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Repsol, S.A.

Repsol

Repsol is a multi-energy company leading the energy transition to become net-zero by 2050.

Lobbying Activity

Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union) and ENEL SpA and

9 Dec 2025 · Meeting with representatives of 9 European multinationals on Pillar Two, "Side-by-Side" approach & a level playing field

Repsol demands simpler EU Taxonomy rules to support industry

5 Dec 2025
Topic — EU review of technical standards for identifying environmentally sustainable economic activities.
Message — Repsol requests simpler environmental criteria to reduce burdens and align with EU laws. They advocate for technological neutrality by including low-carbon fuels and carbon capture. They also suggest more realistic timelines for climate risk assessments and reporting.123
Why — Simplified rules would reduce compliance costs and unlock funding for Repsol’s energy projects.4
Impact — Climate advocates lose as Repsol seeks lower emission thresholds and inclusion of fossil fuels.56
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

5 Dec 2025 · EU tax matters linked to energy and direct taxation

Repsol urges EU to prioritize chemical recycling in Circular Economy Act

6 Nov 2025
Topic — New EU regulation establishing frameworks for secondary raw materials and circular economy.
Message — Repsol requests harmonized end-of-waste criteria across the EU and revision of the waste hierarchy to prioritize advanced circular technologies like gasification above traditional energy recovery. They call for flexible mass balance methodologies for chemical recycling and regulatory coherence across EU frameworks.123
Why — This would reduce compliance costs and enable their gasification projects to compete more favorably.45
Impact — Traditional mechanical recycling operators lose if yield thresholds favor chemical recycling technologies.6
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Repsol urges greater industry focus in Horizon Europe

6 Nov 2025
Topic — EU research and innovation funding programme for 2028-2034.
Message — Repsol requests that Horizon Europe better integrate economic feasibility and scalability into project evaluation. They want assessment frameworks to include cost-effectiveness, market potential, and investment readiness indicators. The company advocates for stronger industry participation mechanisms and transparent performance indicators tracking economic and environmental outcomes.123
Why — This would increase funding for projects aligned with industrial deployment that Repsol could commercially scale.45
Impact — Academic institutions lose advantage if economic viability becomes prioritized over scientific excellence.67
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Repsol urges grants and clarity in EU Competitiveness Fund

6 Nov 2025
Topic — EU long-term budget proposals for post-2027 period supporting competitiveness.
Message — Repsol requests the European Competitiveness Fund build on proven instruments like Horizon Europe and Innovation Fund, maintain grant-based support for capital-intensive decarbonization projects, and ensure clear coordination between EU and national funding. They want the Competitiveness Seal operationally defined and agreed with Member States.1234
Why — This would preserve accessible funding for their high-cost refining and chemical decarbonization projects.567
Impact — Industries needing early-stage support lose if grants shift toward repayable finance instruments.89
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Meeting with Maroš Šefčovič (Commissioner) and

28 Oct 2025 · Priorities of the EU’s trade agenda

Meeting with Peter Liese (Member of the European Parliament)

16 Oct 2025 · Austausch

Repsol calls for market-based CO2 transport network development

11 Sept 2025
Topic — EU legislative initiative on CO2 transportation infrastructure and carbon markets.
Message — Repsol requests that CO2 network development focus on industrial clusters with comprehensive cost-benefit analysis of transport alternatives. They advocate for market-based regimes, tax incentives, and Carbon Contracts for Difference to stimulate investment while avoiding underutilized assets.123
Why — This would reduce infrastructure costs borne by industry and protect competitiveness.45
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Repsol urges EU to recognise biofuels and e-fuels in corporate fleet rules

8 Sept 2025
Topic — New EU regulation setting minimum requirements for zero-emission vehicles in corporate fleets.
Message — Repsol requests a technology-neutral approach that recognises CO2 neutral fuels (biofuels and e-fuels) as zero-emission solutions alongside electrification. They argue the current focus on a single technology pathway undermines decarbonisation objectives and increases costs.123
Why — This would protect Repsol's €2.2 million tonne renewable fuels production capacity and maintain road transport demand.4567
Impact — Electric vehicle manufacturers lose competitive advantage from exclusive zero-emission vehicle mandates for corporate fleets.8
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Repsol urges EU to include road transport in investment plan

4 Sept 2025
Topic — This initiative creates a framework to boost investment in renewable aviation and waterborne transport fuels.
Message — Repsol requests that renewable fuels be recognized for all transport modes, including the road sector, to achieve economies of scale. They advocate for a revised energy taxation framework and stable demand signals to support industrial transition.12
Why — Including road transport reduces financial risks and allows Repsol to maximize its current production capacity.3
Impact — Foreign fossil fuel suppliers lose influence as the EU prioritizes domestic energy security and independence.4
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Meeting with Beatriz Yordi (Director Climate Action)

2 Sept 2025 · Ecoplanta Molecular Recycling Solution

Repsol Urges Expanded Chemical Coverage in EU ETS Aid

22 Aug 2025
Topic — Revision of ETS State Aid Guidelines to address carbon leakage risks.
Message — The company requests harmonized implementation across Member States with updated emission factors, expanded eligibility for chemical sectors including additional polyolefins and organic chemicals, and adequate national budgets to avoid pro-rata reductions in compensation.123
Why — This would reduce their electricity cost burden and provide investment certainty for low-carbon technologies.45
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Repsol Urges Flexible EU Rules for Chemical Plastic Recycling

18 Aug 2025
Topic — The consultation establishes rules for calculating and reporting recycled content in plastic bottles.
Message — Repsol seeks a broader recycling definition and a flexible credit-based accounting method. They want to use existing petrochemical infrastructure to process multiple waste streams.12
Why — Repsol would avoid expensive new investments by integrating recycling into its existing refineries.3
Impact — Non-EU exporters would face tougher entry requirements under Repsol’s proposed enforcement framework.4
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Repsol Urges More Flexibility and Scale-Up Support in Innovation Fund

7 Jul 2025
Topic — This consultation evaluates the effectiveness and operational performance of the EU Innovation Fund.
Message — Repsol requests easier ways to combine EU grants with national funding. They want more flexibility to adjust project budgets for inflation. The company also advocates for funding that supports scaling up proven technologies.123
Why — This would allow Repsol to secure more public money and protect their expensive projects.4
Impact — Breakthrough startups lose if funding shifts from radical innovations to incremental industrial upgrades.5
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Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

1 Jul 2025 · Bio-diesel and Sustainable Aviation Fuels (SAF).

Meeting with Elisa Roller (Director Secretariat-General)

1 Jul 2025 · Clean Transition, Sustainable transport

Meeting with Cristina Lobillo Borrero (Director Energy)

26 Jun 2025 · Roadmap, Omnibus package

Repsol urges EU action plan for fuel industry bioeconomy transition

23 Jun 2025
Topic — The consultation explores strategies for a circular, regenerative, and competitive European bioeconomy.
Message — Repsol requests an EU Action Plan for the transition of the fuel manufacturing industry. They support repurposing refineries to utilize bio-based feedstocks and demand harmonized end-of-waste criteria.123
Why — Repsol would lower costs and risks by repurposing refineries for bio-based feedstocks.4
Impact — Synthetic chemical manufacturers lose market share as organic fertilizers reduce dependence on chemicals.5
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Repsol urges EU to drop mandatory two-factor authentication requirement

17 Jun 2025
Topic — The consultation defines interoperability requirements for data access during electricity supplier switching.
Message — Repsol requests that the Commission reconsider mandatory two-factor authentication for customer switches. They claim the requirement adds complexity and administrative barriers that slow down the process.12
Why — Avoiding this requirement saves the company from expensive and difficult system overhauls.3
Impact — Consumers and regulators lose a robust security layer designed to prevent fraudulent energy account transfers.4
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Meeting with Bernardus Zuijdendorp (Head of Unit Taxation and Customs Union) and IBERDROLA and

26 May 2025 · Exchange of views on the need and prospects for simplification in Pillar 2, in particular in light of the current situation with the US

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra) and ENEL SpA and

26 May 2025 · Exchange of views on the need and prospects for simplification in Pillar 2, in particular in light of the current situation with the US

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

7 May 2025 · Renewable fuels in the EU's road transport decarbonisation

Meeting with Andrea Wechsler (Member of the European Parliament) and International Lead Association

7 May 2025 · EU Energy and industry policy

Meeting with Oihane Agirregoitia Martínez (Member of the European Parliament)

7 May 2025 · Energy

Meeting with Pietro Fiocchi (Member of the European Parliament)

7 May 2025 · Carburanti rinnovabili e CO2 emission

Meeting with Eva Maydell (Member of the European Parliament)

7 May 2025 · General Exchange

Meeting with Ana Vasconcelos (Member of the European Parliament)

23 Apr 2025 · Competitiveness Compass and the Clean Industrial Deal

Response to Interim evaluation of the Strategic Technologies for Europe Platform (2024-2025)

9 Apr 2025

We appreciate the opportunity to comment on the implementation and capabilities of the STEP label for Strategic Technologies. We welcome the label as it facilitates the identification of strategic projects that pragmatically contribute to the resilience of the EU economy, based on high-quality business cases, maturity, and innovation. Since it is in its first year of implementation, it is time to materialize and catalyze its potential through financial institutions, equity investors, and targeted fund programs. The label should be a clear sign for Member States to incentivize the alignment of national funds with EU funds, a matter currently under review through the consultation on the Clean Industrial State Aid Framework. Additionally, the label aims to guarantee that the recognized strategic technologies can benefit from accelerated permits. Faster processing would reduce the risk of these projects and align risk profiles with investors and the financial community. Given the importance of the STEP label, it must reach investors and financial institutions, promoting its high-quality guarantee after undergoing an EC due diligence process for all projects awarded with the label. Repsol has obtained the STEP label for the project TarraCO2storage. In our initial engagements with large commercial banks, awareness of the STEP label was low, and we introduced its significance. We advise the European Commission to organize sessions with financial institutions and key equity investors to explain the label. We believe the STEP label must also catalyze other projects that can be in the same value chain, allowing participation in additional funding programs. We welcome the proposal of a unique platform aggregating all possible funds based on technology, as this would strengthen mature projects. At this stage, it is worth mentioning that some funds, such as cohesion funds and the Recovery and Resilience Facility, are better known at the Member State level than by companies, for a lack of information down the chain. Member States should facilitate more opportunities for these funds. For this reason, we encourage the European Commission to incentivize Member States to allocate a percentage of these funds to STEP projects, as the industries covered are crucial for EU competitiveness. Finally, based on the relationship with the European Investment Bank, the STEP label could act as a facilitator to identify the best financial opportunities and respond to investor appetite. We propose that those projects that are particularly excellent in EU funding programs, receive a gold STEP label to facilitate the connection between investors and developers.
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Meeting with Laura Ballarín Cereza (Member of the European Parliament)

8 Apr 2025 · Green Transition in Energy

Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

1 Apr 2025 · Repsol decarbonization projects, focusing on renewable and next generation fuels.

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

Repsol welcomes the simplification efforts of the European Union to relieve the burden on companies by reducing their reporting obligations and the consultation on the Taxonomy Simplification OMNIBUS proposal. Our company shares the interest of the European Commission in reducing red tape for compliant companies and see a certain amount of relief in the current Omnibus package. Therefore, Repsol wishes to share its views concerning some potential amendments along with some context and remarks to help our answers to be better understood, in the attached document.
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Meeting with Sérgio Humberto (Member of the European Parliament) and European Patient Organisation for Dysimmune and Inflammatory Neuropathies

25 Mar 2025 · Presenting the organization to the office.

Meeting with Stéphane Séjourné (Executive Vice-President) and

14 Mar 2025 · Visit to the Hydrogen Valley Project / Petrochemical Hub Tarragona

Meeting with Dan Jørgensen (Commissioner) and

7 Mar 2025 · Fuels

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

3 Mar 2025 · Energy

Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

We appreciate the opportunity to participate in this public consultation on the draft of the Implementing Act on non-price criteria that broadens the scope and definition of renewable energy auctions for net-zero technologies according to Regulation (EU) 2024/1735. We would like to highlight that auctions should consider the maturity level of eligible technologies. There are technologies in an early development stage (e.g., hydrogen, floating offshore wind) or in initial implementation phases (e.g., biomethane in many countries), so non-price criteria could also be relevant. A more detailed European Guidelines or Recommendations for the application of the Delegated Act could be useful to reduce the degree of interpretation of the regulation. These Guidelines could address the characteristics of the auction (e.g., aimed at a technology or subset), an energy sector (such as electricity or gas), consider the demand, be absolutely horizontal, or differentiate between pre-classification and selection criteria and their effects. Regarding the sustainability-related selection principles defined: - In relation to the carbon footprint (Art. 8), calculated in CO2 equivalent emissions, it is important to value the reduction of methane emissions due to its greater short-term warming containment effect. - On circular economy (Art. 9), beyond reuse, it is worth better scoring those technologies that use fewer rare or critical minerals, or for their ease of dismantling. Regarding the integration of energy systems (Art. 15), paragraph 4 on system connection refers to the capacity to transfer renewable energy from one energy vector to another. However, it should also be valued: - The efficiency of such transfer between vectors. - The consideration that it does not hinder the integration of other renewables. For example, we can compare biogas versus biomethane for this purpose. Biogas production, with a flat profile, is usually dedicated to electricity production in electric engines. Consequently, electricity production is flat, displacing either renewable electricity (more economical alternative) or thermal generation, usually more efficient (higher efficiency combined cycles). - Finally, a criterion should be incorporated that maximizes the potential use of the energy vector, given that an investment that includes an upgrading module to biomethane for injection into the grid is likely to reach a greater number of users/needs than biogas self-consumption. On the ability to deliver criteria, evaluating developers' experience and technical capacity is key to assessing their ability to deliver, but limited information, especially about suppliers and contractors, can make this challenging during tendering. In sectors like offshore wind, an early detailed project description could restrict technology choices later and innovation. Therefore, we recommend reassessing certain criteria at a later stage when more detailed information is available. On the resilience criteria, we emphasize promoting industry and autonomy in the European supply chain. Nevertheless, this may limit developers' flexibility in selecting efficient suppliers. We suggest considering local supply chain promotion as an award criterion to incentivize local industry without restricting supplier selection. This could lead to more competitive proposals and minimize supply chain disruption risks. Additionally, other possible criteria that could be included under Art.26.2 of Regulation 2024/1735 should be mentioned: - Socioeconomic criteria, such as, avoiding jobs losses or fostering new employment, especially highlighting the permanent and stable nature at the local level (i.e., during the plant's useful life, not only during design and installation), given that there are significant variations by technology regarding local employment linked to operation and maintenance. - Adherence to good practices/responsible development criteria.
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Meeting with Maravillas Abadía Jover (Member of the European Parliament)

12 Feb 2025 · Futuro de la industria del automóvil

Meeting with Bruno Gonçalves (Member of the European Parliament)

12 Feb 2025 · ITRE policies

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

11 Feb 2025 · Competitiveness Compass, Clean Industrial Deal

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

13 Dec 2024 · Energy transition

Meeting with Oihane Agirregoitia Martínez (Member of the European Parliament)

10 Dec 2024 · Energía

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and TotalEnergies SE and

6 Dec 2024 · Investments in sustainable liquid fuels production in the EU

Meeting with Rosa Serrano Sierra (Member of the European Parliament) and Ecologistas en Accion

2 Dec 2024 · Priorities for European Commission 2024-2029

Meeting with Susana Solís Pérez (Member of the European Parliament)

13 Nov 2024 · Neutral Fuels

Repsol urges more flexible deadlines for Union Database compliance

7 Nov 2024
Topic — Extending the Union Database scope to cover raw material production and collection.
Message — Repsol requests clearer definitions for traders and more time to report transactions. They argue the current three-day window is an impossible administrative burden for many.12
Why — This would lower administrative costs and protect the company from unfair suspensions.3
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Repsol urges alignment between low-carbon and renewable fuel methodologies

25 Oct 2024
Topic — This consultation establishes a lifecycle assessment methodology for greenhouse gas emission savings.
Message — Repsol requests a level playing field by aligning the low-carbon fuel methodology with existing renewable fuel regulations. They advocate for including carbon capture credits across all fuel categories and avoiding double counting in multi-energy processes.123
Why — Aligning regulations would allow the company to count diverse carbon sources toward emission targets.4
Impact — Environmental groups lose if carbon credits are granted without guarantees of permanent storage.5
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Meeting with Borja Giménez Larraz (Member of the European Parliament)

16 Oct 2024 · Repsol priorities

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

15 Oct 2024 · Introduction

Repsol urges inclusion of renewable fuels in car labelling system

16 Apr 2024
Topic — EU directive on consumer information for fuel economy and CO2 emissions in new cars.
Message — The company requests that car labels include Well-to-Wheel CO2 emissions and recognize renewable fuels' contribution to reducing greenhouse gases. They want vehicles using renewable fuels to be considered zero-emission vehicles.123
Why — This would allow internal combustion engine vehicles using their renewable fuels to avoid emission penalties.45
Impact — Electric vehicle manufacturers lose competitive advantage as combustion engines get reclassified as zero-emission.6
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Response to Recommendation to promote the development of innovative forms of solar energy deployment

2 Apr 2024

REPSOL appreciates this opportunity to provide feedback and so contributes to it by submitting the following comments: Based on the experience in developing the regulatory framework for agro-voltaic technology in other countries, we would like to emphasize that promoting agro-voltaic and other innovative solar technologies should not imply the exclusion of traditional solar technology from auction or incentive procedures. They are compatible and should continue receiving the necessary support in parallel to achieve the global solar penetration targets. On the other hand, to boost the deployment of solar energy in terms of distributed energy, specifically, self-consumption, energy communities and recharge vehicle, it would be necessary to tackle the following points: - Maximize the distance allowed between generator and consumers so that they are considered self-consumption facilities using distribution grid. Specifically, in the case of collective self-consumption and energy communities, allow self-consumption through the network at distances of 20 km. - Simplification of the administrative process to promote self-consumption facilities that inject energy into the grid. - Define a Communication Plan so that the general citizens know the advantages of distributed generation. - Promotion of independent aggregators and their participation in local electricity flexibility markets. - Elaborating (i) Registry of self-consumption facilities, (ii) Registry of Renewable Energy Communities and (iii) Citizen Energy Communities. - Allow flexible access capacity to maximize the integration of facilities (both generation and demand) with the lowest investment needs. As an example, allowing a self-consumption facility to inject energy into the grid only during certain hours previously defined. - Allow the joint permitting process for both public charging infrastructure for electric vehicle and solar self-consumption facilities.
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

Repsol appreciates the opportunity to provide feedback in this call for evidence regarding Renewable Energy Acceleration Areas, after the adoption of the RED III. We would like to express that Repsol advocates for a broad perspective that includes all technologies capable of producing renewable energy. However, the consultation appears to exclusively address wind and solar power. The establishment of Renewable Acceleration Areas aims to contribute to the broader deployment of renewable energies. Therefore, we would like to express that we find it imperative to prevent the definition of these areas from causing the following issues: (i) restricting the development of renewable projects outside the designated zones and (ii) confining administrative simplification initiatives solely to these specified areas. In relation to establishing criteria for the selection of the areas for accelerating renewable energy projects, it is essential to consider the following points: (iii) Broadness of technological criteria: We observe that criteria for identifying these areas can vary significantly depending on the technology involved. Therefore, it is essential to avoid excluding areas that may be suitable for some type of renewable technology, even if they are restrictive for others. This would ensure that the identified areas are as extensive and diverse as possible. (iv) Flexibility in soil type evaluation: The suitability of soil for renewable energy projects can vary considerably among different Member States. Therefore, restrictions based on soil typology should be avoided, thus ensuring fair and comprehensive evaluation of all potential areas. (v) Access to updated information: It is imperative to have up-to-date data when analyzing candidate areas. This includes maps and data on local biodiversity. The lack of updated information could result in the erroneous exclusion of areas that could otherwise be suitable for renewable energy projects. (vi) Facilitation of environmental impact procedure: We recommend implementing measures to simplify the environmental processing for projects developed within these acceleration areas. This could include introducing guarantees or creating streamlined procedures to expedite the process. Additionally, the concept of renewable gases acceleration areas should be explored to achieve the targets defined in REPowerEU, namely the domestic production of 10 million tons of hydrogen and 35 bcm of biomethane. (vii) Renewable acceleration areas should also include hydrogen production projects within its scope. Hydrogen can be extremely useful to evacuate increasing renewable generation in these areas, providing indeed a service to existing electricity grid infrastructure. Many of such nodes already face important delays on connection permission processes due to constrained capacity, and urgently need reinforced grid connections to avoid congestions (e.g. Spain). If hydrogen projects could count with streamlined permission processes too, they could effectively complement electricity grid planning and optimize the costs of integrating larger shares of renewable generation. (viii) Areas rich on organic feedstocks or residues should also be declared renewable acceleration areas, in regard to its potential to boost biomethane production (and other biofuels). (ix) Industrial areas where the quick roll out of renewable gases is critical should also be declared renewable acceleration areas. Particularly in the light of meeting industrial RFNBO consumption quotas and facilitate the value chains of hydrogen and hydrogen derivatives (so-called Hydrogen Valleys), more often produced on site.
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Repsol calls for fairer emission rules at sub-installation level

28 Dec 2023
Topic — Updating European Union rules for free emission allowances under the revised ETS.
Message — Repsol requests interpreting provisions on climate neutrality plans and energy efficiency measures at sub-installation level. They seek to protect commercially sensitive information from disclosure in public plans. Hydrogen produced onsite for refineries should stay within the refinery benchmark.1234
Why — Applying rules at sub-installation level prevents disproportionate penalties for entire installations.5
Impact — Transparency decreases if authorities agree not to publish commercially sensitive elements.6
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Nov 2023

Please, find attached Repsol's feedback on the consultation.
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Repsol urges EU to speed up hydrogen valley development

5 Sept 2023
Topic — Strategic priorities and actions to double the number of EU hydrogen valleys.
Message — Repsol requests faster permitting, dedicated funding, and network tariff exemptions to support hydrogen production. They also advocate for better infrastructure planning and cross-border collaborations.123
Why — These measures would reduce compliance costs and accelerate Repsol's planned large-scale electrolyzer investments.45
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Repsol Urges Faster Permitting for EU Carbon Management Deployment

31 Aug 2023
Topic — The consultation examines policies to support the deployment of carbon management infrastructure.
Message — Repsol requests a coordinated EU strategy that streamlines licensing and permitting. They recommend standardizing CO2 conditions at supply points to ensure integrated planning. They advocate for EU funding lines to derisk these complex geological projects.12
Why — This would provide investment certainty and enable more time-efficient decarbonisation options.34
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Response to Report on the implementation of Article 5 of the Renewable Energy Directive

28 Aug 2023

Please, find attached REPSOL SA's feedback on Renewable energy report on the opening up of support schemes
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Repsol Urges Flexible Biomass Monitoring to Reduce Compliance Costs

18 Aug 2023
Topic — This consultation updates rules for monitoring and reporting greenhouse gas emissions under the ETS.
Message — Repsol requests alternative estimation methods for biomass fractions when laboratory analysis is too costly. They urge alignment with existing directives to reduce administrative burdens.12
Why — This would lower operational costs and bypass the scarcity of specialized testing laboratories.34
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Repsol warns of "disproportionate burden" from EU sustainability rules

7 Jul 2023
Topic — The Commission is establishing mandatory sustainability reporting standards for large European companies.
Message — Repsol requests a risk-based approach to value chain reporting to reduce administrative complexity. They advocate for qualitative disclosures on forward-looking data to mitigate legal risks. The company also urges alignment with international standards to ensure global consistency.123
Why — Narrowing reporting requirements would decrease compliance costs and protect Repsol from litigation risks.45
Impact — Stakeholders could face a decline in information quality due to less granular data.6
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Repsol urges technology neutrality for EU 2040 climate goals

23 Jun 2023
Topic — Establishing a 2040 climate target to achieve EU-wide climate neutrality by 2050.
Message — The company requests a simpler regulatory framework that incentivizes any technology capable of reducing emissions, specifically carbon-neutral fuels and carbon capture. They also advocate for a single net emissions target and streamlined permitting to reduce administrative burdens.123
Why — This would allow Repsol to repurpose existing infrastructure and lower its administrative costs.45
Impact — European workers and industrial sectors face decline if fuel restrictions drive jobs overseas.67
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Repsol Urges EU to Include Renewable Fuels as Strategic Tech

23 Jun 2023
Topic — The Net Zero Industry Act aims to scale up decarbonized technology manufacturing within Europe.
Message — Repsol advocates for designating sustainable alternative fuels and carbon capture as strategic net-zero technologies. They propose extending fuel usage to road transport and demand concrete financing for storage projects.12
Why — Strategic status would safeguard Repsol's industrial assets and prevent relocation of production outside Europe.3
Impact — The internal market loses cohesion if the regulation creates a two-speed competitiveness scheme.4
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Meeting with Izaskun Bilbao Barandica (Member of the European Parliament)

14 Jun 2023 · Combustibles renovables/descarbonización

Repsol Urges Voluntary Power Contracts and Merchant Investment Freedom

23 May 2023
Topic — Reforming EU electricity markets to reduce gas price impacts and support energy transitions.
Message — Repsol suggests that Contracts for Difference must remain voluntary to avoid crowding out other investments. They call for removing regulatory barriers to power purchase agreements to help decarbonize energy-intensive industries. Additionally, they advocate for long-term incentives to unlock investment in electricity storage.123
Why — Voluntary contracts allow the company to maintain market-based revenue and better financial portfolio planning.45
Impact — National governments would lose the ability to withhold Guarantees of Origin from subsidized projects.6
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Repsol urges EU to recognise CO2-neutral fuels in heavy-duty vehicle regulation

19 May 2023
Topic — EU regulation strengthening CO2 emission standards for new heavy-duty vehicles.
Message — Repsol requests recognition of CO2-neutral fuels alongside electromobility for decarbonizing heavy transport. They argue these fuels are already available, compatible with existing infrastructure, reduce emissions by 65-90%, and support circular economy by using non-recyclable waste.123
Why — This would enable transformation of Repsol's fuel production sites and guarantee their continuity and employment.45
Impact — Exclusion threatens viability of sustainable aviation and maritime fuel investments across Europe.67
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Meeting with Kadri Simson (Commissioner) and

4 May 2023 · Russian sanction circumventions, advanced biofuels, renewable hydrogen.

Repsol Urges Technology Neutrality and Alignment with EU Transport Rules

3 May 2023
Topic — Defining technical screening criteria for sustainable activities contributing to EU environmental and circular objectives.
Message — Repsol requests including CO2 neutral fuels to maintain consistency with transport regulations. They also propose a 24-month grace period for reporting on restricted substance lists.12
Why — This would lower administrative expenses and provide more time to update reporting systems.34
Impact — Conservation organizations lose funding as resources are diverted to pay for mandatory audits.5
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Repsol urges EU to recognize chemical recycling for packaging

24 Apr 2023
Topic — The EU is updating rules to reduce packaging waste and increase recycling rates.
Message — Repsol calls for chemical recycling to be legally equivalent to mechanical methods. They request a clear calculation methodology immediately to provide legal certainty for investments.123
Why — This allows the company to leverage existing infrastructure instead of building expensive new plants.45
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and ENGIE and

31 Mar 2023 · Energy Transition. Site visit. Organiser: Administração dos Portos de Sines e Algarve.

Repsol urges EU to provide financial certainty for carbon removals

23 Mar 2023
Topic — A proposal for a regulatory framework to certify sustainable carbon removals within the EU.
Message — Repsol calls for a framework prioritizing emission reductions and providing financial certainty. They advocate for robust carbon accounting including carbon capture and use in products. The regulation must ensure consistency with existing policies like the EU Emissions Trading System.123
Why — A harmonized framework would secure returns on massive investments in industrial storage infrastructure.4
Impact — Environmentalists may challenge the inclusion of commercial forestry exploitation as a removal activity.5
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Meeting with Jens Gieseke (Member of the European Parliament) and Arbeitsgemeinschaft Deutscher Verkehrsflughäfen

24 Jan 2023 · Austausch zur EU-Verkehrspolitik

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

14 Jan 2023 · Energy Transition and Markets

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

10 Jan 2023 · Renewable energy Directive

Repsol opposes Annex IX reclassification threatening existing biofuel investments

29 Dec 2022
Topic — Addition of new feedstocks to EU renewable energy directive biofuel lists.
Message — Repsol requests that feedstocks currently recognized as Part A by Member States not be reclassified to Part B. They argue the Part B cap should be removed or proportionally increased. They want technology maturity assessments to consider supply chain and payback periods.1234
Why — This would protect their existing investments and maintain long-term business case viability.567
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Meeting with Maroš Šefčovič (Executive Vice-President) and

20 Dec 2022 · EU Energy Platform; Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid, GOGC participated as well.

Meeting with Ditte Juul-Joergensen (Director-General Energy) and TotalEnergies SE and

20 Dec 2022 · Energy Platform. Bulgargaz, SPP, EPH, DEPA, Geoplin, Eesti Gaas, Enovos, DEFA, Conexus Baltic Grid and GOGC participated as well.

Meeting with Pierre Karleskind (Member of the European Parliament) and European Community Shipowners' Associations

1 Dec 2022 · Décarbonation du transport maritime

Meeting with José Ramón Bauzá Díaz (Member of the European Parliament, Rapporteur)

22 Nov 2022 · ReFuelEU Aviation

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur) and Mazda Motor Logistics Europe N.V.

19 Oct 2022 · Fit-für-55-Paket: CO2-Emissionsnormen für neue Personenkraftwagen und für neue leichte Nutzfahrzeuge

Meeting with Izaskun Bilbao Barandica (Member of the European Parliament)

29 Sept 2022 · Precio energía

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and ELECTRICITE DE FRANCE and

21 Sept 2022 · EMIR review, clearing threshold

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

21 Sept 2022 · Energy derivatives markets

Repsol Seeks More Flexibility in EU Biomass Co-Processing Rules

20 Jul 2022
Topic — The EU is establishing rules for determining renewable content in co-processed fuels.
Message — Repsol requests a one-year transitional period and flexibility to define measurement zones at the unit level. They also propose increasing the allowed measurement discrepancy from one to six percent to reflect testing uncertainties.123
Why — This would reduce its compliance costs and prevent negative impacts on refinery operations.4
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Repsol seeks technical clarity on biodiesel emission approval rules

29 Jun 2022
Topic — This consultation updates emission type-approval rules for heavy-duty vehicles using pure biodiesel.
Message — Repsol welcomes including FAME as a reference fuel while requesting clearer technical definitions. They suggest specifying relevant CEN standards to avoid misinterpretation regarding fuel blend requirements. They also advocate for including paraffinic renewable fuels in future European standards.123
Why — This change would minimize the technical burden of testing complex fuel blends.4
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Repsol Urges More Flexibility in Green Fuel Methodology

17 Jun 2022
Topic — Drafting rules for calculating greenhouse gas savings for renewable and recycled transport fuels.
Message — Repsol requests additional efforts to simplify the methodology to ensure a swift implementation. They propose allowing industrial captured carbon sources beyond 2035 and introducing credits for landfilling.12
Why — The changes would provide a stable framework for evaluating business cases and protecting investments.34
Impact — Climate goals may suffer if extended use of industrial carbon delays absolute industrial decarbonization.5
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Repsol Urges EU to Include LNG in Gas Storage Targets

25 May 2022
Topic — The consultation proposes mandatory gas storage filling levels to ensure European energy security.
Message — Repsol argues that the Commission must consider national particularities when setting mandatory gas storage rules. They specifically propose that liquefied natural gas stored in regasification plants should count toward filling targets.12
Why — This would prevent unnecessary and costly new storage requirements for companies already meeting standards.3
Impact — Spanish market participants would face disproportionate regulatory burdens under a one-size-fits-all approach.4
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Repsol urges EU to integrate carbon removals into ETS

29 Apr 2022
Topic — A proposed regulatory framework for certifying sustainable industrial and ecosystem carbon removals.
Message — Repsol supports a technology-neutral framework that integrates removal certificates into the EU trading system. They recommend using existing voluntary market standards and international rules for immediate implementation.123
Why — This allows the company to meet climate targets through removal credits and geological storage.45
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Response to Proposal for a legislative act on methane leakage in the energy sector

8 Apr 2022

Repsol supports the development of a cost-efficient EU-wide regulation addressing methane emissions. Repsol supports the use of natural gas to bring about a structured transition to a low-emissions future, particularly due to its short-term potential to substitute coal in electricity generation and consequently an substantially contribution to emissions reduction, which is why we have taken on the objective of achieving a methane emissions intensity of our operated assets of 0.2% by 2025, a value recognized as near-zero by relevant shareholders for the O&G sector and which also coincides with the new target announced by the OGCI (Oil and Gas Climate Initiative) of which Repsol is a member. As an OGMP signatory, Repsol agrees with the European Commission’s objective to improve the accuracy of information about sources of methane emissions and to seek to reduce emissions, control fugitive emissions and to seek to minimize flaring and venting. However, we are generally concerned that the Regulation requires operators to conduct overall overwhelming measurements, verification, leak detection and reporting activities with corresponding cost to the industry and consumers, that do not have any detectable environmental benefit, thereby not being in line with the Better Regulation principles. Whilst we acknowledge there should be some cost related to methane emission reduction in general, such activities should be based on an assessment of a source emission potential and possibility for occurrence (i.e. risk-based). Please find attached our main points of concern.
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Response to Revision of EU rules on Gas

7 Apr 2022

Repsol welcomes the proposal of the Hydrogen and Gas Market Decarbonization Package as it constitutes a framework that paves the way for a fast transition away from coal to natural gas and a progressive transition from natural gas to renewable and low-carbon gases, while establishes a regulatory framework for hydrogen with the same principles as for natural gas, including a transitional period which will favor the development and maturity of such market. In addition, we underpin the inclusion of tariff discounts for renewable and low carbon gases as an incentive for their development. Reducing network tariffs for injection of renewable and low carbon gases to the grid is a key aspect to enable the agents to promote them. We appreciate the opportunity given by the European Commission for the stakeholders to provide feedback on the package, thereby we would like to make the following general comments that we consider could improve the proposal: • The EU interconnected gas infrastructure shall be considered as a single mass balance system. It is worth clarifying that for renewable and low carbon fuels, there should be no physical tracking of the molecules in single mass balance systems. For this purpose, a Guarantees of Origin system should be deployed and issued for renewable and low-carbon gases in accordance with Article 19 of Directive (EU) 2018/2001. This would also ensure other provisions of the package could rely on this Guarantees of Origin system. • Likewise, regarding the certification of renewable and low carbon fuels, the methodology for assessing greenhouse gas emissions savings from low carbon fuels that would allow to classify gas and hydrogen as a “low-carbon” fuel should be approved at the same time the Package comes into force. Otherwise, projects and investments on these low carbon fuels will be postponed until a clearer scenario is set up. • Repsol is committed to the Paris Agreement and the EU 2050 climate neutrality objectives and supports the transition to clean energy and net-zero emissions by 2050. In this sense, Repsol encourages the European Commission to recognize a transparent and favorable framework for the application of carbon, capture and storage (CCS) technologies and other potential options to boost the energy transition. • Transport and distribution gas model should be followed by hydrogen beyond 2030, under the consideration that this market will be mature by then. Given the fact that many infrastructures will consist of repurposed methane gas pipelines, at this second stage, we support the idea that the hydrogen network operator’s definition should distinguish between “transport” and “distribution”. • For further developments of the regulation, it should be avoided that the horizontal and vertical unbundling rules of hydrogen networks operators may become a barrier for their progress, or an increase of the tariffs the agents must face.
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Response to Revision of EU rules on Gas

7 Apr 2022

Repsol welcomes the proposal of the Hydrogen and Gas Market Decarbonization Package as it constitutes a framework that paves the way for a fast transition away from coal to natural gas and a progressive transition from natural gas to renewable and low-carbon gases, while establishes a regulatory framework for hydrogen with the same principles as for natural gas, including a transitional period which will favor the development and maturity of such market. In addition, we underpin the inclusion of tariff discounts for renewable and low carbon gases as an incentive for their development. Reducing network tariffs for injection of renewable and low carbon gases to the grid is a key aspect to enable the agents to promote them. We appreciate the opportunity given by the European Commission for the stakeholders to provide feedback on the package, thereby we would like to make the following general comments that we consider could improve the proposal: • The EU interconnected gas infrastructure shall be considered as a single mass balance system. It is worth clarifying that for renewable and low carbon fuels, there should be no physical tracking of the molecules in single mass balance systems. For this purpose, a Guarantees of Origin system should be deployed and issued for renewable and low-carbon gases in accordance with Article 19 of Directive (EU) 2018/2001. This would also ensure other provisions of the package could rely on this Guarantees of Origin system. • Likewise, regarding the certification of renewable and low carbon fuels, the methodology for assessing greenhouse gas emissions savings from low carbon fuels that would allow to classify gas and hydrogen as a “low-carbon” fuel should be approved at the same time the Package comes into force. Otherwise, projects and investments on these low carbon fuels will be postponed until a clearer scenario is set up. • Repsol is committed to the Paris Agreement and the EU 2050 climate neutrality objectives and supports the transition to clean energy and net-zero emissions by 2050. In this sense, Repsol encourages the European Commission to recognize a transparent and favorable framework for the application of carbon, capture and storage (CCS) technologies and other potential options to boost the energy transition. • Transport and distribution gas model should be followed by hydrogen beyond 2030, under the consideration that this market will be mature by then. Given the fact that many infrastructures will consist of repurposed methane gas pipelines, at this second stage, we support the idea that the hydrogen network operator’s definition should distinguish between “transport” and “distribution”. • For further developments of the regulation, it should be avoided that the horizontal and vertical unbundling rules of hydrogen networks operators may become a barrier for their progress, or an increase of the tariffs the agents must face.
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Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur for opinion) and Hydrogen Europe

9 Mar 2022 · RED

Meeting with Kadri Simson (Commissioner) and

21 Feb 2022 · Spike of energy prices and EC's toolbox, Fit-for-55 proposals and EU taxonomy.

Response to Revision of Alternative Fuels Infrastructure Directive

17 Nov 2021

REPSOL appreciates the efforts and the approach of the Commission on further improving the deployment of the alternative fuels in the transport sector. We appreciate the opportunity to provide our feedback to this Proposal and remain at EC’s disposal for any further clarification needed. AFIR should set a framework for EU-wide and for national infrastructure plans by: -Defining An EU-wide approach for the TEN-T corridors related to road, rail, aviation and waterways, both seaside as well as inland waterways. However, infrastructure roll out should be based on Member States individual demand profiles. -Ensuring coherence in MS approach to handle national, regional and sub-regional specificities related to the transport modes via their NPFs. The proposed targets create a bias in the expected development of the new infrastructure: -The targets for the energies under scope are based on different principles, which makes the framework oriented towards electrification and might regrettably prevent the markets to develop of the most competitive and effective lower carbon solutions. -The proposed proportionality principle between the fleet size and the power output of the infrastructure should not be limited to the electric recharging points and the principle expanded to all energies including hydrogen and LNG. AFIR should promote the development of infrastructure over all transport sectors and all alternative fuels (1) or energies: -Besides the road and shipping, AFIR should cover rail and the airport infrastructure for ground movements and sustainable aviation fuel supply. -The definition of alternative fuels under the regulation should be revised (2) to define clearly that advanced biofuels, recycled carbon fuels and RFNBO as defined in Article 2 of Directive (EU) 2018/2001, are included as alternative fuels and as such to be included in as mandatory fuels under the AFIR to support their uptake. (1)Alternative fuels from recycled CO2 and green/blue hydrogen do not need new, dedicated infrastructure. (2)Alternative fuels means fuels or power sources which serve, at least partly, as a substitute for fossil oil sources in the energy supply to transport and which have the potential to contribute to its decarbonisation and enhance the environmental performance of the transport sector, including: (a) ‘alternative fuels for zero-emission vehicles’: –electricity, –hydrogen, –ammonia; (b) ‘renewable fuels’: –biomass fuels and biofuels as defined in Article 2, points (27) and (33) of Directive (EU) 2018/2001, –synthetic and paraffinic fuels, including ammonia, produced from renewable energy, (c) ‘alternative fossil fuels’ for a transitional phase: –natural gas, in gaseous form (compressed natural gas (CNG)) and liquefied form (liquefied natural gas (LNG)), –liquefied petroleum gas (LPG), –synthetic and paraffinic fuels produced from non-renewable energy. AFIR should address the disparities in the deployment of AFI across the Union: -A clear definition of ‘recharging or refuelling points accessible to the public’ should be provided. This would include the inclusion of private stations that allow access to private users. AFIR should promote information and the use of standards to allow safe use and interoperability of infrastructure: -As a part of the development of new standards and parameterization of alternative fuels, it is recommended to introduce the certification of hydrogen as a fuel and a coherent European regulation on common standards and technical parameters for the construction of hydrogen refueling stations. This will enable a holistic and dynamic development of hydrogen as a fuel in the EU. Hydrogen in transport is currently one of the least regulated alternative fuels. AFIR should enable financial support for rollout. -Alternative fuel refueling sites should be provided with time-limited support for capital and operating expenses, e.g. direct grants, demand guarantees, etc. to address initial underutilization.
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Repsol urges lifting biofuel caps to boost transport decarbonization

17 Nov 2021
Topic — Revision of EU Renewable Energy Directive to align with higher 2030 climate targets.
Message — Repsol requests removing the 1.7% cap on Annex IX part B feedstocks, deleting proposed penalties for residue-based fuels, and recognizing renewable hydrogen from biological sources. They argue caps contradict higher ambition and that fraud can be prevented by other means.123
Why — This would expand their access to feedstocks and reduce penalties on their existing biofuel production.45
Impact — Environmental groups lose stricter limits designed to prevent indirect emissions and feedstock fraud.6
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Response to Revision of the Energy Tax Directive

17 Nov 2021

REPSOL is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050. We welcome the opportunity given to provide input to the Public Consultation on the proposal of Revision of the ETD. REPSOL is convinced that this revision should consider measures aimed to encourage the investments in new technologies and the use of alternative and more sustainable energy, always with a technology neutral approach. The best way to lead a real decarbonization is to incentive all of kind of renewable sources of energy guaranteeing their performance on a level playing field. That’s why REPSOL supports that: - ETD should align the definition of second and third generation biofuels, alternative fuels, e-fuels, etc. with all the measures included in the Fit for 55 Package, such as the revision of RED II. This alignment is critical to assuring consistency for the companies to both make the necessary investments and fulfill all the obligations requested. - Renewable hydrogen and advanced sustainable fuels should be treated in a similar way as electricity. However, the most favorable treatment included in the current proposal for the electricity, irrespective of its origin, is not in line with the general direction of Fit for 55. Arguments given by the Commission in their working papers for excluding this distinction are rebuttable based on the provisions of art. 19 of RED II (guarantees of origin for energy from renewable sources). - We welcome that the lower tax rate for electricity is also applied to low carbon fuels such as “blue” hydrogen. But we regret that this lower rate would only be available to low-carbon fuels for a transition period until 2033, since the EU needs low-carbon fuels while it develops a market for hydrogen based on renewable power. - There should be mandatory exemption for second and third generation biofuels to lead to a more harmonized implementation in the EU. We notice instead that exemptions are mandatory in certain transport sectors (maritime and air transport) while in others those are left to the discretion of the member states. REPSOL calls the attention on the need for carefully considering the competitiveness of peripheral countries of the EU much more dependent on road transport, maritime transport and aviation. This is the reason why we support the maintenance of commercial/non-commercial use differentiated rates. On this sense, we would also welcome further clarification on the application of the categorization and ranking of the minimum tax rates, in particular the inter-category rules to respect and possible intra-category taxation rules. It seems that the minimum rates assigned to each category has to be applied for each product group belonging to this category. However, REPSOL think that a certain flexibility with respect to the application of equal minimum tax rate for each product group should be allowed (e.g., diesel and petrol). Concerning the minimum rates applicable to LPG and natural gas, REPSOL supports a longer transitional period to guarantee a fair and sustainable energy transition among the households more dependent on these energy products. Lastly, we consider that inclusion of all lubricants into the EMCS is not an effective measure against fraud, considering the massive additional administration burden caused at operators not taking part in fraudulent activities. Instead, targeted measures should rather be introduced, such as the creation of specific CN-codes for designer fuels based on their physical and chemical parameters and only extending the scope of EMCS to these. This approach would not burden producers and traders of products that are not fit for use as fuels while offer a more focused tool to combat fraud.
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Nov 2021

At REPSOL we consider the revision of the EED to be timely, as emissions reduction is linked with Energy Efficiency (EE). In any case, we would like to contribute with the following suggestions: a) Benefits of technological neutrality are not fully exploited Annex V provides the direct use of fossil fuels will no longer be counted for meeting EE obligations. This is particularly affecting our industry, considering that the provisions refer to, amongst others, products, transport and vehicles: it could lead to the exclusion of EE interventions that involve the use of efficient technologies (natural gas and low carbon liquid fuels combined with electrification and hydrogen) play a key role for the decarbonization of the transport sector. In any case, other European legislations are better placed than the EED to regulate transport. In Article 3, the introduction of a further criterion for achieving high-efficiency cogeneration (270 gCO2/kWh) inaccurately places the value of electric & thermal kWh on the same level. A reasonable value that may ensure congruence could be 350 gCO2/kWh. For the sake of clarity, we prefer to exclude the use of the most polluting fuels, such as oil & coal, in CHP plants from 2035 instead of the proposed CO2 limit. b) Energy reduction targets risk endangering industrial competitiveness We believe that fixing absolute targets for energy reduction is not the same as improving energy efficiency, which should be the aim of the EED. Targets are set in terms of final and primary energy consumption to be achieved in 2030. This way, Member States would be obliged to provide the shares of energy consumption of end-use sectors (including industry, services and transport) in their national EE contributions. The EC should consider that the absolute final energy reduction is directly linked to major shifts in the structure of primary energy use in each sector. “Energy Efficiency First” principle: an effective energy system aiming to decarbonize as well as meeting energy demand requires that energy is delivered efficiently throughout the value chain: from generation to consumption, including cross-sectoral solutions. c) A proper inclusion of the transformation sector is needed, particularly refineries The transformation sector includes the refineries; however, they are not simple energy transformation sites but also industrial installations. Refineries buy final energy (mainly electricity and natural gas) to a retail energy sales company, as any industry does. This final energy is consumed for the operations that are necessary for running the process. In refineries EE actions are carried out to reduce final energy consumption per unit produced. Refineries have huge potential to improve EE, and many of them are certified under the UNE EN ISO 50.001 "Energy Management Systems" scheme. Hence, these actions should be considered towards meeting the objectives of EED, enabling further EE improvements and supporting the achievement of the EU's ambition to reduce GHG emissions. d) Coherence across all Fit for 55 regulation EE is a cornerstone for many of the other files (ETS, ESR or RED). For the sake of coherence, special care should be taken with overlapping regulation. For instance, not counting reduced energy use as a result of emission trading pursuant to ETS means assuming that all EE projects in the ETS sectors would be realized solely based on the ETS CO2-price incentive. This is not always the case, nor the only factor involved. Regarding the new EU ETS proposal we suggest the EC to withdraw the policy that rules that for the installations covered by the obligatory audits to have 25% of free allocation reduced unless they implement recommendations of the audit report (with pay-back time not exceeding five years and the proportionate costs of those investments), or demonstrate the implementation of other measures which lead to GHG emission reductions equivalent to those recommended by the audit report.
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Repsol urges EU to expand renewable fuel pathways for aviation

17 Nov 2021
Topic — EU regulation mandating sustainable aviation fuel uptake to reduce emissions.
Message — Repsol requests alignment between RED and ReFuel Aviation to allow renewable fuels of non-biological origin as intermediate products. They call for removing the 1.7% cap on Annex IX part B feedstocks and including renewable hydrogen from biological origin in compliance calculations.123
Why — This would expand the range of renewable fuels Repsol can supply for aviation compliance.45
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Repsol urges EU to combine carbon border tax with free allowances

17 Nov 2021
Topic — EU proposal to place carbon price on imported products in selected sectors.
Message — Repsol requests free allowances remain until at least 2030 alongside the carbon border mechanism, with export rebates for EU manufacturers. They argue the import-only mechanism fails to protect EU competitiveness on export markets.123
Why — This would protect their competitiveness and avoid costs when selling products outside the EU.45
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Repsol backs EU maritime fuel rules but urges flexibility

8 Nov 2021
Topic — New EU regulation requiring renewable and low-carbon fuels in maritime transport.
Message — The company requests more flexible emission standards to recognize alternative fuel production methods and efficient propulsion technologies. They want lawmakers to ensure consistency with other EU climate measures and closer engagement with trading partners.123
Why — This would allow their diverse fuel production technologies to qualify under the rules.45
Impact — EU competitors face stricter rules than international rivals, risking carbon leakage and trade friction.6
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Repsol urges EU to include renewable fuels in vehicle emission standards

5 Nov 2021
Topic — EU proposal to strengthen CO2 emission standards for new cars and vans.
Message — Repsol requests technology-neutral approach allowing renewable and low-carbon fuels to count toward emission targets. They propose credit system for fuel suppliers and zero-emission vehicle status for cars designed for net-zero-carbon fuels.123
Why — This would expand market opportunities for their renewable fuel products alongside electric vehicles.45
Impact — Electric vehicle manufacturers lose competitive advantage if fuel-based alternatives count as zero-emission.6
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Repsol warns EU carbon trading reforms threaten refining competitiveness

5 Nov 2021
Topic — Revision of EU Emissions Trading System to achieve 55% emission reductions by 2030.
Message — Repsol requests sustained carbon leakage protection measures, avoiding cross-sectoral correction factors that would reduce free allowances by 60% in 2026-2030. They seek realistic benchmarks that don't penalize best-performing refineries and mandatory EU-wide compensation for indirect emission costs.123
Why — This would prevent them carrying large uncompetitive cost burdens versus non-EU producers.45
Impact — Climate advocates lose stronger carbon price signals that drive faster decarbonization.6
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Response to Action plan on the digitalisation of the energy sector

10 Sept 2021

As a global multi-energy company and being the first one to set the goal of reaching net zero emissions by 2050, at Repsol we endorse this Action Plan on the digitalization of the energy sector. Repsol’s new Strategic Plan aims to accelerate the energy transition, with digitalization playing a key role and welcomes this Action Plan on the digitalization of the energy sector. We are pleased to point out the following concrete initiatives helping to tackle each area defined. Concerning the "Developing a European data-sharing infrastructure" area, the platform must allow citizens to manage their data in compliance with global regulatory systems and, at the same time, it will be necessary to increase flexibility in the use of data between companies of the same group to be able to provide citizens with combined energy offers completer and more competitive, reducing loss of opportunity for citizens and companies. And ensuring traceability of operations and the implementation of Sovereign Digital Identity and Smart Contracts supported by Blockchain. With respect to the "Empowering Citizens" area and according to our understanding it should evolve into the promotion and impulse of Citizen’s solar and wind communities where they can choose becoming energy producer or consumer. Another aspect to be promoted is sustainable mobility in cities, ensuring the necessary infrastructures such as recharging access points. Also, the household sensorization associated to the development and adoption of efficient energy management solutions (EMS) for citizen consumption recommendations as part of the energy offering, as well as adopting it in the industrial units. Finally, encouraging initiatives focused on providing active energy management in which each citizen can choose the source of their energy. Related to the "Enhancing the uptake of digital technologies" and "Enhancing the cybersecurity of the energy sector" areas, it will be necessary to stimulate companies financially by facilitating their digital transformation to adopt advanced technologies (i.e. IA, 5G, IA, ATEX sensorization and smartcams, AI driven industrial robotics, Digital twins, Enhanced autonomous control systems, Remote operation centers, customer centric platforms). It’s essential to bear in mind that digitization of energy services for citizens will require the digitization of the industrial units and sales forces of the companies as a necessary, indivisible and linked paths. Cybersecurity should be driven in two parallel branches aimed at strengthening the security of citizens as well as corporate assets. As for the area "Supporting the development and uptake of climate neutral solutions for the Information and Communication Technologies sector", in our view, the scope should be extended to include the implantation of net zero emissions businesses and energy solutions. In addition, and because of that, we propose to add a new area called "Digitalization for circular economy and development of green energy sources" or similar. As stated, one of the objectives is intended to drive the transition to a fully decarbonized energy supply based on renewables. At Repsol, we are focused on renewables as part of the solution, and to accelerate the pace to decarbonization and ensure energy supply we also propose to consider within the Roadmap to digitalization of the energy sector, further efficient ways to achieve the objective, such as: • Stimulating companies to implement solutions through the efficient use of natural resources, reducing waste production and consumption of raw materials by recycling and circular economy. • Incentivizing the research and implementation of technologies for Carbon Capture, Use and Storage (CCUS), the development of green hydrogen and zero/low carbon fuels to achieve greenhouse gas emissions reduction, directly and indirectly. • Extending carbon pricing to all productive sectors worldwide as a key element in policies to combat climate change.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Please find Repsol's consultation response in the attachment.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Repsol, as a global multienergy company, is aware of the importance of the taxonomy framework launched by the European Commission to reorient EU capital flows towards more sustainable investment and appreciates the opportunity to provide feedback on the draft delegated regulation on Art. 8 of the EU Taxonomy. Please find attached our main recommendations.
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Response to New EU urban mobility framework

25 May 2021

Repsol herewith acknowledges the opportunity to contribute with its position to improve the roadmap on new urban mobility framework. Repsol is a global multi-energy company, which leads the energy transition and has set the goal of being zero net emissions by 2050. It is present throughout the energy value chain, employs 24,000 people and distributes its products in more than 90 countries, in which it has a total of 24 million customers. As a relevant player in the electricity and gas market in Spain, Repsol has 1.1 million customers and owns low-emission power generation assets with a total installed capacity of 3,000 MW. Repsol can satisfy any energy and mobility need of Spanish consumers, with a customer-focused offer. It is at the forefront of the development of sustainable solutions for mobility, with increasingly efficient fuels, sustainable biofuels, electric recharge, AutoGas or vehicular natural gas. It has one of the most efficient refining systems in Europe, made up of 6 industrial complexes, which are being transformed into multi-energy hubs through cutting-edge projects that will reduce its carbon footprint. To achieve net zero emissions by 2050, Repsol is committed to a model that integrates all technologies for decarbonisation, based on improving efficiency, renewable generation, low, neutral or even negative carbon footprint products, the economy circular, industrial innovation and the development of new solutions based on digitization. Regarding EU urban mobility frame work, we are also concerned with the issues detected affecting inhabitants of cities and their surrounding areas and agree with the need for strengthened measures focused on energy efficiency, transport decarbonisation, air quality, noise and affordability, accessibility and inclusiveness of mobility to keep a good quality of life for every citizen. Cities are zones with a high population density and huge mobility needs which are in constant change. Digitalization in transport modes will be a powerful tool to enable different solutions to play a role in an inclusive and multimodal transport sector growing faster. One of the pillars for the development of mobility has to raise from the public investment as well as its legislative actions. In direct connection, TEN-T regulation must perfectly fit with urban transport nodes and on demand passenger transport solutions while ensuring a safer and more sustainable mobility. The Commission should prioritize pursuant to the TEN-T regulation, the full deployment of alternative fuels and gases for all modes of transport, especially renewable fuels and gases, with a view to decarbonisation, including the development of relevant technologies, charging and refueling infrastructure (i.e. e-charging facilities and LNG and hydrogen refueling facilities), safety, security and interoperability standards, and the regulatory framework for alternative fuels in order to achieve climate neutrality by 2050. The boost of recharging infrastructures for light vehicles (gas, electricity, hydrogen…) along with the interaction of every technology available will be an asset to achieve a faster decarbonisation of transport as well as an air quality upgrade. The modernization of vehicle fleet is also very relevant to reduce GHG emissions. New vehicles under new european standard emissions would highly contribute to cut emissions in the very short term as transport remains amounting the 25% of total of GHG in Europe. EU roadmap for road infrastructure should be aligned with the roadmap of the automotive industry in order to ensure that infrastructure investments go hand in hand with vehicle production always taking in mind the protection of the industry and the conservation of the employment in EU. We look forward to continue participating actively in the development of this procedure, by providing further input to upcoming consultations and addressing other information requests the Commission may need.
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Response to Revision of EU rules on Gas

10 Mar 2021

Repsol appreciates the opportunity to submit our views and opinions to the European Commission’s roadmap on Gas networks - revision rules on market access. Please find our feedback in the document attached. We look forward to continuing participating actively in the development of this legislative procedure, by providing further input to upcoming consultations and addressing other information requests the Commission may need.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Repsol, as a global multienergy company, is aware of the importance of the taxonomy framework launched by the European Commission to reorient EU capital flows towards more sustainable investment and appreciates the opportunity to provide feedback on the this draft delegated act. Please find in the attached document our main recommendations focused on: 1) BIOFUELS, LIQUID AND GASEOUS TRANSPORT FUELS OF NON-BIOLOGICAL ORIGIN AND RECYCLED CARBON FUELS • We welcome the inclusion of Section 4.13 on Manufacture of biogas and biofuels for use in transport and the effort to align the technical screening criteria with the Directive (EU) 2018/2001 (RED II). In this sense, a complete alignment between these two pieces of legislation will be necessary in order to promote all sustainable forms of biofuels. • We propose, for the sake of completeness , to amend the description of the activity as follows: “the activity is classified under NACE code D35.21; C20.14; C20.59 in accordance with the statistical classification of economic activities established by Regulation (EC) No 1893/2006 and/or it is dedicated to the production of biofuels and renewable fuels of non-biological origin meeting the sustainability criteria outlined in the Directive (EU) 2018/2001 (RED II)”. NACE code D35.21 concerns only gases whereas biofuels are also liquids. • We call for the explicit inclusion of liquid and gaseous transport fuels of non-biological origin and recycled carbon fuels as they are defined in the RED II. • The manufacture of biogas and biofuels should be classified as sustainable activity rather than a transitional one. 2) HYDROGEN • The section dedicated to the production of Hydrogen should include all low carbon production pathways of hydrogen. This could be done in a consistent manner with the thresholds proposed by the TEG in its report. 3) LIFE-CYCLE APPROACH IN TRANSPORT EMISSIONS • Life-cycle approach used by the European Commission in the Delegated Act should apply to all the transport sector sections.
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Repsol urges EU to include low-carbon fuels in CO2 targets

26 Nov 2020
Topic — Revision of the CO2 emission performance standards for new cars and light commercial vehicles.
Message — Repsol advocates for a technological neutrality approach that recognizes sustainable biofuels and synthetic fuels as solutions alongside electrification. They propose moving beyond tailpipe emission measurements to a well-to-wheel assessment that accounts for fuel production.123
Why — This would preserve the company's refining business and existing infrastructure by allowing internal combustion engines to remain viable.45
Impact — Electric vehicle manufacturers and infrastructure providers may face slower adoption rates if focus shifts from pure electrification.67
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Repsol urges technology-neutral approach to EU renewable energy revision

21 Sept 2020
Topic — The European Commission is updating renewable energy laws to achieve tougher 2030 climate goals.
Message — Repsol advocates for a technology-neutral approach that supports synthetic fuels and clean hydrogen. They request a stable regulatory framework that protects early investments from retroactive changes. They also seek to eliminate overlapping regulations for fuel suppliers.123
Why — A technology-neutral framework would secure Repsol’s investments in low-carbon fuels and reduce compliance costs.45
Impact — Proponents of electrification may see their market dominance challenged by alternative low-carbon fuels.6
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Response to EU Methane Strategy

4 Aug 2020

Repsol Response to the Public Consultation on the EU Methane Strategy Roadmap (Attached file)
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

Repsol welcomes the opportunity to provide initial opinion to the EC's Roadmap on the EU Strategy for a Sustainable and Smart Mobility. Recommendations: • Transport will remain the backbone of the European economy and we need to ensure our transport system, whilst progressively decarbonising, remains competitive, energy secure and affordable. • Society is demanding solutions for more energy, delivered in new and better ways for a low-carbon future and this is why low-carbon liquid fuels (LCLF) – biofuels/e-fuels – will have an important role to play in delivering secure, reliable and affordable energy that is technologically advanced and climate friendly. LCLF are essential in achieving the 2050 climate targets. Currently, no legislation recognises the contribution of LCLF to the improved CO2 performance of vehicles. We therefore ask policymakers to put in place a regulatory framework that reflects this positive contribution. • The affordability of low-carbon alternatives to petroleum-based liquid fuels such as sustainable biofuels and e-fuel is key to reduce net CO2 emissions in road transport. In this sense, we consider that improvement of these technologies should also be taken into account as a complementary measure. Once the supply is ensured, renewable liquid fuels are able to instantaneously provide the whole existing fleet with CO2 abatement, without having to wait for a long fleet turnover. • Similarly, biofuels (both gas and liquid) could play a significant role in accelerating early decarbonisation of shipping and aviation in the short-term. Biofuels allow integration of variable renewable energy without the need for massive investment in new infrastructures or in the replacement of the vessel and aircraft engines. • Hydrogen has an essential role in the energy system integration and has a wide range of applications. It can be used as an alternative fuel in transport (heavy-duty vehicles, aviation and maritime; none of them electrifiable in the medium-term) and we recommend the EC opt for a technology-neutral approach, ensuring all forms of clean hydrogen technologies can fulfil their potential in all upcoming initiatives and play their complementary role in achieving the climate-neutrality goal. • The future mobility measures should be aimed at facilitating the implementation of the alternative fuels infrastructures in different situations, e.g. hydrogen, liquid biofuels and e-fuels, LPG/bio LPG, NG/bio NG, and electricity for light road transport; liquid biofuels, NG/bio NG and LPG/bio LPG for heavy duty transport; liquid biofuels, NG/bio NG and electricity for ports and biofuels/e-fuels for airports. • Technology neutrality and well-defined associated investments in the short and mid-term are required to achieve the 2050 objective in a cost-efficient manner and are crucial to accelerating clean energy innovations. A level playing field for all energy sources and technologies will allow companies to adopt whatever technology is most appropriate to achieve the result, stimulating innovative and cost-efficient solutions at all times, and ensuring an affordable and just transition. • We recommend discussing any agreed EU legislation on CO2 pricing for aviation, maritime or other transport modes with trading partners and other third countries through diplomacy and bilateral negotiations in order to minimise negative impacts of regulatory overlaps. Upscaling EU legislation to the plurilateral or multilateral level would be most effective for reducing global transport emissions. • In order to deliver economic recovery and greater GHG emission reductions, public and private sector efforts should now become more focused on scale and costs. We believe that public support should be also direct to industrial-scale carbon management projects. Industry can deliver the scale of projects required to reach the EU climate goals while, as a priority, maintaining existing jobs and stimulating the creation of new ones.
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Response to A EU hydrogen strategy

8 Jun 2020

Repsol welcomes the European Commission’s intention to present an EU Hydrogen Strategy, as well as the opportunity to provide feedback to its Roadmap. Please find attached Repsol’s comments.
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Response to Strategy for smart sector integration

8 Jun 2020

Repsol welcomes the European Commission’s intention to present an EU Strategy on Smart Sector Integration, as well as the opportunity to provide feedback to its Roadmap. Please find attached Repsol’s comments.
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Repsol urges technology neutrality and support for renewable fuels

2 Jun 2020
Topic — The European Commission is developing stricter emission standards for all combustion-engine vehicles.
Message — Repsol urges policymakers to adopt technology neutrality and avoid bans on combustion engines. They suggest financial incentives for fleet renewal and the inclusion of renewable liquid fuels.123
Why — This would allow Repsol to continue selling liquid fuels for existing vehicle fleets.4
Impact — Environmental groups lose if policy favors combustion engines over faster electric vehicle adoption.5
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Response to Minimum standards for benchmarks labelled as EU Climate Transition and EU Paris-aligned Benchmarks

6 May 2020

Repsol, a global multienergy company committed with the ambition to be net zero emissions in 2050, is aware of the importance of the EU sustainable finance framework to reorient capital flows towards sustainable investments and appreciates the opportunity to provide feedback on climate benchmarks. We consider climate benchmarks as a suitable instrument for investors to align their investment strategies with climate objectives, increasing transparency in the markets. Recommendations Companies setting and publishing GHG emission reduction targets: Increasing the weight of companies committed to a low emissions future in the calculation of benchmarks is absolutely necessary. Those companies with a clear strategy based on targets and ambitions setting and committed with the EU ambition to achieve net zero emissions by 2050 should be taking into account. We think the proposal of 7% of reduction in GHG emissions for at least 3 consecutive years doesn´t fit for this purpose. All available and emerging technologies will be needed. This means that the GHG emission reduction of a transition company will not be linear but will have a saw tooth shape as these new technologies become available on the market. For all these reasons, we think the criteria should be companies with indicators that include scope 1+2+3 with targets set in the medium /long term allowing to measure the progress of those companies in the transition process. As an example, Repsol has defined a carbon intensity indicator in g CO2e/ MJ to establish its emissions reduction targets in 2020, 2025, 2030 and 2040 based on the scope 1+2+3, until the ambition of Net Zero Emissions is reached in 2050. Equity allocation constraint and exclusions: At this point it seems that the proposal leads to an inconsistency. On one hand, it establishes that the exposure of EU Climate Transition or EU Paris-aligned Benchmarks to the sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006 shall be at least equivalent to the exposure of the underlying investable universe to those sectors. But on the other hand, it excludes, for example companies that derive 10% or more of their revenues from the exploration, extraction, distribution or refining oil fuels. If climate benchmark really wants to reflect the reality of the market for this industry, it should fix a higher percentage aligned with the media of the sector and reduce it along the time progressively. This methodology would give companies in this sector the opportunity of being part of the solution and let them to evolve towards a low emission future. Carbon intensity indicator: As reduction rhythms could be different by sector based on the appearance of disruptive technologies, we suggest to define different carbon intensity indicators by sectors. In this sense, GHG intensity defined as metric grams of CO2 per MJ could be appropriate to compare energy companies. Reference temperature scenario: The Paris Agreement holds the increase in the global average temperature to well below 2°C at the end of the century, encouraging to limit it to 1,5 degrees. So, 1,5 degrees is not the target but the ambition. Likewise, these commitments and the way they are reached will depend on the society needs. Hence, those scenarios should be a reference and not a target themselves. In addition, these scenarios don´t take into account new and disruptive technologies that could change the path (as CCUS). GHG emissions phases and calculation of a baseline: We agree that for many sectors there is no currently quality data available for Scope 3 GHG emissions and it is necessary to set out an appropriate phase-in timeline. However, this process can affect the calculation of the annual GHG emission reduction percentage and make it difficult to establish a baseline. For this reason, we encourage the Commission to evaluate the option of setting reduction targets in the medium term instead of an annual criteria.
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Repsol shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement as well as the EU’s 2050 carbon neutrality objective. In this sense, on December 2nd, 2019, Repsol published its aim to become a net zero emissions company by 2050, making it the first oil & gas company in the world to assume this ambition. As published on March 25th, 2020, amidst the current extraordinary conditions, Repsol continues to pursue its goal to achieve net zero carbon emissions in 2050, focusing on leading the supply of low-emissions energy that the world needs. Repsol welcomes the opportunity to provide initial feedback to the European Commission’s (EC) Initial Impact Assessment of Low-emission vehicles – improving the EU’s refueling/recharging infrastructure. The following is our feedback to the EC’s proposals set in its “Combined Evaluation Roadmap/Inception Impact Assessment” document: 1. Concerning Problems 1 and 2: possible measures to extend the scope of the regulatory framework including differentiation for light and heavy-duty road transport infrastructure, ports and airports. These possible measures should be aimed at facilitating the implementation of the alternative fuels infrastructures (AFIs) in different situations, e.g. biofuels, LPG and bio LPG, natural gas (NG) and electricity for light road transport; biofuels, NG and LPG and bio LPG for heavy duty transport; biofuels, NG and electricity for ports and biofuels for airports. 2. Concerning Problems 1 and 2: possible measures to strengthen requirements for roll-out of alternative fuels infrastructure to ensure minimum coverage of the road transportation network, …. We suggest measures to focus on the following aspects of the AFI network: - Enforce the adequacy of each technology to its foreseen use. In the case of electric vehicles (EVs), it doesn’t make sense to install a 3.7 kW charging point in a service station nor a 175-350 kW one at home. - Ensure proper maintenance of the AFI. Given the present autonomy of the EVs, special attention should be paid to the proper maintenance and the availability of the facilities by the operator. Otherwise, it would disincentive the use of these facilities by the end users. 3. Concerning Problem 3: possible measures to strengthen interoperability requirements under AFID, including also communication protocols, and provisions related to consumer information. We suggest measures to ensure different options for means of payment. The customer should have different payment options (apps, RFID cards, etc.) available at the refueling points. 4. Concerning Problem 4: possible measures to strengthen provisions on developing “smart recharging infrastructure”, in a technologically neutral way. As mentioned in Point 2, it is essential that the AFI is fully operative. This only can be achieved if the operator can monitor and have access to real time information. Therefore, these facilities need necessarily to be smart ones. Repsol stands ready to provide further input to the upcoming consultations.
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Response to Climate Law

30 Apr 2020

Repsol, as a global multienergy company committed with the ambition to be net zero emissions in 2050, welcomes the EU’s 2050 carbon neutrality objective and appreciates the opportunity to provide feedback to the proposed European Climate Law. Repsol also welcomes the long-term predictability that the Climate Law aims to provide. The EU climate neutrality target as well as the milestone targets on the pathway to 2050 need to be accompanied by an enabling and coherent policy framework. EU policies, including EU financing and funding mechanisms, should facilitate a cost-efficient energy transition while ensuring that no one is left behind. It is essential that EU policies provide a predictable investment climate for all necessary low-carbon technologies, and security for investors and the real economy actors. Recommendations: 1. A world-wide approach. Addressing climate change requires commitment from all emitters worldwide, as well as global cooperation among countries and regions. To this end, as the EU reflects on its own contribution to global decarbonization efforts, Repsol would like to stress the importance of international cooperation, in particular by an effective implementation of Article 6 of the Paris Agreement. In this context, COP26 in Glasgow offers an excellent opportunity for the EU to show its continued commitment to a global approach to tackling climate change. 2. The role of energy-intensive sectors in reaching climate neutrality. The European Climate Law should provide a stable, long-term framework for EU policies that drive investments in low-carbon technologies such as CCUS and low-carbon liquids and gases, and recognize the role that solutions provided by the oil and gas industry can play in reaching a climate neutral EU economy. It is strongly suggested that the energy intensive sectors be included in all funding instruments allowing companies to carry out the required investments in order to achieve the carbon neutrality. 3. Technology neutrality and well-defined associated investments in the short and mid-term are required to achieve the 2050 objective in a cost-efficient manner and are crucial to accelerating clean energy innovations. A level playing field for all energy sources and technologies will allow companies to adopt whatever technology is most appropriate to achieve the result, stimulating innovative and cost-efficient solutions at all times, and ensuring an affordable and just transition. For instance, in the coming decades a massive deployment of renewables is expected, mainly in the electricity sector; thus bringing further challenges in terms of security of supply. Firm and flexible solutions will be needed in order to optimize renewable production and avoid curtailments, as well as same opportunities for all possible technology solutions. 4. Realistic and achievable targets. Both challenges of climate change mitigation and maintaining EU industries’ competitiveness should go hand in hand. Therefore, it is crucial to have clear, realistic and achievable targets based on a thorough socio-economic assessment and enabling and coherent policies. 5. EU industry competitiveness. A mid-term increase of emission reduction targets may further jeopardize the EU industry competitiveness when compared to other countries. This may be exacerbated in the aftermath of the COVID-19, as countries outside EU may consider loosening their climate ambitions for the sake of economic recovery. 6. Thorough and transparent impact assessments. Due to uncertainties related to R&D, technology, international climate policy and other macroeconomic and geopolitical developments between now and 2050, we strongly suggest that the Climate Law should include regular, thorough and transparent evaluations and impact assessments, not only for the EU as a whole but also for its Member States, to ensure that all economic, social and environmental goals are being progressed during the transition.
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Response to Climate change mitigation and adaptation taxonomy

24 Apr 2020

Repsol, a global multienergy company commited with the ambition to be net zero emissions in 2050, is aware of the importance of the EU taxonomy framework to reorient capital flows towards sustainable investments and appreciates the opportunity to provide feedback on this IIA. Recommendations: A technology neutral approach. The EU Taxonomy, and its specific Technical Screening Criteria (TSC), should adopt an inclusive approach allowing all different technologies that can contribute to the energy transition to be part of the solution. Likewise, the criteria should be flexible enough to adapt to market needs, considering the scalability of a given technology and its potential applicability to multiple sector of activities. Transitional activities. Repsol supports the introduction of the category of “transitional activities” in the agreed EU Taxonomy Regulation. All sectors should be encouraged to reduce their GHG emissions in line with the Paris Agreement. We believe that a list of transitional activities, with its specific TSC, needs to be created (instead of having these activities as a subcategory as outlined in the TEG report). Taxonomy should put the focus on the whole pathway and not just on the end of the road in 2050, going ahead through near-term steps that act as building blocks towards the ultimate aim of minimizing cumulative emissions. In this line: •Energy efficiency, methane and routing flaring management are key levers to achieve quick wins in the GHG emissions reduction next decade. •The manufacture of high-value chemicals will be required as an enabling activity due to the large number of applications to improve efficiency and reduce GHG emissions in other sectors. •Low-emission and blended fuels should be eligible (e.g. LNG in the shipping industry). •Natural gas should be recognized for the role it can play in the future. Gradual thresholds. TSC should reflect a gradual approach, incentivising transitional efforts. Setting too low thresholds too fast would exclude activities regardless of their potential contribution to the transition and ability to improve their environmental performance. The threshold level should be technology-neutral and based on GHG emission reductions on life cycle analysis to be achieved. It should allow all energy types that meet the threshold to be accepted. As an example, we believe that the threshold of 100gCO2e/kWh proposed by the TEG on electricity generation from gas, based on sector emission target and electricity demand growth assumption, does not reflect short-medium term industrial reality. Economic & social impacts. Based on current technologies and anticipated learning curves, the cost for implementing low-carbon solutions is likely to be high. The Taxonomy, and its TSC, will need to safeguard the international competitiveness of EU industries and avoid off shoring of manufacturing activities to countries with lower climate ambitions. Consequences in terms of employment and standards of living of EU citizens should also be taken into account.We would like to highlight the Report of the Expert Panel on sustainable finance “Mobilizing Finance for Sustainable Growth” with recommendations for Canada.This approach tries to safeguard the competitiveness of its industries.It is based on a bottom-up approach where the first step is to map the long-term path to a low-emissions scenario, sector by sector, with an associated public/private capital plan. It supports Canada’s oil and natural gas industry in building a low-emissions future. Timelines to implement the EU Taxonomy. The new reporting obligations will require Companies covered by Non Financial Reporting Directive to notify its level of alignment with the taxonomy. For that, companies will have to stablish new schemes to gather and facilitate data. To ensure a proper implementation of the disclosure obligation, we encourage the Commission to evaluate the possibility of retain the principal of one or two pilot years.
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Response to FuelEU Maritime

24 Apr 2020

Repsol is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. We share the world’s ambition to reach climate neutrality in the framework of the Paris Agreement, as well as, EU’s 2050 carbon neutrality objective. In this sense, on December 2nd, 2019, Repsol published its aim to become a net zero emissions company by 2050, making it the first oil & gas company in the world to assume this ambitious goal and positioning the company at the leading edge of the sector in the fight against climate change. As published on March 25th, 2020, amidst the current extraordinary conditions, Repsol continues to pursue its goal to achieve net zero carbon emissions in 2050, focusing on leading the supply of low-emissions energy that the world needs. Repsol welcomes the opportunity to provide initial feedback to the European Commission’s (EC) Initial Impact Assessment on the FuelEU Maritime Initiative. We welcome the EC’s recognition of key challenges to decrease GHG emissions from shipping, such as lack of regulatory predictability and high risk of investment choices, technological aspects and price factors, interdependency issues and avoidance of carbon leakage. Our industry is looking forward to closely cooperate with all the relevant stakeholders in the future and offer sustainable and cost-effective solutions. With this in mind, we would like to encourage the EC to consider the following recommendations: 1. EU industry competitiveness with a global approach. The sector is committed to reducing CO2 emissions in maritime transport as quickly as possible, in line with the objectives of the IMO, always maintaining the competitiveness of the European economy. Given the nature of the maritime sector, it will be particularly vulnerable to carbon leakage as Europe develops its decarbonisation agenda. We recommend that global solutions to shipping emissions are sought at IMO level as much as possible and maintaining a global competitive playing field. 2. Technology neutrality. The decarbonisation of maritime transport opens up many possibilities for the development and placing on the market of new technologies. To achieve it, all enabling technologies helping to accomplish climate objectives must be taken into account. The EU has an exceptional opportunity to pioneer low-carbon technologies for the sector and serve as a testing center for the development and deployment of alternative and low-carbon fuels (ranging from liquids such as bio- and e-fuels, to LNG, and renewable gases). 3. Certainty for the sector. There are many elements that need to be considered when choosing the right mix of alternative fuels, such as return on investment, compatibility with the existing assets and infrastructure, short vs long-distance, emissions reduction potential, technology maturity, and many others. The sector needs to have certainty about those fuels (e.g. low sulphur marine fuel) valid today will remain so throughout the useful life of the ships, mindful that a supportive policy framework will be indispensable in achieving climate neutrality and the decarbonisation of shipping. 4. The role of LNG and biofuels in fuel switching. The EU should pursue decarbonisation, but also ensure the security of energy supply. LNG is one of the few products that can meet both requirements. Existing gas transportation and LNG bunkering infrastructure offer flexibility to the full transformation of the energy system. Similarly, biofuels could play a significant role in accelerating early decarbonisation of shipping in the short-term. The data suggest that sustainable biofuels currently available are under-utilised and could potentially meet shipping’s energy needs of today. Therefore, LNG and biofuels allow integration of variable renewable energy without the need for massive investment in new infrastructures or in the replacement of the vessel engines.
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Repsol urges carbon border mechanism to protect European energy exports

1 Apr 2020
Topic — A legislative proposal to place carbon prices on imported products entering Europe.
Message — Repsol argues that the mechanism must cover exports to maintain global competitiveness. It should complement existing free carbon allocations to prevent leakage across all markets.123
Why — Maintaining free allowances alongside import taxes would significantly reduce their overall tax burden.4
Impact — Foreign producers lose their price advantage when exporting high-carbon goods into Europe.5
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Response to Revision of the Energy Tax Directive

31 Mar 2020

Repsol is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. Committed to an energy transition toward a lower emissions future we support the European Green Deal’s ambition for climate neutrality in 2050. We believe that the Oil & Gas sector has an important role to play in responding to this challenge being, thus, a relevant stakeholder to consider in the review process of the Energy Taxation Directive. Repsol welcomes the opportunity given by the Commission to provide input to the publication of the inception impact assessment on the review of the Energy Taxation Directive of March 4th, 2020. Under its commitment to lead the energy transition, in line with the Paris objectives and the United Nations’ Sustainable Development Goals, Repsol is the first energy company to make the commitment to achieve net zero emission by 2050. This target includes emissions from both our production and our products, so we have therefore established intermediate goals in 2025, 2030, and 2040 (https://www.repsol.com/imagenes/global/en/ON02122019_repsol_strategy_against_climate_change_tcm14-170857.pdf) . Repsol is convinced that a new energy model based on innovation and technology is necessary. Consequently, the revision of the ETD should consider regulatory measures aimed to encourage the investments in new technologies and the use of alternative and more sustainable energy, but always respecting a technology neutral approach. Repsol supports a reform of fuel and energy taxation that should invite producers to research and commercialize low-carbon fuels. Taxation can be an important tool to provide strong market signals for the development of low-carbon fuels. The Energy Taxation Directive itself provides examples of successful precedents where a favourable tax treatment has enabled that certain hydrocarbon gains market share by replacing others with higher emissions (for example, biofuels gained market share in the countries that took advantage of the allowance envisaged by article 16 of the Energy Taxation Directive by applying an exemption or reduced rate to these products; that was the case for Spain up to December 31th, 2012). Currently all liquid fuels are taxed at a similar level regardless of carbon intensity. Zero or very low tax for low-carbon liquid fuels would facilitate fuel pricing that is both socially acceptable, and able to contribute to a business case for investments. Repsol welcomes that the Energy Taxation Directive review will evaluate on how to promote adequately greenhouse gas emission reduction via several routes, including via alternative fuels. Within the list of indicated alternative fuels, Repsol would like to see that all sustainable biofuels are considered in the Energy Taxation Directive review and not as indicated in the inception impact assessment only the advanced biofuels. Lastly, but not least, Repsol feels obliged to call the attention on the need for carefully assess the impact on two particular aspects: - Competitiveness of peripheral countries of the EU: (i) much more dependent on road transport, maritime transport and aviation, and (ii) nearest to other economical areas with lower environmental standards. - Regressive distributional repercussion on the low-income households. This concern about the impact on the competitiveness of companies and low-income households becomes even more crucial at this time due to the adverse economic consequences of the COVID-19 pandemic, which makes a transition period recommended in order to adapt business models to the new environment. Repsol is willing to become an active participant into the next stages of the review process of the Energy Taxation Directive.
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Response to Revision of Non-Financial Reporting Directive

27 Feb 2020

The Commission has initially identified 3 policy options to review the NFRD. Repsol believes that NFRD should be revised and strengthen, modifying current non-financial reporting requirements in accordance with EU Commission’s option 3 taking into account the following requests: 1) Specifying in more detail what non-financial information companies should report: A reporting framework should help companies and stakeholders understand a company’s material business impacts. The NFRD revision should recognize that material issues vary greatly based upon a company’s size, operating locations and customer base, among other factors. In order to make sustainable investment decisions and promote socially responsible investment analysis, disclosure should be focused on material and relevant information. In order to ensure that the material issues on which companies report are considered valid by investors, analysts and civil society organizations, materiality analysis should be requested as an element of non-financial information, and regulations should provide reference reports that assure stakeholders that these analyses comply with the basic accountability principles of inclusiveness, relevance and responsiveness. Frameworks of reference should help to ensure that the results of these analyses are not undermined. 2) Requiring a non-financial reporting standard: A reporting framework should be clearly defined, with technically robust terms and measurements that should differ between sectors. Trying to create a uniform set of standards to measure and compare non-financial risks across very different companies operating in very different industries, across various jurisdictions, and therefore facing very diverse non-financial challenges may not fit the purpose. In this sense, international non-financial reporting frameworks like GRI or SASB consider a sectorial perspective. Moreover, companies could benefit from the development of sectorial guides. A unique/ harmonized non-financial reporting standard is essential for guarantying that analysts and investors can take sufficient account of sustainability-related risks and opportunities, or of the social and environmental impacts of their investments. This may prevent risks to the economy from investments that do not adequately price in sustainability-related risks, and guarantee that capital flows to companies that contribute to resolving sustainability-related problems. 3) Strengthening the provisions regarding the assurance of non-financial information: In accordance with the provisions of Directive 2014/95 / EU, the auditor's performance will be limited only to the verification that the non-financial information has been provided in the corresponding reports. We consider non-financial information independent limited assurance verification should be established as mandatory. 4) Clarifying and further harmonising provisions regarding where non-financial information should be reported (with regard to publishing such information in the management report and/or in a separate report): We believe that the Management Report should be the report containing no financial information and avoid to have a separate report (since in the investment decisions and in the valuation of the companies it is necessary to take into account financial and non-financial information it is very useful that they are in a single document). Local non-financial information disclosure regulations existing within the EU are introducing significant differences in this issue, which has a direct impact in the approach, extension and contents of the report. This hinders proper comparability of the reported information across companies and sectors. 5) Strengthening the enforcement regime and promoting greater supervisory convergence: Criteria used for non-financial information assurance should be harmonized across countries. If assurance is based on local regulations, these criteria may differ.
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Response to Climate Law

6 Feb 2020

Repsol shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement. On December 2nd, 2019, Repsol published its aim to become a net zero emissions company by 2050, making it the first oil & gas company in the world to assume this ambitious goal and positioning the company at the leading edge of the sector in the fight against climate change. As such, Repsol welcomes the EU’s 2050 carbon neutrality objective and appreciates the opportunity to provide feedback for the Climate Law Roadmap. We would like to encourage the Commission to consider the following recommendations: 1. A world-wide approach. Addressing climate change requires commitment from all emitters worldwide, as well as global cooperation among countries and regions. To this end, as the EU reflects on its own contribution to global decarbonization efforts, Repsol would like to stress the importance of international cooperation, in particular by an effective implementation of Article 6 of the Paris Agreement. In this context, COP26 in Glasgow offers an excellent opportunity for the EU to show its continued commitment to a global approach to tackling climate change. 2. The role of energy intensive sectors in reaching climate neutrality. The European Climate Law should provide a stable, long-term framework for EU policies that drive investments in low-carbon technologies such as carbon capture, use and storage (CCU and CCS) and low-carbon liquids and gases, and recognize the role that solutions provided by the oil and gas industry can play in reaching a climate neutral EU economy. It is strongly suggested that the energy intensive sectors be included in all funding instruments allowing companies to carry out the required investments in order to achieve the carbon neutrality. 3. Technology neutrality and well-defined associated investments in the short and mid-term are required to achieve the 2050 objective in a cost efficient manner, as mentioned in the Roadmap. We believe that a technologically neutral approach is crucial to accelerate clean energy innovations: A level playing field for all energy sources and same opportunities for all technologies will allow companies to adopt whatever technology is most appropriate to achieve the result, stimulating innovative and cost-efficient solutions at all times. 4. The proposed impact of the intermediate 2030 target of 50-55% GHG emissions reduction should be further analyzed. In the case of the refining and chemical sectors, the Technological Readiness Level (TRL) requirements may not match the 2030 deadline, even if massive investments in research and innovation are committed in the short-term. 5. Thorough and transparent impact assessments. Given the fact that the Climate Law proposal will not be accompanied by a full impact assessment and the uncertainties ahead between now and 2050, we strongly suggest that the Climate Law should include regular, thorough and transparent evaluations and impact assessments, in line with the Better Regulation principle, to ensure that all objectives, such as the wellbeing of citizens, the prosperity of society, the competitiveness of the economy, energy efficiency and security, health, protection of vulnerable consumers, fairness and solidarity across society and regions and a science-based approach, are being progressed during the transition.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

25 Nov 2019 · EU Sustainable Finance action plan

Response to Revising the rules for free allocation in the EU Emissions Trading System

8 Jul 2019

Repsol welcomes the intention from the Commission to propose adjustments to free allocation of emission allowances due to activity level changes. The proposed relative threshold of 15% activity level change is however not sufficient to ensure the alignment of allocation level for large installations, like refineries and petrochemicals, with their actual activity level. Repsol is in favour of an absolute threshold as an alternative to the relative one referred to in Article 10a (20). One of the reasons is the necessity for the EU ETS to keep incentivizing the operators of large and complex installations to invest in the best available and efficient technologies. The use of only a relative threshold discriminates between operators of (sub)-installations of different size investing in the same highly performing unit since the level of free allocation given to the smaller installation would be adjusted, which might not necessarily be the case for the larger ones. Article 3 As regards reporting requirements, annual reporting on activity level of each sub-installation starting from 2021 constitutes an additional administrative burden to operators. This burden should be minimized in two ways. First, by applying, for example, a screening quality analysis, while requiring a “fully verified approach” only for those cases where the screening approach indicates that the change in activity level is 10% or higher. Second, the provision in Art. 3. 2(2) allowing competent authorities to require from operators to also report on any of the additional parameters included in section 3 of Annex IV to Delegated Regulation (EU) 2019/331 in the activity level report, should be deleted. We note that the article 3.4 does not foresee any deadline for the competent authority to assess the report. We suggest to mirror the time left to operators to submit any additional data once the above-mentioned assessment has been performed. Article 5 Repsol regrets the absence of an absolute threshold that would trigger the adjustment of the allocation as an alternative of the 15% relative threshold. We also would like to reiterate our support for a strict linear approach in free allocation, without unnecessary complexity to the scheme. We do not support the provision in article 5.2 and the further adjustments that are conditioned to the exceedance of the nearest 5% interval. In that respect we find disproportionate losing all additional allowances as soon as one misses the relative 15% threshold by 0.1% compared with the requirement to exceed another quasi 5% range for further adjustments. We do not support the provision in article 5.4 according which if the activity level of a sub-installation is reported as zero, the free allocation of this sub-installation shall be set to zero in the following year. As formulated that provision would have the effect that half of the activity level of the year following the year with no activity level would never be recuperated by the operator. This penalty is not supported by the ETS directive and we suggest its removal. In the event the provision would nevertheless remain in the final text, we propose that where the operator resumes activity in one of the following calendar years, the adjustment for the following calendar year shall be based on the average of the two last calendar years with non-zero activity. Article 6 Activity level reductions due to improvement in energy efficiency (EE) should unambiguously be excluded. In that respect, an operator should be able demonstrate that the decrease of a sub-installation activity level is due or partially due to increased EE at that sub-installation. An explicit formulation should guarantee that energy efficiency measures would not be disincentivised.
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Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

26 Apr 2019 · Gas role in teh Long Term Strategy

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

5 Feb 2019 · Sustainable finance

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič), Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

5 Feb 2019 · Sustainable Finance

Meeting with Elżbieta Bieńkowska (Commissioner) and

27 Sept 2018 · Energy, industry and decarbonisation

Meeting with Miguel Arias Cañete (Commissioner) and

27 Sept 2018 · Innovating for a sustainable future

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

27 Sept 2017 · Gas policy in the EU

Meeting with Miguel Arias Cañete (Commissioner)

20 Feb 2017 · ETs, carbon price,

Meeting with Dominique Ristori (Director-General Energy)

29 Sept 2016 · Energy policy

Meeting with Dominique Ristori (Director-General Energy)

28 Sept 2016 · Energy policy

Meeting with Miguel Arias Cañete (Commissioner) and EPIA SolarPower Europe and

24 May 2016 · Business Forum EU-ALGERIA

Meeting with Valdis Dombrovskis (Vice-President) and

1 Oct 2015 · Corporate Tax Transparency

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

17 Sept 2015 · European energy policies

Meeting with Dominique Ristori (Director-General Energy)

17 Sept 2015 · European energy policies

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Investment in Algeria

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 Colin Scicluna (Cabinet of Vice-President Johannes Hahn)

5 May 2015 · situation in Libya and engagement in country

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

24 Mar 2015 · Exchange on the current EU energy and climate policy topics

Meeting with Miguel Arias Cañete (Commissioner)

13 Feb 2015 · Energy Union