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European Association of the Electricity Transmission and Distribution Equipment and Services Industry

T&D Europe

T&D Europe is the main association representing the electricity transmission and distribution equipment industry.

Lobbying Activity

T&D Europe urges grid digitalization to unlock energy AI

4 Nov 2025
Topic — This initiative leverages digital technologies and artificial intelligence within the European energy sector.
Message — T&D Europe demands urgent grid upgrades and better access to high-quality data. They call for harmonized regulation implementation and realistic transition times to prevent duplication.12
Why — This shift would boost investment in digital infrastructure and software provided by their members.3
Impact — European AI developers risk losing ground to global competitors due to restrictive energy data regulations.4
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T&D Europe demands stronger grids to accelerate EU electrification

9 Oct 2025
Topic — The EU initiative aims to increase electricity demand to meet decarbonisation targets.
Message — T&D Europe requests lower electricity prices and financial incentives for switching to electric technologies. They also demand faster grid access and prioritizing infrastructure in EU funding.12
Why — Prioritising grid expansion would significantly increase demand for the industry's transmission and distribution technology.3
Impact — Strict environmental standards could be compromised by calls to allow hazardous chemicals in equipment.4
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Meeting with Joachim Balke (Head of Unit Energy), Vincent Berrutto (Head of Unit Energy)

9 Oct 2025 · Digitalisation and competitiveness

T&D Europe urges removing electrical steel from CBAM scope

26 Aug 2025
Topic — The EU is consulting on extending its carbon border tax to downstream products and anti-circumvention rules.
Message — The association requests removing Grain Oriented Electrical Steel from CBAM scope while adding finished transformers to prevent carbon leakage. They also advocate for export compensation schemes and simplified reporting to lower compliance burdens.123
Why — These changes would reduce input costs for European manufacturers and protect them from cheaper non-EU competition.4
Impact — Non-EU equipment producers would lose their current tax-free access to the European transformer market.5
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T&D Europe warns steel trade measures threaten transformer industry

18 Aug 2025
Topic — The EU is reviewing trade measures against global excess capacity in steel.
Message — T&D Europe requests alternatives to steel duties to protect local transformer manufacturers. They argue trade protection should not sacrifice the industry's only local customers.12
Why — This would prevent rising production costs and maintain the industry's global competitiveness.3
Impact — Energy consumers and network operators would face higher prices for essential infrastructure.4
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Meeting with Joachim Balke (Head of Unit Energy) and Hitachi Energy

24 Jul 2025 · Tripartite contracts – Affordable Energy Action Plan

Response to Technical description of important and critical products with digital elements

18 Apr 2025

Despite the very good effort to technically clarify the family of products under Class I, II and III, some uncertainties and unclear elements are still present. Special attention should be given to class III equipment where the description is still very vague and , in some cases , not bringing the needed clarification of scope.
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Meeting with Dario Tamburrano (Member of the European Parliament, Shadow rapporteur) and ENEL SpA and

4 Mar 2025 · Reti elettriche

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

T&D Europe fully supports the Net-Zero Industry Act (NZIA) as a crucial measure to strengthen Europes supply chains for net-zero technologies, in alignment with the EUs 2050 climate objectives. The NZIA offers significant opportunities for the European grid industry by recognising the role of grid manufacturers and establishing a supportive regulatory environment. In our response, we propose the establishment of clear guidelines, structured timelines, and a phased approach to the resilience and sustainability criteria to mitigate administrative burdens. We also request clarity on the calculation of domestic content requirements and alignment with other EU frameworks, ensuring that all net-zero technologies can benefit from EU funding. Furthermore, we recommend the inclusion of additional items in the Electricity Grid Technologies category. We are eager to engage with the European Commission and work collaboratively to ensure the successful implementation of the NZIA within the grid technology supply chains.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

T&D Europe fully supports the Net-Zero Industry Act (NZIA) as a crucial measure to strengthen Europes supply chains for net-zero technologies, in alignment with the EUs 2050 climate objectives. The NZIA offers significant opportunities for the European grid industry by recognising the role of grid manufacturers and establishing a supportive regulatory environment. In our response, we propose the establishment of clear guidelines, structured timelines, and a phased approach to the resilience and sustainability criteria to mitigate administrative burdens. We also request clarity on the calculation of domestic content requirements and alignment with other EU frameworks, ensuring that all net-zero technologies can benefit from EU funding. Furthermore, we recommend the inclusion of additional items in the Electricity Grid Technologies category. We are eager to engage with the European Commission and work collaboratively to ensure the successful implementation of the NZIA within the grid technology supply chains.
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Response to Update of format for F-gas reporting

10 Jun 2024

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry, would like to use this opportunity to raise our feedbacks on the format for submitting the reports of data into F-Gas Portal and repealing Commission Implementing Regulation (EU) 2014/1191. Key points: focusing on format referenced 11_M and 11_N. 1. According to EU 2024/573, Art. 26 §4 and Annex IX §6, manufacturers shall report on categories of product, number of units and quantities of substances. There may be a confusion possible regarding the definition of units. In T&D switchgear application we are using the term functional unit as a part of switchgear comprising all the components of the main circuits and auxiliary circuits that contribute to the fulfilment of a single function (current breaking, fuse protection, metering, disconnecting/insulating). There is not always one-to-one correlation between pressurized compartment and functional unit. In Medium Voltage it is possible to have up to 6 functional units into a single pressurized compartment, instead, in High Voltage, it is possible to have only one phase (one third of functional unit) per compartment. T&D Europe suggests reporting on categories of product, number of functional units and associated quantities of substances and proposes to add this specificity in additional paragraph at the beginning of section 11 or in the comment column of the line information to be reported relative to section 11_M. 2. T&D Europe do not understand what is behind the reference 11_M5 Other switchgear for transmission and distribution of electricity as the previous categories 11_M1 to 11_M4 are covering all the ranges of voltage for transmission and distribution switchgear. T&D Europe suggests deleting this category and rename the category 11_N as other switchgear for production of electricity and electrical equipment related to switchgear. This will cover both generator circuit breakers and equipment described in §2.4 of EU report C(2020) 6635. Categories 11_M1 to 11_M4 and11_N will describe all T&D electrical equipment.
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Response to Update of format of F-gas labels

4 Jun 2024

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry, would like to use this opportunity to raise our feedbacks on the format of the labels for certain products and equipment containing fluorinated greenhouse gases and repealing Commission Implementing Regulation (EU) 2015/2068. Key points: 1. The use of digitally readable link mentioned in Art. 1 §10 should not be restricted to small products but should be possible for every product as an option and avoiding the multiplication of other kind of digital links already present on the product. 2. In order to simplify the digital links management, the digital readable link mentioned in Art. 1 §10 should NOT refer to specific quantities such as CO2 equivalent of F-Gas contained in the product, because it will make the link management more complex for each different products that contain different quantities of gas and errors in references can occur more frequently. These quantities shall be displayed on the product... 3. For electrical switchgear the visible label shall be in English and/or, if requested by the operator, the official languages of the Member State in which the good is to be placed on the market.
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

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.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

26 Apr 2023 · Net Zero Industry Act and role of grid technologies in the green transition

T&D Europe seeks flexible F-gas rules for electrical switchgear

29 Jun 2022
Topic — The EU is revising regulations to further reduce fluorinated greenhouse gas emissions.
Message — T&D Europe calls for excluding spare parts and defective equipment from prohibitions to maintain existing grids. They also suggest removing 'open' tender requirements because switchgear markets rely on long pre-qualification processes.12
Why — Manufacturers avoid high costs from changing technologies during ongoing infrastructure delivery contracts.3
Impact — Climate goals may suffer if exemptions allow the continued use of potent greenhouse gases.4
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Meeting with Kadri Simson (Commissioner) and

30 Sept 2021 · Implementation of the Green Deal in the energy sector and the scaling up of investments in clean, resilient, digital electricity system.

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

8 Mar 2021

T&D Europe welcomes the revision of the Trans-European Networks – Energy guidelines proposed by the European Commission (EC), as an essential instrument to strengthen and expand European power grids in the context of the EU’s commitment to climate neutrality. With the European Union on track to reach its 2020 renewable energy target, and renewable power expected to cover more than 60% of electricity demand in 2030, reliable and flexible power grids will be key for a successful energy transition. According to the EC’s own estimates, today’s grid investments have to almost triple and reach more than €65 billion annually in the coming decade to reach 55% greenhouse gas reduction by 2030. Yet, there is no sign that such massive investment is about to happen without policy action. Against that background, T&D Europe supports the adoption of an ambitious TEN-E regulation. Please find attached our position paper that recommends preserving or reinforcing a numberkey elements for preparing Europe energy infrastructure for a climate-neutral energy future. These include the call for - better specifying the sustainability criteria for PCI by adding reduction or avoidance of CO2 emissions among the default selection criteria for all types of projects in article 4. - operationalise the energy efficiency first principle by adding reduced network losses and avoided curtailed energy in the list of default selection criteria for electricity projects. - adding more flexibility in the Smart grids PCI selection criteria by either reducing their number or make some criteria optional - better support for hybrids projects in the Integrated Offshore Renewables Development Plan - establish synergies between TEN-E and TEN-T projects, in particular for building a fast and ultrafast EV charging network enabling cross border travel, that is likely to accelerate the joint deployment of electricity and transport infrastructure We welcome the increased oversight of the European Commission and ACER on the TYNDP planning. The governance of the PCI selection process will benefit from technical experts across different sectors, including technology providers. We commend the proposed tools to accelerate completion time of infrastructure projects. As the Commission points out, in 2020 27% of electricity PCIs were delayed by an average of 17 months. In ACER’s report on PCI progress , a third of electricity projects permitting took more than three years and six months. We believe the total permitting time for electricity projects should not exceed a duration of 24 months. In the context of the deep transformation on the energy system towards further electrification and decarbonisation, the main objective of the TEN-E regulation revision should be future-proofing the grid both on cross-border level by facilitating the transport of renewable energy across countries, and on local level by supporting the deployment of distributed energy and flexibility solutions.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

15 Feb 2021 · Sustainable Finance T&D Europe expressed support for the European Green Deal and the EU’s sustainable finance agenda. They would like manufacturing of electricity transmission & distribution equipment included in the taxonomy classification system.

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

I am responding on behalf of T&D Europe, Europe's grid technology providers. T&D Europe’s members enable the energy transition to a climate-neutral Europe by 2050. Over 200,000 people in our industry manufacture, innovate and supply smart systems for the efficient transmission and distribution of electricity. Our technologies and services future-proof the grid and make clean electricity accessible to all Europeans. We put our collective expertise to work to craft a brighter, electric future. Ready for the Green Deal. As strong supporters of the EU Green Deal and key enablers of the energy transition to a climate-neutral Europe, we ask you to explicitly include the manufacturing of equipment and systems for the management of electricity in a specific section 3.6 named “manufacture of electrical equipment”. This proposed modification captures the enabling role of electrical equipment for climate change mitigation and is compliant with article 10(1) point (i) of Regulation 2020/852 on the establishment of a framework to facilitate sustainable investment.6 This would correspond to the NACE code C27.1 Manufacture of electric motors, generators, transformers and electricity distribution and control apparatus. Furthermore, we believe that this inclusion does not require a complex and in-depth technical assessment. We ask you to consider our proposal. We remain at your disposal for further discussions and our experts are available to provide further input to you and the responsible Commission services. For more details on our request and proposal, which is furthermore supported by 6 other associations in the electricity industry (CAPIEL, CECAPI, CEMEP, EuropeOn, SolarPowerEurope and Wind Europe), I refer to the attached file.
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Response to Review of EU rules on fluorinated greenhouse gases

3 Sept 2020

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry welcomes the opportunity to present its feedback experiences from the current 517/2014 “F-Gas regulation”, specifically regarding aspects of SF6 management. Please see the attachment
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

8 Jul 2020 · Speech on the European Green Deal at T&D Europe's Executive Committee

Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

T&D Europe, the European grid technology providers association, welcomes the review of the Alternative Fuels Infrastructure Directive (AFID) in the spirit of the European Green Deal and the climate-neutrality objective of the EU. Our contribution touches upon the following concerns identified in the roadmap document: 1. National policy frameworks not meeting the expected uptake of alternatively fuelled vehicles and vessels and the ambitions under the Green Deal 2. Lack of comprehensive network connectivity across borders and modes with minimum coherence in the EU 3. The impact of electromobility charging on the electricity networks 1. On this issue, we would like to focus on the low uptake of shore side power infrastructure for ships. Shore connection technologies enables the ships to switch off their engines while docked, eliminating pollution, noise and vibrations. The AFID target was to equip TEN-T core network and other ports by 2025 with electricity at shore-side “unless there is no demand and the costs are disproportionate to the benefits, including environmental benefits” (Article 5). Due to the condition of economic viability overshadowing obvious environmental benefits, few national policy frameworks include the electrification of ports in their plans. 2. An EU-wide harmonised development of network connectivity across borders and modes should in our view be promoted in the revised AFID. The existing system of national policy frameworks (NPF) is a good base to achieve the harmonisation and consistence. However, the system needs to be coupled with binding targets and proper assessment by the Commission to allow a benchmarking exercise among Member States. In order to link the revised AFID to the Green Deal goals, the NPFs should be consistent with the national energy and climate plans (NECPs) drafted by Member States. The final version of NECPs all include targets on take up of electric vehicles (EV). 3. Today, electricity networks are able to cope with the new demand from EV charging. By 2030, this will not be the case anymore. The reason is not only the impact of a higher number of EVs in the market, but first and foremost because electrification will be expanded to a wide range of sectors (heating/cooling, buildings, industry, etc). The intense burden on the network may cause congestion. A German distribution network study shows that under a 100% EV market share, distribution cables and transformers that are loaded at 90% today could experience up to 170% by 2040. Solutions like smart charging can be used to peak shave and thus defer the upgrade of feeder and transformer capacity. However, the first step is to conduct a feasibility strategy to foster network investments to keep up with the joint impact of eMobility and the electrification of domestic loads. We believe two actions are needed to meet this concern: a. Energy regulators need to make a solid assessment of the future requirements of the grid in order to plan the reinforcement needed and assess progress every two years (as required under the Electricity Directive art 59.1 (l)). In addition, the EPBD should be revised to take into account the buildings impact on the network. b. EVs can be enablers of flexibility and play an active part in improving the efficiency of the network. But an important first step is to establish a common protocol and standards to enable the exchange of energy and information between vehicles, chargers and the grid. Harmonised EU standards need to be set for car manufacturers and grid operators. Please find attached our full contribution including our recommendations.
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Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

T&D Europe, the European association of the electricity grid technology providers, is following with interest the assessment and review process of the TEN-E regulation and in particular the provisions on the identification of the projects of common interest for smart grids. With the adoption of the Clean Energy Package, 32% of the energy consumed will have to come from renewables by 2030. This means that more that 45% of the electricity will have to be produced by renewable energy generation. Smart grids are pivotal to integrate such high share of variable generation and enable the transition to a decarbonised power sector. Technology is ready, but its deployment on a large scale requires investment in electricity distribution, transmission and interconnection. Against that background, the TEN-E Regulation is the main European policy tool to support large electricity networks project, thanks to €4.7bn of grants distributed from 2014 to 2020. Transmission and interconnection projects have widely benefited from it, however investment in smart grids has not been visibly boosted. Only four projects appear on the 2017 list of projects of common interest, with an increase to six on the proposed 2019 list. This situation likely results from stringent eligibility criteria for smart grids project in the TEN-E guidelines. In particular, the need for a project to be cross-border, to cover networks above 10kv, in densely populated regions with a high energy consumption, is a clear obstacle for project developers. To match the reality of the power system, the TEN-E regulation should be updated. Modernisation of distribution networks above and below 10kv is necessary to integrate decentralised renewables and keep the lights on at a low-cost for consumers. It is also a prerequisite for increasing the flexibility ofthe power system and let new market players in, such as aggregators. Therefore, T&D Europe invites the European Commission to make the most of the review process to review the eligibility criteria for smart grids projects in the TEN-E guidelines, and open the door to new projects, e.g. DSO-only, at any voltage level. In addition, we would also see a benefit in considering the energy efficiency first principle in selecting the projects in order to support the best available innovation solution in grid technology. By taking these steps, the European Commission could advance the EU decarbonisation goals and support new business models based on flexibility and consumer empowerment.
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Response to Small, medium and large power transformers - Commission Regulation amending Regulation (EU) No 548/2014

21 Nov 2018

I am submitting the comments for T&D Europe Members acting as the Secretary of the Work Group Transformers. I have attached a pdf file that contains T&D Europe's considered comments on the test. Our conclusions is: T&D Europe is in favour of this amendment but strongly requests that the frame of the activity of repair and refurbishment will be limited to avoid the deployment of inefficient transformers on the network. This should allow users to repair their own transformers but not start a new market for inefficient transformers T&D Europe request to change the request concerning the noise measurement by calculation or extrapolation because this measurement is not requested by the standard today and that lead to high extra cost on the transformers.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

15 Nov 2018 · Possible safeguards

Response to Proposal to create a cybersecurity competence network with a European Cybersecurity Research and Competence Centre

23 Apr 2018

Dear Sir, Madam, T&D Europe, the European association of Electrcity grid technology providers, wishes to provide its feedback on the Impact Assessment of the initiative to “Create a cybersecurity competence network with a European Cybersecurity Research and Competence Centre”. Our members are favouring Option 1 and add important recommendations to take into consideration when going forward with a Joint Undertaking structure. Please find our arguments in the document provided in attachement. Kind regards, Laure Dulière T&D Europe Policy Adviser
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Response to Revision of the Shipping MRV Regulation

18 Jul 2017

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry, welcomes the opportunity to respond to the inception impact assessment initiative in the context of the forthcoming revision of the Shipping MRV Regulation. Regarding the question of the alignment of the EU MRV with the global data collection system (DCS), we want to point out the importance of the separate collection of emissions data from ships at berth in EU harbours, as requested in the EU MRV (Art 4, Art 10). The DCS does not specify a separate provision for ships at berth. We ask the EU Commission to consider keeping this separate emission data collection from ships at berth to protect public health and support the emergence of low-emissions maritime transport technology, an essential contribution to the very goal of the Shipping MRV Regulation. The objective of the EU monitoring, reporting and verification (MRV) of shipping emissions is indeed to incentivize emissions reduction. Due to the increase in global maritime transport, CO2 emissions are expected to increase despite the introduction of energy efficiency standards for ships engines. In city ports, CO2 emission and noxious gases have an increasing impact on public health. As an example, a cruise vessel (12 MW) emits during 8 hours at berth 0.2 t of nitrogen oxides (NO X) and 30kg of particulate matter (PM). To tackle these issues further, innovative technology needs to be considered, specifically electrification of harbours. The option of Shore Side Electricity (SSE) to further reduce CO2 emissions from ships while at berth has the potential to successfully support CO2 emissions. In addition to the CO2 reduction, SSE will also heavily contribute to the reduction of Sulphur Oxides (SOx), nitrogen oxides (NOx), particulate matter (PM) from ship emissions and remove noise and vibration from harbours and their waterfronts with immediate and tangible social aspects, while increasing the public acceptance of shipping industry.
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Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

16 Jul 2015 · Anti-dumping proceeding with regard to imports of GOES

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

12 Mar 2015 · Energy Union, infrstructure, smart grids