well as enhanced legal certainty is needed. • The same applies with regard to the question which recipient of a service is an “active recipient” in the sense of Article 25 1. of the Regulation. It remains unclear at this point whether being “active” starts with an active account (only) or requires actively downloading and/ or posting of information. Regarding the status as “recipient of the service” the open question is whether simply reading information on an online platform means that a person is using a service. The definition of active recipient/ recipient of a service should be more specific.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The energy transition can only succeed if all sectors contribute their fair share to the overall EU objective of achieving "net zero" by 2050. The building sector currently accounts for approximately 39% of CO2 emissions in the EU; therefore, it is also essential to set an ambitious course for climate neutrality here. In our opinion, the following aspects are necessary to achieve emission reductions in the buildings sector: 1. Contracting Efficiency measures are often not the top priority and does not constitute part of core business for majority of the owners of commercial and residential properties. Additionally, it is often difficult for owners to choose the right efficiency measures, energy source or the overarching and system-serving optimisation of the energy supply. To this end, contracting business models are an important link between the potential effect of an efficiency measure and the real outcome after implementation. Currently, energy service providers, who are specialised in delivering and financing energy efficiency projects, do not have the same level of eligibility compared to property owners to benefits on levies, taxes or subsidies. This should be addressed. 2. City quarter solutions Currently, buildings in certain districts are renovated or rebuilt separately, often without overall planning, which may lead to lost efficiency gains on the society-level. Therefore, whenever possible, several buildings could be combined into a building complex - a “quarter” - for which all requirements regarding energy consumption, use of renewables or emissions could be fulfilled as a whole. “Quarter” solutions should not be too narrowly defined, but can be defined through the local expansion of heating networks or by limiting the supply area in terms of its spatial and social structure. By taking this “quarter-level” perspective, it would not only bring better efficiency to the heating sector, but also to electricity and, if necessary, also to the cooling and mobility sectors. 3. System integration A properly-designed energy management system could contribute to the integration of intermittent renewable energy resources through flexible generation and use. This is particularly true and important on the district level, which may include on-site renewable generation, heating supply from renewables, waste heat or environmental heat, storage options for electricity, heating and cooling, e-mobility with smart charging management and market-oriented energy procurement. This would require smart cooperation of the generation plants, storage facilities and consumers, which in turn would necessitate a suitable policy and regulatory framework with sufficient incentives for system-level flexibility. 4. Local and district heating networks To decarbonize the building sector via the expansion of district heating, regulatory requirements should be revised to better reflect customer needs. District heating can be decarbonised by changing the energy source. Ideally, renewables and waste heat should be used. To bring about better efficiency and better integrate these resources, the lowering of grid temperatures will be required. To implement this consistently, measures also are necessary on the customer side, which cannot be easily influenced by the supplier. 5. E-mobility As most of the charging processes in the private sector take place at home or at work, the roll-out of private infrastructure needs to be prioritized. When revising the EPBD the following should be addressed: lowering the threshold for parking spaces; recalibrating the relationship between preparatory measures and the actual installation of charging points; and significant shortening of implementation deadlines. Moreover, from the point of view of the energy industry, central aspects such as sector coupling, the network perspective, smart charging management, and progressive digitization need to be considered as well.
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Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

18 Mar 2021 · European Green Deal as a growth strategy

Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

E.ON welcomes the opportunity to actively participate in the roadmap consultation on Europe’s 2030 digital targets. E.ON generally supports the plans of the European Commission for a green and digital transformation. Digitization is crucial for Europe’s economic recovery but also for a green future. Naturally, the energy transition with data and digital solutions at its core is at the heart of the European climate ambitions. In order to achieve the EU’s digital ambitions, investment incentives and regulation that keeps pace with technological developments are required. What is needed now is clear and smart regulation, legal certainty and the willingness to invest. In order to make this a reality, E.ON proposes inter alia the following: Data access & sharing • Access to data – not limited to personal data – is fundamental to ensure the success of the digital and energy transition. Therefore, common standards and clear rules on permitted processing of data will be needed in order to build the basis for the successful exchange, access to, use etc. of data. • Data exchange, whether with or without the use of a neutral intermediary, can only take place on a voluntary basis between the parties involved. The voluntary basis should equally apply to data spaces that are yet to be created, including for the energy sector. • Measures envisaged must be compatible with existing data protection regulations ensuring at the same time that there is no over-regulation or duplication, e.g. through legislation on Member State level. • Cyber security is of utmost importance for all digital and data activities. Rules have to be strict enough to protect data and critical infrastructure, whilst giving enough freedom to effectively structure data exchange. Legal Certainty • The legal requirements for the processing of personal data shall not be extended to the processing of non-personal data. This induces administrative as well as financial burdens that are potential obstacles for those objectives to be met while at the same time causing legal uncertainties to businesses. • Explicit statutory permissions for the exchange of certain data could be useful in order to ensure legal certainty for business involved in the data exchange. • Legally secure anonymisation processes need to be developed as they are a prerequisite to enable effective data sharing. Investments & New Technologies • Increased public and private investments and funding in European data infrastructure (e.g. a real European cloud infrastructure) represents the essential prerequisite for Europe’s ambitions in efficient data exchanges. • Investments in new technologies are required to create the basis for future innovative and data-based products and services, resulting in improved efficiency. Uniform standards are needed across Europe that guarantee fair competition and investment security as well as sufficient capital allocation for early stage higher-risk digital technology ventures. • The broad debate on ethical data in the EU is appreciated. Our values must be valid in the digital world. However, algorithms, AI and other new technologies should not be placed under general suspicion that require strict regulation and bureaucratic processes per se. Costs in the range of those produced by the GDPR must be avoided. Applying new digital solutions to the energy sector is a crucial element of the energy transition. Digital Market & Sovereignty • A true digital single market as a driver of growth and innovation: The potential of the EU internal market in a digitized world is not being fully exploited today. A true digital single market without national fragmentation and country regulatory specificities should be developed. This would allow the markets to deliver impact at scale and foster European sovereignty. • The EU’s digital capabilities must be strengthened in order to enable Europe to catch-up with the leading digitalized economies and to reinforce Europe’s digital sovereignty.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

8 Mar 2021 · Sustainable finance & taxonomy

Response to Revision of the guidelines for trans-European Energy infrastructure

4 Mar 2021

For the full feedback paper and suggestions for amendments of articles, please see attached files. E.ON’s response to the EC’s proposal for a revised TEN-E Regulation Last year, the European Commission announced its intention to propose legislative changes that will commit the EU to reaching climate neutrality by 2050 and to significantly increasing its 2030 climate targets. To this end, and in order align existing EU legislations with the enhanced climate ambitions, the TEN-E Regulation needs to be revised. E.ON supports the European Commission’s proposal on all major points, but would still like to see the further strengthening of the Smart Grids category and the allocation of additional support in the proposed legislation in order to ensure that the right financial incentives will be provided to smart grid projects. At the end of 2020, the European Commission published its proposal for a new TEN-E regulation. As the revised TEN-E Regulation by the European Commission now has been submitted to the European Parliament and to the Council by the end of 2020, E.ON would like to call on the institutions to consider the following crucial aspect that would allow the revised TEN-E to better leverage smart grids’ enormous potential to help bring about deep decarbonisation of our economy: Incentives should also be provided to smart grid projects Currently there are only 6 PCI smart grid projects on the PCI list. Given the consensus the important role Smart Grids plays in our ongoing energy transition, this must be addressed. While there are myriad of other reasons that might have contributed to this problem, E.ON continues to believe that the main reason behind the current lack of smart grid projects in the PCI list and CEF is due to the financial disincentive on national level. It would also be worthwhile to point out that the PCI process is a rather complicated one, involving many FTEs. Sadly, under the current regimes in place in many MS, the financial incentives are simply not in place for companies such as E.ON to make a sound business case for utilising the PCI mechanism and the CEF funding. What can be done? Projects related to the Smart Grid category should also be able to benefit from incentives in Article 16 and 17. Furthermore, the incentives need to be adapted in order to properly incentivize the DSOs. Currently DSOs and smart grid projects are not referred to in neither article 16 nor 17, we would therefore recommend the institutions to not treat smart grid projects any differently compared to other projects. It must be assured that: • DSOs aren’t disincentivised by raising OPEX linked to the projects funded by grants and punished with efficiency requirements for their PCI projects. • DSOs can benefit from future regulatory depreciation allowance for any CAPEX related to maintenance, repair or replacement of project-related assets. Furthermore, financial incentives don’t necessarily have to be connected to grants. Projects making it to the PCI list could benefit from a “smartness bonus”. Since there already is a well-functioning PCI selection process on the EU level, the PCI status can thus be used to unlock other kinds of mechanisms or grants rather than just the CEF-budget, which is admittedly quite limited in relation to the huge investment need in grid infrastructure. To this end, a connection could also be made to e.g. the Horizon Europe program, where innovative solutions to support the energy transition are created. This would not only benefit the PCI-project itself, but also innovative solutions such as flexibility platforms to become more than just another flexibility platform that dies when the project is over.
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Response to Legislative framework for the governance of common European data spaces

1 Feb 2021

E.ON appreciates the opportunity to participate in the European Commission's consultation process on the Data Governance Act. E.ON is open to and supports any initiative strengthening the European digital economy. We believe that facilitating the sharing of personal and non-personal data by companies and public authorities, including through neutral third parties, who are prohibited from using such data for their own purposes, can be a useful contribution to this goal. In E.ON's view, the exchange and sharing of data - within and outside the energy sector - must at all times be subject to the voluntary decision of the data holder. In addition to protecting the data itself, this also serves to protect the investments made by the data holder (e.g. for digital devices or systems for the purpose of collecting or processing certain data). We welcome the fact that the Data Governance Act does not result in the lowering of legal standards created for processing personal and non-personal data. However, from E.ON's point of view, explicit statutory permissions for the exchange of certain data could be useful in order to ensure legal certainty for those involved in the exchange. Here we are thinking in particular of the area of potential exchange of data with third parties regarding the planning, operation and maintenance of distribution networks, including the generation and demand side, etc. Regarding the requirements for data sharing services, the following points are of particular relevance from E.ON’s perspective: 1. Data exchange, whether with or without the use of a neutral intermediary, can only take place on a voluntary basis between the parties involved in the data exchange. The voluntary basis should equally apply to data spaces that are yet to be created, including for the energy sector. 2. If a company already is the data holder of certain data which it may use for its own business purposes or for the fulfilment of other obligations, the application of the obligations in particular of Articles 10 and 11 of the Regulation to such data holder would be artificial and should be rejected if this data is also transferred or has to be transferred to any third party, e.g. in the fulfilment of legal or sector specific obligations. In the energy sector, this would be conceivable in the case of the transfer of metering data by the data holder, e.g. the distribution system operator, to a third party designated by the customer on behalf of the customer. It should be excluded that an original data holder of certain data can be regarded as a neutral intermediary for such data. A data sharing provider should be seen always as a company whose main business purpose is to organise and perform services for the exchange of data between data holder and data user. 3. The provision of Article 5 (3) of the proposal for the Regulation seems misleading when put side by side with recital (11). Where the re-use of personal data by the re-user requires prior anonymisation, this ought to take place already prior to the transfer to the data re-user (and not only prior to a possible further transfer from the latter to any third party) for data protection reasons. The anonymisation should therefore have to be carried out by the authority itself and not by the data re-user, who would receive data that is already anonymised from the authority. Moreover, we are also of the opinion that the requirements for "pre-processing" in the sense of legally secure anonymisation processes need to be concretised if this is to be imposed on the data re-user. 4. Article 11 (4) needs further clarification: The right of the data user to request a specific data format needs to be restricted to customary data formats.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

E.ON sees the need to make better use of private financial resources to finance the energy transition and to achieve the ambitious goals of the European Union and its Member States by framework conditions geared towards sustainability. In this context, three subject areas are important to us, and we will comment on them below: 1. Financing issues, effects on green bonds or development of the entire corporate bond market towards green bonds. What effects will this have on our future investments? 2. Reporting on taxonomy, non-financial reporting, sustainability reporting, ESG ratings. 3. Impact of the evaluation criteria on our existing and future business. POLITICAL DEMAND SUSTAIMABLE FINANCE: To be able to use the taxonomy evaluation criteria in practice, a systematic assessment of complex projects against a uniform threshold value is considered to be more appropriate. However, it should be taken into account, especially in the area of heat supply, that seasonally, i.e. in winter, a higher limit value for e.g. essential supplementary firing may be necessary, as otherwise a reliable supply cannot be guaranteed. POLITICAL DEMAND REPORTING: To be able to use taxonomy in business practice, plausible data from former experience and estimations should be allowed to evaluate cross cutting economic activities. These estimations could be verified by third parties. By this means, the utilization of the evaluation criteria would be possible in practice also for existing businesses rather than for investment projects only. The accounting regulations must be examined and possibly amended, to ensure that taxonomy reporting can be managed without too much additional efforts using primary bookkeeping. POLITICAL DEMAND EVALUATION CRITERIA: When setting the threshold values for transitional activities, other benchmarks should be applied for technologies that in fact enable the transformation to a climate-neutral economy. An economic activity should be recognized as conform to taxonomy if a development path towards climate neutrality can be shown, i.e. it does not involve any lock-in effects. The starting threshold should always be a value according to state-of-the-art technologies with fuels or feedstocks for which there is a liquid market today. The taxonomy can also define a further development of the criteria for the coming years. However, it is recommended not to plan too far into the future and better adjust the threshold values as part of a periodic revision of the taxonomy. We strongly recommend to assess the ecologic and economic impact of the proposed and of alternative thresholds in order to comply with the Better Regulation principles, given the wide-ranging effects of the Taxonomy Regulation on all economic sectors in Europe. In general, the different treatment of electricity generation from renewable sources and the role of gas infrastructure for the energy transition and the future distribution of green gases and hydrogen should be reconsidered. A more detailed description of the practical hurdles and acute problems that leads us to the political recommendations is given in the attached file.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

E.ON welcomes the Commission´s roadmap consultation on the CO2 Emissions Performance Standards for Cars and Vans, we consider this a pivotal policy for the decarbonization of transport. Please see attached our full response.
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Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

1 Oct 2020 · Discussion on Green Recovery

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

We welcome the opportunity to contribute to the roadmap consultation of the Energy Efficiency Directive. E.ON fully supports the increase of the 2030 target to reduce greenhouse gas emission by 55%. It sets an appropriate pace to achieve net-neutrality until 2050. Mainstreaming energy efficiency is pivotal to making such a steep cut possible. As the recently published Evaluation of the National Energy and Climate Plans has shown that the current 32.5% target would be narrowly missed, we believe that correlating the level of ambition and removing any remaining barriers are essential going forward. In general, the Energy Efficiency Directive should serve multiple purposes: to accelerate decarbonization, offer relief to citizens by reducing energy-related expenses and produce economic growth opportunities to stimulate the green recovery. In order to make the Energy Efficiency Directive an effective policy instrument, we propose the following: 1. Mainstream “energy efficiency first” at system level – to enable energy system integration • The Directive should be correlated with the Energy System Integration Strategy and broaden its approach to enable system efficiency. • Intelligent sector integration requires locally and regionally optimized energy systems. • In the distributed energy system, smart electricity distribution grids will play key role to connect increasing renewable energy capacity, active consumers and enable flexibility through demand-side management. 2. Correct and effective market signals • Clear commitments and incentives for Member States to implement energy efficiency policies are welcome. • However, the policy design in Article 7a, that opens up the possibility to obligate energy companies to implement energy efficiency measures for their customers, does not account for the lack of interest or incentive for consumers. • To ensure the consumer is invested in implementing energy efficiency, correct price signals must be ensured: - The price of electricity should be relieved from taxes and levies. - A robust carbon price, that is expanded to all end-use sectors, including non-ETS, should be introduced. • An energy taxation based on carbon-intensity, together with a 0% fiscalization of electricity, will send strong incentives to consumers to switch and save. • We firmly believe that market-based approaches are the best way to deliver energy efficiency. They give the customer the flexibility to decide the best technology, financing and approach for them. 3. A meaningful Renovation Wave will come as a package deal with efficient heating & cooling • Projected to consume 40% renewable electricity by 2030, heating is a strategic sector for energy security. Whether by decentralized (i.e. small-scale heat pumps at home) or large-scale heat pumps in district heating systems, electrification will enable the integration of higher shares of renewables in the heating sector. • The Renovation Wave and Energy Efficiency Directive revision should be correlated to enable thermal insulation to come as a package deal with the decarbonization of heating and cooling systems, predicated on take-up of renewable energy sources. • The “energy efficiency first” approach should be the norm for demand and supply. 4. Ensure flexibility for member states to choose the best way to meet the targets • The option to exclusion of transport targets from baseline calculations reduces countries’ flexibility. • By removing transport emissions from the baseline, efficiency targets would be increased considerably and Member States are ill-stimulated to rely less on free market activities to meet the efficiency targets and more top-down measures. • Therefore, energy efficiency measures will be less market driven and become more of a command and control system, which is an undesirable result.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

We welcome the opportunity to contribute to the roadmap consultation on the review of the EU renewable energy rules. E.ON supports the new, clear path for the EU 2030 climate targets and the reduction in greenhouse gas emission of at least 55%. The evaluation of the National Energy and Climate Plans of the Member States by the European Commission published last week reveal that the current national goals are missing the 2030 targets, but there is a slight over-reaching in targets of renewable energy sources (RES). Additional commitment is needed. E.ON proposes the revision of the Renewable Energy Directive (RED) takes into account the following: 1. Renewable generation and electrification are a package deal A predictable framework for RES should come hand in hand with a proper incentive framework for consumers to switch to electricity, e.g. for heating or transport. In order to achieve this: • Electricity prices should be relieved of taxes and levies, saving all business and citizens money and incentivising the switch to clean electricity and support successful sector coupling. RES support schemes, if required, should no longer be passed-through in the final electricity price to consumers. • A strong carbon price and expansion to non-ETS sectors, i.e. transport and buildings, is required to ensure a level playing field between electricity and more carbon intensive energy carriers. 2. Green infrastructure development is a prerequisite to integrate RES • To improve overall system efficiency and integrate more renewables, green infrastructure investments should be accelerated, particularly the expansion of smart grids, but also eMobility charging infrastructure and low-carbon gas grids (by increasing content of Hydrogen). The directive should recognize the need for sound and stable grid regulation. 3. Mainstream energy system integration • Overall efficiency and the use of renewable sources should be advanced in all end-use sectors. • In buildings for instance, where it is important to cut emissions and costs for consumers, we recommend the upcoming Renovation Wave and RED revision are correlated to enable thermal insulation to come as a package deal with the decarbonization of heating and cooling systems, predicated on take-up of renewable. The “energy efficiency first” approach should be the norm. • For industry, decarbonization can be done via the direct use of RES or indirect via hydrogen. But important savings can be achieved by using technologies that recover and reuse of waste heat from industrial processes. This may be in many cases a least-cost option, that ensure the circular character of the system. The revision of the RED should consider counting the recovery of waste heat towards the RES targets. 4. Ensure good conditions and streamlined procedures for solar • Furthermore, we welcome the strong recognition of solar energy in the climate legislation. However, we need to underline the importance of photovoltaics on rooftops. • RED should provide additional guidance to ensure streamlines procedure avoid additional bureaucratic and cost burdens for PVs, particularly for self-consumption.
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

Digitalisation in E-Mobility A 90% emission cut is required in the transport sector in order to achieve the climate neutrality target by 2050. At E.ON we believe that this objective can only be achieved with the electrification of large parts of the mobility sector, whereas we are dedicated to ensure that e-mobility is an attractive option for our customers. We are focused on delivering intelligent networks and innovative customer solutions. Thereupon, we have already made extensive investments in e-mobility and the corresponding networks of the future. As a leading charging solution provider and manufacturer, E.ON has already installed 36,000 charging points worldwide for private and business customers as well as 180 High Power Chargers in Europe. Open standards for charging infrastructure We think it is of high importance that there should be no mandatory obligation for charge points to connect to a specific roaming platform. Data sharing during charging situation Data sharing between vehicles and energy providers is of essential importance. Unlocking the full potential of e-mobility depends, in large part, on the ability to integrate increasing numbers of EVs into the energy system. While this is a challenge to manage increases in local peak energy demand, it is also an opportunity to empower the customer and give them the ability to monetize the flexibility their vehicle provides. Access to vehicle data, especially the state-of-charge (remaing capacity of the battery) and the possible charging power, is essential to making this possible. This goes beyond data from intelligent metering. Fair access to data will reduce grid-expansion costs and increase flexibility. A corresponding exchange of data, especially at the interface between vehicle and charging station is vital. This communication interface is described with the ISO 15118 standard. In addition to intelligent load management, this also enables functions such as plug and charge (PnC). PnC describes the immediate authentication/authorization and start of the charging process by means of connecting the cable to the vehicle. Charging Management for sector coupling Intelligent charging management is essential as it provides one of the most important interfaces of sector coupling. Here, electric cars can be seen as a supportive and stabilizing element in three ways: • As ‘controllable’ consumers, who (ideally) mainly obtains electricity when available from renewable energy sources. • As a storage for potential excess electricity from renewable energy that might otherwise have to be curtailed. • For feeding electricity back into the grid locally in order to balance voltage fluctuations. In order to ensure a smooth data exchange, a common communication standard is required: This would ensure the interoperability between charging station, vehicle and mobility provider. The communication must be non-discriminatory, openly interoperable and secure between all market participants. Authentication certificates integrated directly into the vehicle electronics For enabling the PnC feature via ISO 15118 the integration of contract certificates in the vehicle is necessary The secure communication required for this is based on digital certificates and digital signatures as part of a public key infrastructure (PKI). This PKI infrastructure must be developed and set up by an independent body. We hereby explicitly recommend that the development and implementation of the ISO 15118 standard as an internationally valid standard for vehicles and infrastructure be accelerated and based on these recommendations. This is vital for the wider integration of electric vehicles into the electricity grid (sector integration), secure data transmission as well as additional value added services.
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Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

E.ON welcomes the renovation wave. Energy efficiency can lead to lower bills, efficient buildings, lower carbon emissions and stimulate job creation. The renovation wave is particularly welcome in the context of the economic stimulus following the COVID-19 restrictions. Historically, large public subsidies for energy efficiency have been underutilized. There are myriad reasons for this, not just the level of subsidy. There are often conflicts of interest between renters and owners or residents of the same building. Differing levels of purchasing power can deter renovation or reduce a project’s scale. Further, many energy efficiency schemes are administratively complex and suffer from low awareness among tenants/owners. In order to address these hurdles, the European Commission should consider: Incentives and policies focused on installers/service providers: state aid guidelines only allow building owners and tenants to receive aid for energy efficiency in buildings. This should be expanded to allow incentives for installers/service providers. This would allow the market to provide capacity and expertise to speed up delivery. Installers/service providers can offer bundled solutions and financing options widely. They can also help to reduce the complexities of individual consumers applying for funding. Support should also be made available for (re)training tradespeople (plumbers, electricians etc.). They are often the salesperson as well as the installer and thus should be aware of the products and subsidy options available. Increasing the use of output-based tenders: whether at a European, national or local level competitive tenders for energy efficiency should be the norm. Tenders should be technologically open, have very low administrative burdens and have an output-based criterion. Businesses can then enter their project and funding would be granted to those offering the largest carbon reduction at the least cost. This will ensure money is spent efficiently, the integration of multiple solutions and will tap into the ability of the market to sell energy efficiency. Renovation wave should be broad: funding and legislative design should consider how to combine energy efficiency and onsite renewables. Further, it should not focus only on individual buildings but also the climate-friendly redevelopment of entire urban districts or industrial clusters. A single CO2 standard for buildings: The EU should develop or focus on a CO2 performance standard instead of a primary or end use performance standard. Setting stronger C02 standards for buildings, and ensuring inspection and implementation, is key. Remove energy company obligations: much of the low hanging fruit for energy efficiency has been picked. As such the costs of energy efficiency could escalate. Therefore, obligations placed on energy providers should be phased out to prevent increasing energy bill costs for customers. A market-based approach (i.e. tenders) should be used to control costs. Renovation wave must be underpinned by the correct price signals: Non-energy costs such as policy and social cost must be stripped from energy bills and the Energy Taxation Directive should be reformed – allowing electricity taxes and levies to be driven down to zero. Carbon pricing should be expanded to cover the transport and heating sectors. A clear carbon pricing trajectory should be implemented both in the ETS and in the new carbon pricing schemes. This will make low carbon technologies, like heat pumps and electric vehicles, as competitive as more carbon intensive ones, such as gas boilers and combustion engines. In addition, there are several ongoing approaches that should be continued/pursued. Such as, awareness raising campaigns, the expansion of energy efficient mortgages, the use of public buildings as lighthouse projects, introduction of the smart readiness indicator and obligatory installation of EV charging.
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Response to Strategy for smart sector integration

8 Jun 2020

We welcome the European Commission’s holistic approach to the integration of energy systems. A break from silo thinking can accelerate decarbonization and increase resource efficiency. Capitalizing on the interlinks between the energy and end-use sectors, and links within the energy sector itself, can ensure decarbonization at least cost and contribute to a sustainable European recovery from the economic impact of Covid-19. Please find enclosed our full response.
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E.ON urges tax relief and investment certainty for green gas

8 Jun 2020
Topic — The European Union strategy for developing clean hydrogen to achieve climate neutrality goals.
Message — E.ON requests removing taxes and levies on electricity used for green gas production. They recommend annual capacity tenders and financial aid to support technology scale-up. The company advocates for a market-based approach rather than treating plants as regulated infrastructure.123
Why — Tax exemptions and subsidies would significantly lower E.ON's operational costs for hydrogen.4
Impact — Promoting non-renewable hydrogen could harm purely green competitors and climate targets.5
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Response to Revision of the guidelines for trans-European Energy infrastructure

5 Jun 2020

E.ON welcomes the European Commission's intention to revise the TEN-E Regulation. In the recently European Green Deal communication, the European Commission announced its intention to commit the EU to reaching climate neutrality by 2050 and to explore increasing the EU’s 2030 climate target, to which the TEN-E Regulation needs to be aligned. As an evaluation of the TEN-E Regulation by the European Commission will be finalized and submitted to the European Parliament and to the Council by the end of 2020, E.ON would like to call the European Commission to consider the following aspects: Include low-voltage smart grid projects in the TEN-E The definition of smart grids must be revised and the restrictive eligibility criteria enlarged to support the integration of RES. Smaller and decentralised infrastructure projects, including low-voltage smart grids, should be included. Stimulate smart sector integration In its revision, the TEN-E should further emphasise coupling electricity to other sectors, especially heating and transport. District heating is not defined as a priority thematic area in the current TEN-E Regulation. However, power-driven heating generation stabilizes power grids by offering additional flexibility solutions, such as local balancing and peak shaving. Likewise, the development of electro mobility as a new form of electricity demand and flexibility resource lacks attention in the TEN-E Regulation. Replicable projects connecting RES to electric vehicles (EV) charging infrastructures at low- and medium-voltage level require further promotion. DSOs provide crucial potential for the build-out of EV charging infrastructure which is urgently needed. Digitalisation E.ON welcomes the inclusion of the technological evolution towards a digitalised economy in the revised TEN-E Regulation. Smart grid deployment as a TEN-E priority thematic area, helps stimulate the digitalisation of the energy system, and ultimately leads to increased economic benefits.
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Response to Revision of Alternative Fuels Infrastructure Directive

29 Apr 2020

To achieve the objectives set out in the Green Deal, all EU policies and sectors will need to make their contribution – notably the transport sector. As E.ON explicitly advocates for electric mobility in road traffic, we welcome the Commission’s commitment to spur the action needed to keep the transition towards cleaner mobility and the EU on the path in meeting its Paris climate commitments. As such we welcome the Commission´s incentive to revise the Alternative Fuels Infrastructure Directive and have provided a more in depth analysis in the attached document.
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Response to Report on the application of the General Data Protection Regulation

28 Apr 2020

As an operator of critical infrastructure and service provider to around 50 million customers we take our elevated responsibility for data protection very seriously. We have taken all steps necessary to comply with the General Data Protection Regulation including revising data protection contracts and other documents, informing all relevant parties, and reviewing our data breach process. We also put in place a Data Protection Management System which provides guidance on data protection issues and ensures we take a structured, coordinated, consistent approach to data protection across our company. We are enthusiastic about the GDPR and see high data protection standards as a chance to build trust and transparency with our customers. It has harmonized many existing rules across Europe, given clear instructions to businesses as to what is expected of them and helped customers feel protected. After two years’ working with GDPR we do believe there are some areas in which the Regulation could be improved to increase its effectiveness. These are as follows: 1. Harmonization of authorities` opinions: in the last two years we have found that the regulatory bodies across Europe can provide different legal interpretations of the GDPR. Even in a single member state there are often conflicting opinions from numerous data authorities. As a company operating in over 15 countries it is challenging and expensive to implement standardized processes across the company when there are differing regulatory opinions across the Union. It also creates considerable uncertainties that carry a potentially high financial risk. We would welcome stronger steering from the European Data Protection Board to ensure a more consistent approach across the EU. 2. Making information duties more customer friendly (allowing the so called “media break”): in certain contexts the need to provide information at the time when data are collected raises practical questions, especially for offline-communication. For example, when requesting a meter reading from a customer this simple procedure must now be accompanied by a lengthy and unwieldy letter. It is equally challenging where communication is verbal, and it is impractical to recite such information. A simpler and more customer friendly solution would be to provide a link to a webpage with the relevant information. However, the acceptability of switching communication channels during a customer contact (so called “media break”) is questionable. A clear statement from the relevant authorities on the permissibility of such actions would be welcome. 3. 72-hour breach notification (Art. 33): the GDPR stipulates that in the case of a personal data breach the data controller has 72 hours after having become aware of it to notify the regulatory authority. We support prompt reporting; however, the 72-hour window is challenging. In many cases frontline colleagues are essential to clarifying whether there has been a reportable breach. Their natural human reaction to the such enquiries is often defensive and it takes time to coach them through the process. This is further complicated for a larger company, such as ourselves, as there are numerous reporting lines and adjacent teams to align with and/or investigate. An extension of the window that factors in these challenges would be welcome. 4. Data protection by design (Art 25): Under the current rules the requirement for “Data protection by design” are directed towards the data controller. However, we are often reliant on hardware, standard operating systems and application software that is bought in. In some cases, the choices available to us in both the products and the way we use them are limited. As such there is little we can do to ensure data protection by design. Despite this lack of control we are held accountable for failing to deliver on this Article. A fairer and more comprehensive approach would be to make a wider group of parties subject to this requirement.
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E.ON urges higher climate targets and expanded carbon pricing

14 Apr 2020
Topic — The EU's consultation focuses on increasing the 2030 greenhouse gas emission reduction target.
Message — E.ON supports raising the 2030 climate target to 55% while protecting current legislation. They propose extending carbon pricing to transport and buildings alongside cutting electricity taxes and levies. The company also calls for incentives to modernize distribution grids for renewable energy.123
Why — Lowering electricity costs would make E.ON's low-carbon energy technologies more competitive in the market.4
Impact — Sectors relying on carbon-intensive fuels will face higher costs due to expanded carbon pricing.5
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Response to Revision of the Energy Tax Directive

30 Mar 2020

E.ON welcomes the European Commission’s initiative to review the Energy Taxation Directive and make it consistent with the climate agenda of the Green Deal. Taxation policy can become one of the most important and effective instruments to steer the European economy and consumer behavior patterns towards increasingly sustainable choices. Net-neutrality by 2050 requires a timely re-alignment of the policy framework around the “polluter pays” principle. This means that energy taxation rates should better reflect carbon emissions-intensity of energy carriers all over Europe. While industry has generally fared well to improve the energy intensity of their operations in order to reduce costs and stay competitive, little incentive exists for individual consumers. Tax rates that are proportional to the CO2 output are essential to steer consumption patterns, promote fuel-switching and the use of renewable energy. The cost of externalities from fossil fuels (health, climate abatement, climate adaptation) should be factored into energy prices. The minimum rates provided in the current ETD are not based on any specific logic. These thresholds remained unchanged since 2003 and their relative value has decreased over time, making them ineffective and unfit to give an adequate price signal to energy users. 1. Zero tax on electricity to unlock potential for a net-zero future Electricity generation has decarbonized at the fastest rate, reaching a RES share in the generation mix of 32.3% in 2018. As clean technologies reach maturity and costs go down, this trend is likely to continue. This makes electricity the best energy carrier to serve the mobility and heating needs of European citizens. Yet the electricity price still carries a disproportionate burden of the energy transition, with high level of taxes and levies, and other forms of fiscalization, like social tariffs. The review of ETD must account for the developments in the generation mix, the potential of decentralized production, and stimulate further electrification of these sectors, by enabling a reduction of the taxes and levies on electricity to zero. To incentivize investment in Power-to-Gas (P2G) facilities, the ETD should also provide that they are not be categorized as end-user and face input costs that include taxes and levies. 2. ETD revision should mitigate further market fragmentation In some MSs, in addition to fulfilling its fiscal, energy taxation already has a role in addressing environmental challenges, taking into account the carbon content of different energy products. But having divergent national tax rates above the minimum threshold actually leads to the fragmentation of the internal market. New technologies, not covered under the 2003 ETD, allow for some MSs to apply their own classifications. ETD should address the risk of growing distortion and prop up the internal market, to make the European economy fit for the bold transformation envisaged in the decades to come. Providing clear guidelines on how to set taxation rates based on environmental impact could mitigate this and improve coherence between MSs. This would also help all MSs differentiate between new lower-carbon energy carriers like biogas or hydrogen, from their fossil counterpart. 3. Lower taxes on electricity could be budget-neutral Energy taxation is an important revenue stream for all countries. The reduction in electricity taxes should be recovered from higher rates for carbon-intensive energy carriers. Relieving the electricity prices can have two other important positive effects for the economy: 1) foster the competitiveness of energy-intensive European industry, by covering the price differential compared with non-EU regions; 2) adress social aspects, by making electricity more affordable for all consumers.
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E.ON urges rapid 2030 climate action and lower electricity taxes

6 Feb 2020
Topic — Legislation to enshrine the EU’s 2050 climate neutrality goal into law.
Message — E.ON calls for a quick conclusion on climate targets to shift focus toward 2030 objectives. They propose lowering electricity prices by removing taxes and levies while expanding carbon pricing to transport and buildings. Additionally, they request incentives for smart grid investments and more flexible state aid rules for climate technologies.123
Why — Lowering power costs and taxing competitors would boost demand for E.ON's electricity-based services.4
Impact — Suppliers of fossil fuels for heating and transport will face higher operational costs.5
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and innogy SE

27 Nov 2019 · European Green Deal

Meeting with Ditte Juul-Joergensen (Director-General Energy)

27 Nov 2019 · Clean energy transition and decarbonisation of the economy. Transformation of the E.On business

Meeting with Günther Oettinger (Commissioner)

2 May 2019 · Energy and Competition policy

Meeting with Kilian Gross (Cabinet of Vice-President Günther Oettinger)

25 Apr 2019 · Energy and Competition Policy

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

We welcome the opportunity to give feedback to the European Commission in their evaluation of the Alternative Fuels Infrastructure Directive. Please find our views in the attached document.
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Meeting with Marie Frenay (Cabinet of Vice-President Andrus Ansip)

22 Nov 2018 · Artificial Intelligence

Meeting with Maroš Šefčovič (Vice-President) and

6 Sept 2018 · Merger case RWE-E.ON, state of play Energy Union, Carbon Intensive Region Initiative

Meeting with Miguel Arias Cañete (Commissioner)

10 Jul 2018 · Clean energy transition and future strategy of E.ON

Meeting with Günther Oettinger (Commissioner)

10 Jul 2018 · Energy policy

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

26 Apr 2018 · Energy Markets

Meeting with Miguel Arias Cañete (Commissioner) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

20 Nov 2017 · clean energy package

Meeting with Kilian Gross (Cabinet of Vice-President Günther Oettinger)

7 Jul 2017 · energy policy

Meeting with Günther Oettinger (Commissioner)

6 Apr 2017 · Digitalisation energy, energy projects

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

21 Sept 2016 · Market design

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

28 Jun 2016 · Challenges of the Energy Union implementation with a focus on innovation and the E.ON strategy in this respect

Meeting with Miguel Arias Cañete (Commissioner) and WindEurope and

5 Jun 2016 · policy framework post-2020: review of the renewable energy directive and market design

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

14 Apr 2016 · Energy Efficiency and Investment

Meeting with Miguel Arias Cañete (Commissioner) and ENEL SpA and

23 Feb 2016 · 2nd EU Energy Summit - breakfast roundtable

Meeting with Eric Mamer (Digital Economy)

30 Oct 2015 · DSM

Meeting with Maroš Šefčovič (Vice-President) and

30 Oct 2015 · creation of a network of Energy Union Business Ambassadors

Meeting with Dominique Ristori (Director-General Energy) and Eni S.p.A. and

6 Oct 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

Meeting with Dominique Ristori (Director-General Energy)

17 Sept 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Gas security of supply

Meeting with Dominique Ristori (Director-General Energy) and ENEL SpA and

17 Sept 2015 · European energy policies

Meeting with Dominique Ristori (Director-General Energy) and TotalEnergies SE and

4 Sept 2015 · gas and oil

Meeting with Miguel Arias Cañete (Commissioner) and

4 Sept 2015 · Security of supply and Energy diversification

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

26 Aug 2015 · Energy Union

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

24 Jul 2015 · Market Design

Meeting with Dominique Ristori (Director-General Energy)

17 Jul 2015 · Energy Union strategy

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

26 May 2015 · EC/Russian/Ukrainian gas talks; Gas supply South-East Europe

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

26 May 2015 · Financil Market Legislation

Meeting with Maroš Šefčovič (Vice-President) and

20 Apr 2015 · Gas storage

Meeting with Miguel Arias Cañete (Commissioner) and

14 Jan 2015 · Energy Union and Internal Energy Market

Meeting with Dominique Ristori (Director-General Energy)

12 Jan 2015 · Gas Storage