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European Renewable Energies Federation asbl

EREF

The European Renewable Energies Federation represents national green energy associations across Europe.

Lobbying Activity

EREF calls for unified data infrastructure to scale energy AI

5 Nov 2025
Topic — The consultation seeks to leverage digital technologies and artificial intelligence within the energy sector.
Message — The group proposes a unified data network to overcome national barriers and support AI applications. They advocate for shared technical standards to ensure energy services work across all EU countries.12
Why — Unified standards would lower market entry costs and simplify expansion for independent producers.3
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EREF urges EU to mandate fossil fuel phase-out

9 Oct 2025
Topic — This consultation explores policy options for accelerating the decarbonisation of heating and cooling.
Message — The federation calls for a definitive fossil fuel phase-out and a new European Heat Fund. They also seek rebalanced electricity pricing and legal recognition for heat energy communities.12
Why — This would increase demand for EREF's member technologies and strengthen European manufacturing supply chains.3
Impact — Fossil fuel importers and providers would lose significant subsidies and face shrinking market demand.45
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EREF Urges Renewable-Led Electrification to Ensure Affordable Energy

9 Oct 2025
Topic — A policy initiative to increase electricity’s share in the EU’s final energy consumption.
Message — Electrification must be powered by renewable sources and paired with energy efficiency. EREF proposes rebalancing price ratios between electricity and fossil fuels to promote renewable solutions. Small-scale projects and diverse renewable technologies must also be supported.123
Why — Rebalanced price structures would make renewable electricity investments more competitive for EREF members.45
Impact — Fossil fuel providers would lose their price advantage as tax burdens shift and incentives end.67
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EREF urges longer certification periods for permanent carbon removals

22 Sept 2025
Topic — The consultation establishes methodologies for certifying permanent carbon removals like BioCCS and biochar.
Message — EREF requests extending the certification period to thirty years to ensure investment bankability. They seek priority for BioCCS and alignment with existing renewable energy sustainability criteria.123
Why — This would reduce administrative burdens and provide the predictability required for long-term project financing.4
Impact — Fossil fuel operators would be denied incentives to prevent extending the life of polluting plants.5
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EREF urges stronger market rights for energy citizens and communities

11 Sept 2025
Topic — This consultation addresses consumer empowerment and participation in a just energy transition.
Message — Citizens and communities must be recognised as structural market actors with enforceable rights. Existing laws require effective implementation to allow fair participation in the energy system.12
Why — Independent producers will benefit from new payments for helping balance the grid.3
Impact — Large energy companies lose their dominant position as local projects get fair treatment.4
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EREF urges grid reforms to end renewable connection backlogs

1 Aug 2025
Topic — The European grid package aims to modernize energy infrastructure for a clean, resilient system.
Message — EREF calls for structural reform of grid access prioritizing projects based on technical maturity and climate goals. They advocate for rapid deployment of flexibility and storage solutions to manage renewable integration. The federation also demands fair grid access and dedicated capacity for SMEs and cooperatives.123
Why — Structural reforms would allow renewable producers to bypass backlogs and reduce connection delays.45
Impact — Fossil-fuel plants and speculative developers lose their dominance and priority in grid allocation.67
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EREF urges EU to prioritise renewables over nuclear investments

9 May 2025
Topic — This consultation gathers evidence on investment needs across the European Union's nuclear energy ecosystem.
Message — EREF calls for the EU to prioritise renewable energy and stop equating nuclear power with sustainable solutions. They demand a revision of the EURATOM Treaty to end the privileged status for nuclear projects.123
Why — Renewable energy producers would secure more investment by removing competition from heavily subsidised nuclear projects.4
Impact — The nuclear energy industry would lose the extensive government subsidies and legal privileges it currently enjoys.5
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

EREF welcomes the opportunity to provide feedback on the Commissions Implementing Act on PreQualification and Award Criteria for Renewable Energy Auctions, a crucial step toward strengthening Europe's netzero technology manufacturing ecosystem amid evolving European and global challenges. Our feedback emphasizes that the new rules must avoid duplicating existing national requirements, ensure that cybersecurity compliance is the responsibility of manufacturers, and apply resilience and sustainability criteria uniformly while avoiding additional administrative burdens for SMEs and independent producers. Please find our detailed twopage feedback document attached for your consideration.
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EREF urges exclusion of nuclear and fossil-based hydrogen

25 Oct 2024
Topic — The EU is establishing a methodology for certifying emissions savings from low-carbon fuels.
Message — EREF strongly opposes including nuclear-derived hydrogen and fossil-based hydrogen with carbon capture under low-carbon fuels. They argue public financial support should be reserved for renewable hydrogen.12
Why — This approach directs investments toward renewable technologies and ensures subsidies for their members.34
Impact — Fossil fuel and nuclear producers would be denied access to the low-carbon label.56
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Meeting with Bruno Tobback (Member of the European Parliament)

14 Oct 2024 · Renewable Energy

Renewable Energy Federation calls for overhaul of EU auctions

1 Mar 2024
Topic — This consultation concerns EU guidance on designing criteria for renewable energy auctions.
Message — EREF calls for phasing out mandatory bidding and making technology-specific support the rule. They advocate for higher exemption thresholds and tracking the entire European supply chain.123
Why — Smaller independent producers would avoid prohibitive upfront costs and unfair competition from giants.45
Impact — Non-European component suppliers and large state-backed firms would lose their market dominance.67
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

EREF welcomes the plans to accelerate and simplify permit granting procedures for renewable energy development, as foreseen in the amended Renewable Energy Directive (REDIII). With climate change progressing faster than envisaged, decarbonisation of our societies and industries must take place much faster. And for this ambitious task and to reach greater energy independency, EREF underlines that all renewable energy technologies must be used. Consequently, as introduction of our proposals for a good guidance document, we emphasize that acceleration areas have to be open for all renewable energy sources. Please see our detailed recommendations on renewable energy technologies as well as procedures in the attached document.
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Meeting with Jens Geier (Member of the European Parliament)

23 Jan 2024 · Exchange on the electricity market

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

5 Dec 2023 · Presentation of EREF/CNF report and ideas to support resilience of EU supply chains for strategic net-zero technologies.

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

3 Aug 2023

Despite a legally binding overall climate neutrality target (European Climate Law), there are neither national climate neutrality targets nor a framework to set binding national reduction targets for after 2030. Even if 13 EU countries have set these national targets for themselves, significant inconsistencies still exist across Member states in terms of standards of national climate ambition and governance enabling conditions. EREF therefore recommends amending the Governance Regulation to introduce economy-wide national climate neutrality targets for each Member State including national binding energy and national binding sectoral targets (for ESR and non-ESR sectors) including the development of detailed plans to achieve those sectoral targets. EREF has always advocated for binding national targets as enforcement measures of last resort. Despite these binding targets, four EU Member States (Ireland, Netherlands, Romania and France) were in 2021 below their 2020 target. Two and a half years later (summer 2023), it is still not clear what steps will be taken to ensure these Member States are no longer below their national trajectory. This demonstrates that the delivery gap mechanism (Article 32) is not working properly. Not only do we need quicker intervention, but there also needs to be much more transparency about discussions between the European Commission and the Member States. Additionally, the Commission needs to have the possibility to call for stricter measures whenever a Member State is below its trajectory for its 2030 national renewable energy contribution. In addition, the Governance Regulation needs to be amended to the new elements added under the revision of the Renewable Energy Directive (RED): 1) The revised RED includes an additional non-binding top up target of 2,5%, but the revised RED itself will not give clarity on how this part of the target will be met. The Governance Regulation needs to include what kind of additional measures will be taken to achieve this non-binding part of the 2030 EU renewable energy target. 2) New and revised policies will require changes in the NECPs template (Annex I) to give a boost to renewables. Particular attention should be given to streamlined admin procedures and permitting (including key performance indicators) and planning to accelerate the deployment of all available renewable sources to deliver the energy transition. The assessment of the first National Energy and Climate Plans (NECPs) shows that their current design is insufficient to address the remaining gap between measures and objectives. EREF calls for the strengthening of the monitoring and reporting processes of the implementation of the NECPs. The original NECP template in Annex I of the Governance Regulation from 2018 needs to be updated with respect to recent and ongoing changes in EU legislation of the Fit for 55% and REPowerEU packages. Special attention should be given to a clear methodology relating to financing measures, as well as policies, timelines and measures to phase out of subsidies for fossil fuel sand nuclear energy. During the RED revision, there have been several attempts to dilute. The articles in the Governance Regulation which relate to renewable energy should remain firmly focused on renewables. The Member States contribution setting process in the area of renewable energy (Article 5) and the Annex with the formula for calculating national contributions for the renewable energy share (Annex II) should not be weakened. Any attempts to dilute the RED by adding low carbon fuels in the provisions must be rejected.
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Renewable energy federation demands 95% EU climate target

23 Jun 2023
Topic — The EU is establishing a 2040 climate target to achieve climate neutrality by 2050.
Message — EREF recommends setting a 2040 emission reduction target of 90% to 95% and at least 80% renewable energy. They urge the re-installation of legally binding national targets to ensure investment security. The federation also warns against carbon removal technologies, preferring nature-based solutions to avoid fossil fuel lock-in.123
Why — Binding national targets and a fossil fuel phase-out would provide long-term security for renewable project developers.4
Impact — Fossil fuel and nuclear industries lose out as EREF demands an end to their subsidies and market promotion.5
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EREF urges EU to fast-track all renewable energy permitting processes

12 Apr 2022
Topic — The Commission is drafting guidance to streamline permitting and power purchase agreements for renewables.
Message — EREF calls for renewable projects to be recognized as having overriding public interest. They demand simplified permitting through one-stop-shops and relaxation of state aid rules.12
Why — Producers avoid financial losses from administrative delays and technology becoming outdated before approval.3
Impact — Conservation groups lose the ability to block projects located in protected environmental areas.4
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

EREF welcomes the COM proposal to reduce GHG emissions by at least 55% by 2030. This is the minimum necessary. COM should consider that the EP ENVI asked for at least 60% and that there are numerous calls for at least 65% GHG emission reductions; at least 45% renewable energy; and at least 40% energy savings. Therefore, the proposal for a reduction must go hand in hand with an ongoing assessment on whether the reduction target is sufficient for reaching the Paris Agreement obligations and whether the steps to achieve the goals are on track. When setting trajectories, we urge COM to focus the overall strategy to reduce GHG emissions and reach climate neutrality on avoiding emissions rather than later removing them from the atmosphere for storage and/or usage. In order to be able to achieve a GHG reduction target of at least 55% by 2030 compared to 1990, the existing 2030 targets for renewable energies and energy efficiency need to be increased. The technologies for achieving a higher share of renewable energy generation are mature and available at low cost in the form of wind turbines, PV systems, biomass and hydropower systems and other renewable energy technologies in all end-use sectors. EREF strongly regrets that no binding targets for Member States are included in RED II. When revising RED II, the role of distributed and decentralized energy generation from renewable energies and community self-sufficiency should also be strengthened. To ensure that the transformation to a fully renewables-based system can take place at the pace required, communities and local governments must be involved. Community energy projects increase the public support for the energy transition. Art. 22, 23 of the Directive already build a strong base for Renewable Energy Communities, but their lacking transposition needs further assessment by COM. Regarding Art. 4, EREF believes that Member States should maintain the right of flexibility on how they design their respective renewable energy mix. This is the most efficient way of reaching the 100% RES target whilst taking the country-specific differences in to account. The permitting process for new and repowered renewable projects remains too complex and lengthy despite the provisions in Art. 16, 17. Unclear regulatory frameworks and delays in legislation exacerbate investor uncertainty. Without permits, the renewable energy volumes spelled out in the NECPs remain academic. The revision of RED II also needs to lead to a more transparent framework for Guarantees of Origin (GOs) in Art. 19. GOs are crucial to evidence the consumption of renewable energy. In order to avoid greenwashing, clear rules to guarantee the traceability and to ensure issuance of GOs to all renewable energy producers, with a consistent approach across all Members States, should be implemented. According to the Inception Impact Assessment, elements from the EU strategies on Energy System Integration and Hydrogen should be considered in the revision of RED II. The building and transport sector in particular have enormous potential for an increased use of renewable energies. The sector-wide expansion of renewable energies would also contribute to increased sector coupling and thus to an increase in the resilience of the energy system. Locally produced green hydrogen is an option for complementing renewable deployment but is by no means a silver bullet for the energy transition. As the projected demands for hydrogen far outweighs the projected capacity to produce green hydrogen, it is important to focus on two elements: upscaling the renewable energy development and limiting the use of hydrogen to those areas where it really is the best or only available energy source to replace fossil energies. As a general approach for the Green Recovery from COVID 19, the Just Transition Fund and the EU Hydrogen Strategy, we strongly urge COM to adhere to a strict fossil energy phase out and all direct or indirect fossil subsidisation.
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EREF urges renewable-led approach to EU energy sector integration

8 Jun 2020
Topic — A policy strategy linking energy sectors to achieve deeper decarbonization and secure supply.
Message — EREF advocates for a market design prioritizing renewables and flexibility while phasing out fossil fuels. They request EU guidelines to ensure energy storage is fairly rewarded for its system services. All future gases should be renewable, specifically green hydrogen.123
Why — These measures would ensure renewable energy producers receive fair market value and improved network access.4
Impact — Fossil fuel and nuclear plants lose out as the strategy targets inflexible overcapacity for reduction.5
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Response to Union renewable Financing mechanism

3 Jun 2020

EREF welcomes the establishment of a new EU financing mechanism for renewable energy, assisting the EU in attaining its energy and climate goals. In order to meet the upcoming 2030 and 2050 targets, a considerable expansion of renewable energy deployment both at EU and national level must take place. EREF supports the goals and ambitions of the financing mechanism, in particular its “enabling function”, and the fact that it is in principle open to all renewable technologies and the possibility for specific grants for small-scale and innovative projects as well as for medium and large-scale ones. The inclusion of the private sector as a source of finance for the projects may prove to be a safe way to invest in renewable energy. However, this draft leaves certain key questions unanswered, and there is need for further clarification. As several options for renewable energy are moving towards subsidy-free, how will this work in practice? Can only options in need of subsidies be part of this mechanism? What about differences between the Member States? Will Member States delay their participation until it becomes clear they will miss their targets? Concerning the eligibility and the selection criteria in an EU call under the new mechanism, what should be the minimum (licensing) maturity of a project that will be allowed to participate in the call? Or, should there be other selection criteria, besides the bidding price? Should environmental criteria be set in case of equal bidding prices? Moreover, there is a need to clarify if and how crucial RES enabler projects, such as storage, grid reinforcement/upgrading/expansion, and interconnection with RES-rich remote regions and islands, fit in this new programme – in our opinion they should definitely be included.. Furthermore, the following considerations should be taken into account: o The participation of third countries in the mechanism (as possible RES project hosts) should be examined carefully, on a case by case basis. It should, in general, be limited and should only concern third countries respecting the Community energy acquis communautaire, such as, for example, the countries of the Energy Community. o All Member States should be given the same opportunities, as well as fair and equitable access to this new RES financing tool. In this context, individual Member State parameters that are not controlled by the project promoters should be internalized in the calls, so as to establish a level-playing field for competition among all project promoters. o It is crucial to ensure that the mechanism is offered under attractive terms and conditions and to secure increased participation. This can be achieved by providing the Member States with additional incentives, as well as by providing more transparency and more detail regarding all stages of the functioning of the mechanism. o The Draft Implementing Regulation must include specific provisions to safeguard the viability of the calls for expression of interest and the benefits of all involved parties, namely the contributing Member States, host Member State(s) and project promoters. The successful participation of a minimum number of companies from the host country is highly desirable in all these EU calls, in order to increase acceptance, local value and speedy realization of a winning project. o There is no reference to renewable energy communities, which represent vital players in the energy transition. In order to achieve equal footing it is crucial that RECs are included in the financing mechanism, and that the necessary financial tools are made available. o Projects should not be granted simply due to lowest price, but should take into account the reduction of CO2 and the kWh produced from renewable sources. Please note these proposals originated from GAREP, one of our members, their views & proposals on the new union renewable energy financing mechanism. This document is attached to our feedback.
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Response to Climate Law

1 May 2020

The Climate Law’s aim is to enshrine the goal of climate neutrality by 2050 into legislation and to set out the conditions for a fair and effective and transition to guide all policies. EREF welcomes the 5 year interval for the trajectory assessment as well as the proposed early revision by June 2021, adjusting measures where necessary to make it an effective tool. However, the proposal remains vague and fails to cover urgent issues. It fails to set a clear roadmap on how climate neutrality should be achieved – by binding targets and milestones for investing in renewable energies (RES) and energy efficiency (EE) whilst phasing out fossil-fuels. The proposal lacks the introduction of a clear priority of RES and EE as those technologies and instruments which guarantee adherence to the DNSH-principle in the cross-policy approach of the European Green Deal. In order to develop a comprehensive pathway for decarbonising our economy, the GHG reduction target needs to be combined with higher targets for the development of RES and EE. EREF deplores that the Renewable Energy Directive (Recast) as well as the to be amended Governance Regulation failed to introduce binding targets. The Climate Law proposal widens the reliability and robustness gap as it maintains the weak non-binding Member State target approach. The deficits are in direct contradiction to the Climate Law’s own commitment to determine the necessary measures based on science (Art. 7 of the proposal). Setting the target between 50-55% doesn’t reflect the scientific knowledge available. It is pointless to set a range for the target as there is no need for a cap on GHG reduction. A binding target of at least 55% for 2030 is necessary. The COM should consider that there are already calls for at least 65% GHG reductions (i.e. by the EP rapporteur for the Climate Law); at least 45% RES and at least 40% energy savings. The criterion for climate neutrality must be clearly defined as “no emissions” instead of “shall be balanced” as laid out in Art. 2 (1) of the proposal. The law should require avoiding emissions rather than later removing them from the atmosphere for storage and/or usage. This is inexplicable as a 2016 report commissioned by COM found that 85% of carbon offset programs analysed overestimated their reduction benefits at best and at worst failed to reduce emissions at all. It is incomprehensible that the proposal defines its scope solely as reducing GHG and enhancing GHG removals without referring to a sustainable energy transition (Art. 1).The IPCC Special Report on the impacts of global warming underlines that the overall feasibility of solar, wind and storage technologies has improved dramatically over the past years, while nuclear and CCS haven’t shown similar improvements. Energy efficiency in industry is more economically feasible and helps enable industrial system transitions. The proposal also lacks commitment to a fossil fuel phase-out. Since fossil fuels are responsible for a large proportion of GHG emissions, phasing out should be a priority. Instead, a recent report by the Global Energy Monitor identified investment plans of €117 billion into new gas-fired power plants, LNG import terminals, and gas pipelines in Europe. Given the rapid technology development and cost decrease of RES technology, there is no need to lock in gas as another “bridge technology”. The proposal lacks clear enforceability regarding national measures. It remains unclear how the Member State obligation in Art. 4 (2) relate to the NECPs referred to in Art. 6 (1) of the proposal. Once the NECPs are accepted by the COM, they should become mandatory, subject to infringement procedures and potential penalties. The wording of Art. 5 (3) for the assessment of EU progress and measures clearly points to enforceability. The same should be adopted for Art. 6 regarding the assessment of national measures which currently only lay out the preliminary proceedings of an infringement procedure.
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Response to Climate Law

4 Feb 2020

In order to meet the challenges of global warming and to ensure the EU has a leading role in achieving a climate-neutral economy, a comprehensive long-term strategy is needed in the EU as a whole and in all MS. This can only succeed if clear goals, limits and criteria are set at an EU level and a MS level. The Climate Law must provide clear targets, milestones and trajectories for the EU and for the MS. A law with loopholes and undefined legal terms would only be a postponement of the long overdue debate. The legislative framework needs to convey clarity that no support for new coal, gas or nuclear is allowed, except for phasing out. Net-Zero for 2050: The criteria for climate neutrality must be clearly defined as “no emissions”. The law should require avoiding emissions rather than later removing them from the atmosphere for storage and/or usage. Removal and sequestration measures will probably be necessary to mitigate historic emissions and for industrial processes, where no GHG-free technologies exists or are not yet mature. Sequestration faces challenges in terms of technology, costs, planning, and in public acceptance. Carbon removal cannot be used as an arbitrary compensation option for future investments, but only as a limited solution for technologies (not yet) available. Capture and sequestration is not a pretext for continued use and further lock-in of emitting technologies, particularly where renewable energies are available, cleaner and affordable. EREF calls for a GHG reduction of at least 55% for 2030. A higher target of 65 % as called for by NGOs would be preferable to give strong incentives to the European industry. Targets, milestones, trajectories, related policies, regulatory and financial frameworks must be developed and agreed within the present term of the European Commission and Parliament. Fast and steep uptake of renewables and energy efficiency needs to be triggered before 2025. To develop a comprehensive and meaningful strategic pathway for decarbonising our economy, a strategic agenda for accelerating renewables deployment across all sectors, the GHG reduction target needs to be combined with higher targets for renewable energies and energy efficiency. Building on the existing Governance Regulation, MS should be obliged to present and regularly update their NECPs including milestones, sectoral targets and policy frameworks. Once accepted by the Commission the NECPs should become mandatory and subject to infringement procedures and penalties. EREF believes that MS should maintain the right of flexibility designing their respective renewable energy mix and support scheme mechanism. This is the most efficient way of reaching the 100% RES target. The support and promotion of conventional energy such as fossil and nuclear energy must be strongly discouraged. We agree with the EIB's assessment that continued investment in conventional energy infrastructure will lock in GHG emissions for decades. Future-oriented action means investing in innovation, e.g. renewables and efficiency as well as system integration. The need for this legislative anchoring is obvious in the light of announcements of an energy transition using gas power as a “bridge technology”. Considering the rapid technology development and cost decrease of renewable energy, locking in gas as a “bridge technology” would result in billions of stranded investment and require another expensive phase-out strategy like the ones for nuclear and coal. Therefore, investments should be redirected and focus on the rapid uptake of renewable energies and energy efficiency, aiming at a 100% renewable system well before 2050. The Just Transition Fund should secure sufficient means for job-generating measures to achieve a long-term effect in the affected regions. The EU needs to avoid competition within the regional transformation needs. The Fund should not be restricted to coal but also start helping regions which phase out nuclear energy.
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Meeting with Dominique Ristori (Director-General Energy)

18 Jun 2018 · clean energy issues in Europe

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

23 Nov 2016 · renewable energies

Meeting with Dominique Ristori (Director-General Energy) and Greenpeace European Unit and Friends of the Earth Europe

8 Nov 2016 · Energy Union, renewable energy, energy efficiency

Meeting with Dominique Ristori (Director-General Energy) and WindEurope and

21 Jun 2016 · European renewables industry

Meeting with Miguel Arias Cañete (Commissioner)

26 Jan 2016 · Keynote speech at the new year's reception of the European Renewable Energy Federation (EREF)

Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete) and German Renewable Energy Federation

29 Apr 2015 · Proposals on renewable energy pursuant to the Energy Union Strategy

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

8 Jan 2015 · Energy Union