IFP Energies nouvelles

IFPEN

IFP Energies nouvelles (IFPEN) est un organisme public, acteur majeur de la recherche et de la formation dans les domaines de l’énergie, du transport et de l’environnement.

Lobbying Activity

Response to Circular Economy Act

30 Oct 2025

Hello please find our feedback in the uploaded file enclosed. We keep available for further discussion. Thank you very much in advance Th.Gauthier
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Response to Sustainable transport investment plan

4 Sept 2025

IFP Energies nouvelles welcomes the initiative to establish a European Strategic Transport Investment Plan, especially to meet the objectives set by the ReFuelEU and FuelEU Maritime regulations. To decarbonize various mobility sectors and strengthen Europes energy sovereignty, investments are needed in the e-fuels and advanced biofuels value chains to deploy production units across territories, structure the supply chains for feedstocks, foster the consumption of more environmentally friendly products, and support research and innovation. The attached file provides a more detailled overview of our reflexions on the matter.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

12 Feb 2025

The European regulation on establishing a framework of measures for strengthening the European ecosystem for the manufacturing of net-zero technology products (NZIA) aims to enhance the EU's manufacturing capabilities in essential clean technologies. The regulation takes into account not only the final product but also the main components used for their production. IFP Energies nouvelles (IFPEN) welcomes the implementation of the NZIA regulation, which is intended to enable the development of a sustainable and competitive European industry. The NZIA regulation provides for the adoption of a delegated act identifying, for each sub-category of net zero emission technologies, the final products as well as the components primarily used for these technologies. This delegated act has prompted several comments and proposed amendments from IFPEN, detailled in the attached file.
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Meeting with Marc Lemaitre (Director-General Research and Innovation)

14 Oct 2024 · Echange de vues sur notamment la contribution de la recherche aux grands défis, le continuum de la recherche fondamentale à l’innovation

Meeting with Pascal Canfin (Member of the European Parliament)

29 Nov 2023 · Green Deal

Meeting with Pascal Canfin (Member of the European Parliament) and Confédération française démocratique du travail

27 Nov 2023 · Green Deal

Meeting with Pascal Canfin (Member of the European Parliament)

5 Sept 2023 · Green Deal

Response to Net Zero Industry Act

23 Jun 2023

IFP Energies nouvelles (IFPEN) soutient la proposition de la Commission européenne relative au règlement pour une industrie «zéro net», et propose dans le fichier joint une série de recommandations.
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Response to 2040 Climate Target Plan

23 Jun 2023

IFP Energies nouvelles (IFPEN) soutient linitiative de la Commission européenne de donner un objectif en matière de climat à léchelle de lUnion à lhorizon 2040, et propose dans le fichier joint une série de recommandations.
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Response to Communication on revamping the SET Plan

28 Oct 2022

IFP Energies nouvelles welcomes the opportunity to contribute to the EC Consultations on EU research and energy policy revamping the Strategic Energy Technology Plan, and hereby puts forward a set of recommendations in the attached PDF document.
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Response to Interim evaluation of Horizon Europe

26 Jul 2022

IFP Energies nouvelles welcomes the opportunity to give feedback on Horizon Europe's research & innovation actions funded by the EU in 2021-2023 and hereby puts forward a set of recommendations concerning the key bottlenecks: • Horizon Europe (HE) is an ambitious program that covers all the innovation chain from frontier research to market deployment. However, there is a need to support more collaborative excellence basic research activities below TRL 4 that are essential to the emergence of new ideas and new concepts. Such calls could find their place in each cluster of HE Pillar 2, with dedicated basic research budget. With EU Missions and EU Partnerships mainly proposing projects that are higher in the TRL scale, it is important to ensure a proper coverage of the lower TRLs levels of cross-border collaborative RD&I. However, this dedicated basic research budget should not be taken from applied research projects with a valorisation finality, requiring projects at a higher TRL level, essential to the strengthening of European industrial competitiveness. A balanced representation of basic and applied research, in addition to demonstration and innovation actions should be achieved. • Industry' pilots and demonstration project budgets are often far below the needs of the projects. In such framework, it is important to continue the work of prioritization at the European level, in collaboration with the European Technology and Innovation Platforms (ETIP), to focus the fundings on demonstrators with high European added value. • Europe must continue to promote and to reinforce the existing programs dedicated to the international mobility of students and researchers, since they are the ambassadors within the European Union, and beyond its borders. However, the existing instruments remain complex with very low success rate. This could be improved by bringing greater simplicity into programmes’ implementations and by favouring smaller and more targeted projects. • Horizon Europe has brought novelties and simplifications such as a new approach to partnerships. However, the landscape remains very complex, with related calls emanating from multiple sources such as clusters, partnerships, missions. In such context, it is essential to ensure a good coordination and complementarity of fundings within the framework of the various initiatives or programs, to avoid scattering and to maximize the impact. • It is essential to maintain a good balance between the requirements of intellectual property protection and the development of open science IFP Energies nouvelles welcomes the updated DESCA model and underlines the importance of preventing a weakening of IPRs in EU funded projects. • Public entities should remain owners of the research results they have developed, and protect them with patents, as they play an important role in their credibility and attractiveness. IP management is often criticized as insufficiently detailed in project proposals, and for RTOs like IFP Energies Nouvelles it is currently hard to strike the right balance between the page reduction and the sufficiently detailed paragraphs. • IFP Energies nouvelles expresses its concern about the generalization of the use of lump sum funding for larger consortia, that may result in a risk-averse approach regarding the choice of partners and their collaboration. It is important to avoid negative impact that such decision may induce in terms of widening participation and strengthening collaboration objectives. IFP Energies nouvelles also refers to the recommendations published by the EARTO association, of which it is a member, in association with CESAR and EUA (1). IFP Energies nouvelles remains at the disposal of the EU Institutions to further discuss these recommendations. (1) EARTO Joint Statement with CESAER and EUA – Caution needed on interim analysis of lump sum pilot (22 November 2021)
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Response to A New European Innovation Agenda

9 May 2022

IFP Energies nouvelles welcomes the European Commission’s communication on a New European Innovation Agenda in Q3 2022 and hereby puts forward a set of recommendations concerning the key bottlenecks: • Bringing national and European programs into alignment is essential. The dialog should be established in close collaboration between the European Commission, Members States and innovation providers and users, including the public research organisations and industry, to insure the consistency between the national and European levels. • Existing funding mechanisms and instruments that support research and innovation are not yet fully exploited, especially by VSEs, SMEs, start-ups, often mastering the mechanisms less well. The intermediate role of Research and Technology Organisations (RTOs) is essential for these companies. RTOs can make available their skills and technical resources, to accelerate their innovation projects, help to develop new technologies or bring them to the relevant scales. Access to national financial contributions granted to labelled research structures that support those companies through very complex calculation methods, should be further simplified and encouraged on a European level. • Horizon Europe (HE) is an ambitious program that covers all the innovation chain from frontier research to market deployment. However, there is a need to support more collaborative excellence basic research activities below TRL 4 that are essential to the emergence of new ideas and new concepts. Such calls could find their place in each cluster of HE Pillar 2, with dedicated “basic research” budget. • There are very few funding instruments open to the first-of-a-kind plants, and they are complex and highly competitive. This gap should be filled favouring simplifications and synergies between structural funds and sectoral programmes at national and European level. • Industries that co-invest in costly but essential steps, such as the first-of-a-kind plants in emerging domains (plastics and metal recycling, carbon capture, storage and valorisation, advanced biofuels, etc..) should have simplified access to instruments favouring synergies between European, national and regional initiatives. In such specific contexts, to encourage financial risk-taking of industries that co-invest, the revision of the state aid rules should apply. • The public support is needed not only until the very pre-commercialization phase, but should go further, until established levers are in place (price of CO2, carbon-free product bonus, border tax, etc.) and allow the sectors to be economically viable. • Faced with the complexity of climate change and the achievement of carbon neutrality, research must have the means of observation, analysis and monitoring, from the design phases, through testing and deployment or transition policies. Beyond the regulatory sandboxes, it is necessary to set up a regulatory framework favourable to innovation and to the emergence of new industrial sectors, maintaining as much technology neutrality as possible. This framework should also ensure long-term stability, since frequent revisions can jeopardize emerging ecosystems and value chains (REDII revision). • Europe must continue to promote and to reinforce the existing programs dedicated to the international mobility of students and researchers, since they are the ambassadors within the European Union, and beyond its borders. However, the existing instruments remain complex with very low success rate. This could be improved by bringing greater simplicity into program implementations and by favouring smaller and more targeted projects. • The spin-off system should also be more encouraged, especially the academic spin-off, still confronted to insufficient resources for technology transfer, lack of «seed capital», etc.. IFP Energies nouvelles remains at the disposal of the EU Institutions to further discuss these recommendations.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

17 Jan 2022

IFP Energies nouvelles has analyzed the recast of Commission regulation (EC) No 282/2008 on recycled plastic materials and articles intended to come into contact with foods (consultation document), and would like to bring forward its concern about BHET classification. Our comprehension of the Article 1.2, defining the exception to this new regulation, is as follows: a) PTA and MEG are PET monomers included in the list of authorized substances in accordance with the Article 5 of (EU) 10/2011. Therefore, recycling processes leading to PTA and MEG are out of the new regulation scope. IFP Energies nouvelles agrees with this statement because chemical recycling involves several steps of purifications (such as distillation, adsorption, crystallization, filtration), leading to decontaminated monomers. b) BHET is not explicitly listed in the Article 5 of (UE) 10/2011, although it is a PET monomer (see 1). We understand that recycling processes leading to BHET could therefore fall in the scope of the new regulation. IFP Energies nouvelles considers this statement inconsistent since BHET is purified by the same unit operations as PTA and MEG. All these monomers, PTA, MEG and BHET should thus be treated equally. IFP Energies nouvelles’s Proposal : As BHET falls under the Article 6.3.d of Regulation (EU) 10/2011, describing derogations for substances not covered by the Article 5 of (EU) 10/2011, IFPEN suggests that the Article 1.2 should explicitly mention derogations linked to the Article 6.3.d of Regulation (EU) 10/2011, so that all monomers could be managed under the Article 5 of (EU) 10/2011. To reinforce the validity of these considerations and this proposal, we would like to emphasize that a recycling process through BHET has received authorization for food contact applications by Japanese authorities. Currently, a 20 000 tons per annum industrial plant located near Tokyo, based upon this recycling process through BHET, is running to provide recycled PET for the manufacturing of food grade bottles (see 2). 1 See REACH (Article 3.6), ECHA Guidance for monomers & polymers and IUPAC definitions. 2 See https://www.asahiinryo.co.jp/company/newsrelease/2021/pick_1125.html https://www.sojitz.com/en/news/2021/03/20210319-01.php
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