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RWE AG

RWE AG

RWE is a German energy company investing in renewable energy, offshore wind, solar, and batteries while phasing out coal by 2030 to reach net zero by 2040.

Lobbying Activity

RWE demands simpler Taxonomy rules and removal of gas deadlines

5 Dec 2025
Topic — The European Commission is reviewing technical screening criteria for the EU Taxonomy environmental act.
Message — RWE requests a 25% reporting reduction and the removal of redundant environmental checks in the EU. They also seek to abolish the 2035 deadline for gas plants to switch to hydrogen.123
Why — This would lower administrative costs while ensuring long-term investment certainty for existing energy assets.45
Impact — Climate advocates lose a fixed timeline for decarbonizing gas infrastructure and stricter environmental oversight.67
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Meeting with Dan Jørgensen (Commissioner) and Ørsted A/S and

1 Dec 2025 · Cross-border energy partnerships

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

12 Nov 2025 · Security of supply, climate and energy policies

Meeting with Michael Bloss (Member of the European Parliament)

12 Nov 2025 · EHS

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

12 Nov 2025 · Short introductory meeting / trade and competitiveness questions

Meeting with Peter Liese (Member of the European Parliament)

12 Nov 2025 · Austausch

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

12 Nov 2025 · Capacity mechanisms, hydrogen

Meeting with Kurt Vandenberghe (Director-General Climate Action)

12 Nov 2025 · EU ETS

Meeting with Christian Ehler (Member of the European Parliament)

12 Nov 2025 · Kraftwerksstrategie

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

12 Nov 2025 · EU energy policy and the contribution to competitiveness

Meeting with Maroš Šefčovič (Commissioner) and

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

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

24 Oct 2025 · Energy policies; industry challenges

RWE Backs Market-Led Energy Security, Warns Against Regulatory Overreach

13 Oct 2025
Topic — EU review of energy security framework following Russia's invasion of Ukraine.
Message — RWE supports measures reducing import dependency through domestic renewables but warns markets proved adaptable during the 2022 crisis. They urge the EU to focus on removing market barriers, avoid extending gas storage mandates, and respect subsidiarity by letting Member States create detailed rules.1234567
Why — This would reduce compliance costs and preserve market flexibility that benefits their gas operations.89
Impact — European consumers continue bearing costs of market interventions like storage mandates without clear benefits.10
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German energy giant RWE urges faster EU carbon border rules

25 Sept 2025
Topic — EU regulation on recognizing third-country carbon prices under carbon border adjustment mechanism.
Message — RWE requests the Commission accelerate implementation rules before January 2026 to provide clarity on carbon prices paid in third countries. They want CBAM discounts applied to all electricity traded on exchanges in countries with carbon pricing, and recognition of carbon credits as effective carbon prices paid.123
Why — This would reduce uncertainty and compliance costs for importing electricity into the EU.45
Impact — Environmental groups lose stronger carbon pricing if low-quality credits are recognized as equivalent.67
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RWE calls for harmonized CBAM carbon accounting across international regimes

25 Sept 2025
Topic — EU implementing regulation on calculating embedded emissions under the Carbon Border Adjustment Mechanism.
Message — RWE requests accelerated completion of implementing acts before January 2026. They seek standardized carbon accounting aligned with ISO standards and GHG Protocol. The company emphasizes harmonization between EU and UK CBAM regimes to avoid separate measurement systems.123
Why — This would reduce administrative costs by avoiding multiple compliance systems for different jurisdictions.45
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RWE calls for robust CBAM benchmarks to prevent importer loopholes

25 Sept 2025
Topic — EU rules on adjusting carbon border certificates for free ETS allowances.
Message — RWE requests accelerated implementation of CBAM rules before January 2026. They demand that CBAM benchmarks mirror EU ETS stringency to prevent importers from exploiting loopholes through minor product adjustments while EU installations must make significant emission reduction investments.12
Why — This would protect them from unfair competition with importers exploiting regulatory loopholes.34
Impact — Importers lose the ability to undercut EU producers through minor compliance workarounds.5
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RWE urges flexible BioCCS rules to accelerate carbon removal

22 Sept 2025
Topic — EU certification methodologies for permanent carbon dioxide removal activities like DACCS and BioCCS.
Message — RWE requests extending activity periods from 10 to 15 years to align with financing structures. They want simplified electricity verification rules and transitional incentives for capturing fossil CO2 from mixed waste sources. They seek to replace 'nameplate biomass consumption' with 'nameplate power production' to avoid locking facilities into current fuel sources.1234
Why — This would improve bankability of their BECCUS projects capturing 11-14 Mt CO₂ annually at Dutch plants.56
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RWE seeks legal clarity and simplified testing for energy reporting

15 Sept 2025
Topic — New rules for the authorization and supervision of energy market reporting entities under REMIT.
Message — RWE requests a legal recital confirming that platform submission satisfies disclosure obligations to avoid fines. They also argue that testing requirements should not apply to established reporting mechanisms.12
Why — This would protect the company from regulatory penalties and expedite the approval of existing systems.34
Impact — National regulatory authorities lose the ability to issue fines for specific market disclosure breaches.5
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RWE Warns Against Excessive Energy Market Reporting Burdens

15 Sept 2025
Topic — The European Commission is updating rules for reporting wholesale energy market data.
Message — RWE recommends shortening the reporting period and excluding forecast data to simplify requirements. They suggest limiting algorithmic tracking to a simple binary indicator and aligning terminology with financial regulations. Finally, they request a one-year implementation period after technical guidelines are finalized.123
Why — These changes would significantly lower compliance costs and reduce regulatory complexity for utilities.45
Impact — Energy regulators would lose the detailed oversight required to identify suspicious trading behaviors.6
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RWE urges streamlined EU CO2 network development

11 Sept 2025
Topic — This consultation covers a legislative initiative regarding EU CO 2 transportation infrastructure and markets.
Message — RWE recommends streamlining planning processes for carbon pipelines. They suggest prioritizing industrial clusters for a faster rollout. They also advocate for flexible rules that avoid strict profit controls.12
Why — RWE would benefit from faster project connections and reduced regulatory oversight during the early rollout.3
Impact — Smaller companies outside major industrial clusters could face restricted access to new CO2 transport networks.4
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Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

Meeting with Michael Bloss (Member of the European Parliament)

3 Sept 2025 · Energiepolitik

Meeting with Jens Gieseke (Member of the European Parliament) and Bayerische Motoren Werke Aktiengesellschaft and Gesamtverband der Deutschen Versicherungswirtschaft e.V.

3 Sept 2025 · Austausch zu EU Politik

Meeting with Jens Geier (Member of the European Parliament)

22 Jul 2025 · Exchange on the delegated Act on Low Carbon Hydrogen

Meeting with Jens Geier (Member of the European Parliament)

14 Jul 2025 · Exchange on the German Energy Capacity Mechanism

Meeting with Christian Ehler (Member of the European Parliament) and DHL Group and

2 Jul 2025 · RFNBO und Wasserstoff

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

26 May 2025 · Commodity Derivatives Consultation

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

23 May 2025 · EU Energiepolitik

Meeting with Angelika Niebler (Member of the European Parliament)

16 Apr 2025 · Omnibus Paket

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

8 Apr 2025 · Wind energy, electrification, competitiveness, permitting, grids

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

2 Apr 2025 · MiFID II commodities Consultation Paper (Chapter 1 - Data Aspects)

Meeting with Jens Geier (Member of the European Parliament)

13 Mar 2025 · State of the German Capacitiy Mechanism

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Eni S.p.A. and Cheniere Energy

11 Mar 2025 · Exchange of views with US/international oil and gas companies

Meeting with Tom Berendsen (Member of the European Parliament) and GLASS ALLIANCE EUROPE AISBL

25 Feb 2025 · Work visit

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

21 Feb 2025

RWE welcomes the opportunity to provide feedback on the Net-Zero Industry Act (NZIA) draft Implementing Act on the specification of non-price criteria in renewables auctions. This comes at a time where most renewables business cases are under high pressure due to severe supply chain bottlenecks and low electricity prices. Our impression is that the proposal, particularly on resilience, will seriously harm renewables build out in Europe. It results in substantially higher complexity, bureaucracy and cost compared to respective frameworks in international markets, e.g. the UK and US. This contradicts the contemporary political priorities for reducing bureaucracy burden, as foreseen with the Omnibus Simplification Package by the European Commission. NZIA auctions for Offshore Wind, Onshore Wind and Solar PV urgently need to come with two-sided CfDs and sufficiently high bid ceilings. The industry extremely suffers from the current market environment already and cannot absorb additional costs. Furthermore, RWE suggests the attached amendments which effectively contribute to resilient and sustainable supply chains, while limiting negative impacts on an affordable and secure energy supply. RWE asks the European Commission to take into account the attached key recommendations and proposed amendments to the draft Implementing Act. These proposals aim for urgently needed simplification in line with the current EU initiative of the Omnibus procedure, hence reducing negative impacts on society and industrial competitiveness.
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Meeting with Cristina Lobillo Borrero (Director Energy) and

19 Feb 2025 · Current market situation on hydrogen projects

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

5 Feb 2025 · MiFID II commodities review

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

4 Feb 2025 · MiFID

Meeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque)

4 Feb 2025 · Exchange with the CFO of RWE on MiFID/Energy Trading

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

24 Jan 2025 · Energiepolitik

Meeting with Dan Jørgensen (Commissioner) and

23 Jan 2025 · Discussion on the future of European energy policy and competitiveness.

Meeting with Jozef Síkela (Commissioner) and

23 Jan 2025 · Clean energy

Meeting with Wopke Hoekstra (Commissioner) and

22 Jan 2025 · Exchange of views on the decarbonisation of the energy sector and the Clean Industrial Deal

Response to Amendment to Registry Regulation in response to the ETS revision/Fit For 55 (Batch 2)

9 Jan 2025

The date to hand in verified emission reports should be postponed to a date after May 31. Reasons: The verified emission reports for the EU ETS 1 have to be handed in already on March 31. As the verifying entities are usually the same for ETS 1 and ETS 2, handing the report on the ETS 2 emissions is challenging for operators and verifiers. At least a national opening clause should be included. E.g. in Germany the energy tax declaration is due May 31 each year. Handing in ETS 2 reports means risk of correction and new verification efforts simply driving the costs.
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Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

6 Dec 2024 · Energiepolitik

RWE urges flexible hydrogen rules to kickstart the economy

25 Oct 2024
Topic — This consultation establishes the methodology for calculating greenhouse gas savings from low-carbon fuels.
Message — RWE requests allowing long-term electricity contracts and using project-specific emission values. They advocate for removing the 40% methane surcharge and introducing hourly emission accounting immediately.123
Why — Broader electricity sourcing options provide the flexibility needed to increase low-carbon fuel production.4
Impact — Environmental advocates may find that removing methane surcharges weakens the integrity of climate targets.5
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Meeting with Dennis Radtke (Member of the European Parliament)

23 Oct 2024 · EU Beschäftigungspolitik

Meeting with Nicolás González Casares (Member of the European Parliament) and ELECTRICITE DE FRANCE

22 Oct 2024 · Energy policy

Response to Update of minimum requirements for certification programmes for switchgear

14 Oct 2024

The draft of the Commission Implementing Regulation (EU) of 17 September 2024 establishing Regulation (EU) No 2024/573 of the European Parliament and of the Council on minimum requirements for, and the conditions for mutual recognition of, certificates for natural persons regarding the installation, maintenance, servicing , repair or decommissioning of stationary electrical switchgear containing fluorinated greenhouse gases and for the recovery of fluorinated greenhouse gases from stationary electrical switchgear and repealing Commission Implementing Regulation (EU) 2015/2066 states in Article 1, 1. a): This Regulation shall apply to natural persons who carry out the following activities: (a) installation, maintenance, servicing, repair and decommissioning of stationary electrical switchgear containing fluorinated greenhouse gases listed in Annex I, Annex II Section I and Annex III to Regulation (EU) No 2024/573. Accordingly, it is stipulated that all natural persons who install, maintain, repair and decommission stationary F-gas switchgear must be certified through training in accordance with the requirements of the regulation. In this case, this also applies to all activities on these switchgear that have no effect on the F gas tank. These activities represent the majority of all activities on these switchgear. In this case, these people would also be authorized to carry out work on the F-gas tank without experience in that work. In terms of the F-Gas Regulation, it would be advantageous to only train the group of people in accordance with the Implementing Regulation who also regularly work on the F-Gas tank. This would ensure that there is sufficient work experience in dealing with F-gases. In addition, the training effort would be reduced by applying it to the focus group.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

1 Oct 2024 · Energy markets

Meeting with Tiemo Wölken (Member of the European Parliament)

27 Sept 2024 · Grüner Wasserstoff auf dem Markt & im Verkehr: Der „H2-Filling Hub Lingen“ der RWE (staff level)

Meeting with Andrea Wechsler (Member of the European Parliament) and Handelsverband Deutschland

19 Sept 2024 · EU Energy and Industry Policy

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Sept 2024 · Energy Policy

Meeting with Andreas Glück (Member of the European Parliament)

17 Sept 2024 · Energy and Climate Policy

Meeting with Christian Ehler (Member of the European Parliament) and E.ON SE and

13 Sept 2024 · Energiepolitik - allgemein

Meeting with Daniel Caspary (Member of the European Parliament)

3 Sept 2024 · Energiepolitik

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

11 Jul 2024 · Energiepolitik allgemein

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Shell Companies and

10 Jun 2024 · review of the MiFID II commodities regime

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

31 May 2024 · Energiepolitik allgemein

Response to Recommendation to promote the development of innovative forms of solar energy deployment

28 Mar 2024

RWE generally welcomes the revised Directive (EU) 2023/2413 on the promotion of the use of energy from renewable sources and the EU Solar Energy Strategy. The implementation of both initiatives can significantly contribute to the achievement of the EUs renewable energy and climate targets. The ECs planned Recommendation to promote the deployment of innovative Solar PV represents a good starting point and needs to be followed by enabling adjustments of relevant energy, construction and nature legislation at EU and national level. RWE is involved in the development of Agri-PV, Inland Floating Solar PV and Offshore Floating Solar PV projects and thus recommends the following. Agri-PV solutions offer opportunities for a more sustainable and efficient use of land and resources. The following actions can promote its expansion: 1) Guidelines: Provide clear EU-wide definitions of the various Agri-PV technologies, compared to standard ground-mounted PV systems. Based on these guidelines the countries can establish or adapt their national Agri-PV standards 2) Economic efficiency: Establish clear and technology-specific tenders and financial support instruments for Agri PV solutions 3) Permitting: Standardize and simplify permitting processes. Remove compensation requirements, if Agri-PV will be deployed on existing arable land. Consider potential biodiversity net-positive environmental impacts 4) Taxation: Treat Agri-PV land like agricultural land in the case of inheritance 5) Agricultural system integration: Provide additional incentives and support for farmers to implement Agri-PV for promoting technological innovation in agricultural activities Inland Floating Solar PV (FPV) solutions increase space use efficiency and can have a positive impact on the environment and local communities. The following measures enable an accelerated development of Inland FPV: 1) Environment: Allow a higher coverage of water bodies by Inland FPV. Provide EU guidance on environmental impact assessments and support data collection and the publication of environmental impacts. Acknowledge positive environmental impacts of Inland FPV in permitting processes 2) Quality & Safety: Publish EU-level guidelines for technical and safety assessments. 3) Permitting: Adapt permitting procedures together with relevant water authorities and focus on access to water and allow dual-use of water bodies 4) Funding: Incentivise Inland FPV technology through dedicated auction schemes with adequate financial support options Offshore Floating Solar PV (FPV) solutions contribute to a more efficient use of maritime space and grid infrastructure. We recommend for an upscale of the technology: 1) Provide targeted financial support and incentive frameworks for allowing Offshore FPV technologies to mature and scale up 2) Develop targeted supply chain initiatives such as an industrialization and supply chain roadmap and the inclusion of Offshore FPV as Important Projects of Common European Interest (IPCEI) for further promoting existing European Offshore FPV supply chains and value creation 3) Implement tailored enabling instruments for Offshore FPV remuneration, such as well-designed CfD schemes at cost-reflective levels and reliable, publicly available auction schedules for Offshore FPV 4) Where Offshore Wind development is not economically or technically feasible: Identify suitable areas for stand-alone Offshore FPV installations in national Maritime Spatial Plans, complemented by a clear and robust regulatory framework 5) Launch coordinated research programs at EU level to identify and mitigate potential environmental and socio-economic impacts of Offshore FPV Furthermore, it is crucial to accelerate the grid and storage expansion for effectively integrating all renewable energy technologies into the energy system without further delay. Please find the detailed feedback of RWE in the attached PDF document.
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Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Mar 2024 · Clean Transition Dialogue with the Steel Sector

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Mar 2024 · Discussion of current challenges facing the European Steel sector attended by private industry as well as Ministers and official representatives of Italy, Romania, Poland, Czechia, Belgium, Hungary and Luxembourg

RWE Urges Flexible Technology-Specific Rules for Renewable Energy Auctions

1 Mar 2024
Topic — Guidance on using non-price criteria in auctions to support renewable energy.
Message — RWE requests technology-specific non-price criteria focusing on simple pre-qualification for smaller projects. They demand maintaining current 30% limits on the weight of non-price criteria.12
Why — This strategy minimizes bureaucratic burdens and reduces financial risks of project delays.3
Impact — Consumers could face higher bills as price ceilings rise to cover compliance costs.4
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Meeting with Sabine Verheyen (Member of the European Parliament)

1 Mar 2024 · Energy Policy and structural change

Meeting with Niels Fuglsang (Member of the European Parliament)

23 Feb 2024 · Grøn omstilling

Response to Guidance to facilitate the designation of renewables acceleration areas

22 Feb 2024

Feedback of RWE An effective implementation of renewables acceleration areas for speeding up the EUs energy transition Summary: RWE generally welcomes the revised Directive (EU) 2023/2413 on the promotion of the use of energy from renewable sources (RED), which has the potential to significantly contribute to the achievement of the EU renewable energy targets. Now it is crucial to rapidly and consistently implement the revised RED. Any delay harms the urgently required accelerated build-out of renewables in the EU. We strongly support the new concept of renewables acceleration areas, which can significantly accelerate planning and permitting processes for onshore wind and solar PV projects. However, renewables acceleration areas should not be applied for offshore wind projects due to longer lead times, substantially larger project scales, related legal risks and public acceptance, as well as effective centralized planning instruments already available for offshore wind through Maritime Spatial Planning. The following key points should be taken into account for ensuring an effective implementation of renewables acceleration areas: 1. As pre-condition for designating renewables acceleration areas, an effective and sufficient mapping of space for renewables projects in line with long-term national renewable energy targets needs to be ensured (Art. 15b). The mapping should only include sites with favourable conditions for renewables. In addition, the identified space needs to significantly exceed the theoretical requirement, as this ensures that most economically viable areas can be used and non-realised projects can be compensated for. 2. Ensure a significant combined size of new renewables acceleration areas with low environmental sensitivities (Art. 15c) for onshore wind and solar PV. It needs to be highlighted that renewables projects outside these areas are still possible and necessary under regular permitting rules. Renewables acceleration areas should be regularly updated, for taking into account potential technological developments. 3. Complementary to the mapping and designation of renewables acceleration areas, areas for grid and storage infrastructure (Art. 15e) need to be applied to a large extent as well. In combination with further instruments for accelerated infrastructure build-out this can prevent further project delays. In addition, the following fundamental principles should be taken into account when implementing the three planning instruments mentioned above: o Timely, but also diligently implement the measures, so that the full potential can be utilized. For this, it is also crucial that Member States provide sufficient resources for implementing these instruments, referring to Art. 16 (7). o Avoid any negative impacts on planned and existing projects of renewable energy generation and related infrastructure development, inside and outside the dedicated areas. This avoids adverse effects on renewables build-out. o Apply the overriding public interest (Art. 16f) of renewable energy and related infrastructure projects for the planning and permitting procedures, o Identify the space required for achieving the EU climate-neutrality objective in 2050. This increases planning security and allows for anticipatory investments by renewables supply chains and infrastructure developers. Please find the detailed feedback of RWE in the attached document.
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Meeting with Jens Geier (Member of the European Parliament)

31 Jan 2024 · Development of the renewable power market

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

26 Jan 2024 · Energiepolitik allgemein

Meeting with Maroš Šefčovič (Executive Vice-President)

19 Jan 2024 · Energy, clean transition

Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

12 Jan 2024 · Exchange on industrial and energy policy

RWE urges free emission allowances for renewable hydrogen production

20 Dec 2023
Topic — The Commission is updating rules for distributing free carbon allowances under the ETS.
Message — RWE requests that the production of renewable hydrogen be made eligible for free carbon allowances. They argue production benchmarks must be designed to ensure sufficient support for electrolysers.12
Why — This would provide financial support and lower costs for RWE's renewable hydrogen projects.34
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Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

8 Dec 2023 · Exchange on energy policy

RWE urges faster state aid approvals and simpler emissions rules

30 Nov 2023
Topic — The initiative aims to identify reporting requirements in EU legislation for simplification.
Message — RWE suggests implementing binding deadlines for state aid procedures to prevent multi-year delays. They also seek to eliminate overlapping reporting requirements within the Industrial Emissions Directive and energy efficiency laws.12
Why — Streamlined procedures would grant the company legal certainty and faster project implementation.3
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

11 Oct 2023 · Energy Transition

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Ørsted A/S and

6 Oct 2023 · Energy Transition

Meeting with Jens Geier (Member of the European Parliament)

29 Sept 2023 · Exchange on the Methane Regulation (staff level)

Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

14 Sept 2023 · Exchange on the gas market directive and EMD (staff level)

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

31 Aug 2023 · Energy transition

RWE supports competitive bidding but urges regional funding allocations

7 Aug 2023
Topic — This consultation concerns new competitive bidding rules for the EU Innovation Fund.
Message — RWE suggests allocating regional funding portions to ensure geographical balance across the EU. Funding rounds should target specific renewable products that have similar investment requirements. Rules for combining government subsidies with EU support must be clearly defined.123
Why — Higher investment thresholds and new project categories will reduce market competition distortions.4
Impact — Non-renewable low-carbon projects lose out if funding is prioritized specifically for renewable technologies.5
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RWE calls for limited and aligned sustainability reporting requirements

6 Jul 2023
Topic — Consultation on standards specifying how companies must disclose environmental and social performance.
Message — RWE recommends starting with a limited set of requirements covering only essential aspects. They argue that additional reporting should be omitted to avoid unnecessary complexity and maintain group-level data.123
Why — Simplifying these rules would reduce internal administrative efforts and protect sensitive commercial data.45
Impact — Investors and public data users lose comparable information and detailed corporate resource plans.67
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

31 May 2023 · Energy transition

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

23 May 2023 · Implementation of circular economy and chemical recycling

RWE urges permanent capacity mechanisms in EU power market reform

22 May 2023
Topic — The European Commission is proposing a reform of the EU’s electricity market design.
Message — RWE supports fixed-price contracts for new renewable projects but opposes applying them to existing plants. They want capacity payments to become a permanent feature to fund backup power plants. Additionally, they demand that temporary limits on renewable energy profits be removed immediately.123
Why — A permanent capacity market would provide long-term financial security for RWE’s power plant investments.45
Impact — Energy consumers might lose out if peak-shaving tools are replaced by more expensive capacity payments.6
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RWE calls for flexible and well-funded green energy auctions

17 May 2023
Topic — This consultation addresses the Net Zero Industry Act proposal to support European manufacturing.
Message — RWE wants a clear catalog of auction criteria reflecting technology-specific differences. They suggest using prequalification for complex standards and higher price caps for expenses.123
Why — Higher price ceilings would ensure that new environmental and social requirements do not undermine project profitability.4
Impact — Speculative bidders would face higher barriers to entry due to new technical and financial capability standards.5
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RWE calls for broader EU Taxonomy to support energy transition

2 May 2023
Topic — The initiative establishes a classification system for sustainable economic activities contributing to EU environmental goals.
Message — RWE requests including phosphorus recovery from sewage sludge through incineration and gasification. They propose lowering recovery rate requirements and recognizing post-mining site restoration as a sustainable activity.123
Why — This ensures the company can access green capital for its decarbonization investments.45
Impact — Groups advocating for higher recycling targets lose out due to lower recovery requirements.6
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Meeting with Jens Geier (Member of the European Parliament)

2 May 2023 · Exchange on the electricity market design (staff level)

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Rapporteur)

27 Apr 2023 · REMIT

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and Ørsted A/S and

21 Apr 2023 · Hydrogen bank

Meeting with Jens Geier (Member of the European Parliament, Shadow rapporteur)

5 Apr 2023 · Exchange on the methane Regulation (Staff Level)

RWE Urges Pragmatic EU Certification for Carbon Removals

22 Mar 2023
Topic — A European Commission proposal to establish a framework for certifying sustainable carbon removals.
Message — RWE calls for a pragmatic certification system that separates technical development from political influence. They request prioritizing methodologies for permanent industrial technologies like DACCS and BECCS to ensure a fast ramp-up.123
Why — This would allow RWE to monetize removals by integrating them into the EU-ETS market.4
Impact — Environmental groups could see weaker sustainability protections if stricter taxonomy-based criteria are abandoned.5
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Meeting with Kadri Simson (Commissioner) and

7 Mar 2023 · Exchange on the needed regulatory support to promote the deployment and manufacturing of the solar power in the EU and the EU’s support for the solar energy so far.

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

7 Mar 2023 · Energy Transition

Meeting with Jens Geier (Member of the European Parliament)

15 Feb 2023 · Exchange of view on RED and electricity market design (staff level)

Meeting with Kadri Simson (Commissioner) and

9 Feb 2023 · Electricity market design.

Meeting with Frans Timmermans (Executive Vice-President) and EPIA SolarPower Europe and

2 Feb 2023 · Hydrogen bank proposal and the Green Deal Industrial Plan

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and WindEurope and

1 Feb 2023 · Renewable energy

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Kadri Simson (Commissioner) and

26 Oct 2022 · Joint purchasing options.

Meeting with Virginijus Sinkevičius (Commissioner) and

7 Oct 2022 · To discuss maritime spatial planning (MSP), co-existence and multi-use of the space, permitting, regional cooperation, sustainability and recycling.

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

RWE urges faster permitting and flexible renewable energy zones

27 Jul 2022
Topic — The EU is consulting on accelerating permitting processes for renewable energy projects.
Message — RWE supports declaring renewables as an overriding public interest to speed up approvals. They propose turning all mapped sites into accelerated zones while renaming go-to areas to avoid creating restricted zones elsewhere.123
Why — Streamlined permitting would reduce project risks and lower financing costs for RWE.4
Impact — Environmental groups may see increased development in protected areas if exclusions are narrowed.5
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Response to Regulation on REPowerEU chapters

18 Jul 2022

The EU Commission is proposing to increase the budget of the Reconstruction and Resilience Facility (RRF) of the €700 billion Corona aid package, to finance the measures of the REPowerEU package. Under the Commission’s proposal, allowances worth €20 billion would be returned from the Market Stability Reserve (MSR) to the market by the end of 2026 through auctions – based on current market prices this corresponds to 200-250 million EUAs. By comparison, the number of allowances available in the EU ETS is currently being reduced by 38 million EUAs annually. The planned transfer would thus reverse emission reductions in the EU ETS of 5 years. The EU Commission's proposal is harmful to the EU-ETS and risks the successful transformation towards a climate-friendly industry: ▪ Emissions trading as a volume-based instrument is the central steering instrument for reducing greenhouse gas emissions in the EU. ▪ The EU ETS ensures the achievement of the politically set climate targets in the included sectors of energy/industry and should give the participants a stable signal for green investments. ▪ The Commission's proposal damages this mechanism. Firstly, the additional volumes lower the price and thus the incentives for green investments, such as the use of H2, market-driven RES expansion, and investments in climate-friendly industrial solutions. According to analysts, the measure will reduce the price by around 5 – 10 €/t CO2. ▪ Even more important, the mechanism proposed by the Commission undermines investor confidence, which is essential for long-term investments in the energy transition, especially in the industry sector. In the future, investors will have to fear that the steering instrument will become a financing instrument for the EU budget. It undermines confidence because this type of intervention cannot be calculated as it is EU budget driven instead of achieving climate protection targets. ▪ The EU Commission's proposal is also a zero-sum game. Although the EU budget increases, the price is paid by the member states: due to the price decrease, the member states receive lower auction revenues. In addition, the allocation of Carbon Contracts for Difference to enable industrial conversion becomes more expensive for the member states when CO2 prices are lower. ▪ Furthermore, the proposal contradicts the more ambitious EU climate protection policy as it reduces the CO2 price. ▪ The instrument is initiating a vicious circle via a price/quantity spiral. The lower the price, the higher the quantity that must be returned to the market to achieve the €20 billion. The higher the quantity, the lower the market price, and so on. As a result, market participants are unable to estimate the impact. Conclusion: The EU ETS should remain what it is: a steering instrument to ensure compliance with climate protection targets rather than a financing instrument. The EU Commission is setting a precedent for financing REPowerEU and in doing so it is destroying the most important feature of emissions trading: the confidence of participants in a functioning market.
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RWE warns industrial emissions proposal threatens energy security

23 Jun 2022
Topic — The Commission proposes updating environmental rules for large-scale European industrial facilities.
Message — RWE wants to keep existing pollution limit ranges rather than enforcing the strictest possible levels. They also seek to remove new mandates for energy efficiency and climate transformation plans.12
Why — These changes would avoid expensive technical upgrades and prevent the early closure of power plants.3
Impact — Environmental groups and citizens would have fewer legal tools to seek compensation for health damages.4
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Meeting with Jens Geier (Member of the European Parliament, Rapporteur)

1 Jun 2022 · Exchange on the gas market directive and the hydrogen economy

Meeting with Jens Geier (Member of the European Parliament)

1 Jun 2022 · Hochlauf des Wasserstoffmarktes

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Response to Sustainable corporate governance

5 Apr 2022

RWE fully supports the European Green Deal and the goal of a climate-neutral European Union by 2050. The Green Deal should enable the EU to transform its economy and put it on a more sustainable pathway. Therefore, RWE warmly welcomes the EU's various sustainability initiatives including the harmonisation of human rights and environmental due diligence obligations in the EU. To ensure that this harmonisation can also be successfully implemented in practice, we propose the following amendments: • Refining the Scope of Due Diligence: Currently, it is almost impossible for companies to monitor the entire supply chain according to the requirements of the CSDD without legal uncertainties arising. To ensure feasibility and the realistic possibility of achieving the objectives of the Directive, the due diligence requirements should differentiate between comprehensive requirements for direct suppliers and reasonable requirements for indirect suppliers. • Preventing Additional Civil Liability: The introduction of extensive civil liability rules for the provisions of the Directive would create enormous legal uncertainty and the risk of excessive litigation for companies with complex supply chains. The enforcement mechanism should rely on sanctions and administrative enforcement. • Focusing on Human Rights and Environmental Aspects: It is of great importance that the EU is moving forward ambitiously on climate policy. But the present proposal should focus on human rights and environmental due diligence. To avoid fragmented and incoherent regulation, the climate aspects should be dealt with in a separate legislative proposal to allow create a more coherent framework. • Aligning the CSDD with the CSRD, EFRAG, and the EU Taxonomy: Aligning the reporting requirements in the CSDD with existing or planned requirements is essential for robust and comparable reporting. As reporting requirements are increasing extensively, it is necessary to limit the requested disclosures based on a materiality assessment to identify the most important topics. • Safeguarding a Coherent Transposition by Unambiguous Definitions: Currently, the definitions of “appropriate measures”, “established business relationships”, “principal risks” or “principle adverse impacts” are too vague and leave a considerable amount of flexibility for the national transposition. To achieve greater harmonisation in due diligence and to create a level playing field, it is necessary to make the definitions clearer.
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Meeting with Kadri Simson (Commissioner) and

27 Jan 2022 · The CEOs of the leading wind energy companies presented the key barriers to renewable energy project permitting they had experienced, and suggest some possible good practices for the upcoming Commission guidance on this topic.

Meeting with Kadri Simson (Commissioner) and

8 Oct 2021 · • Short introduction of RWE; • Fit for 55 package, especially the revision of the Renewable Energy Directive; • Delegated Act on Art. 27.3 of the Renewable Energy Directive regarding criteria for renewable hydrogen.

Response to Revision of Non-Financial Reporting Directive

15 Jun 2021

RWE welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Strengthening reporting requirements including relevant sustainability aspects will lead to more transparency in corporate reporting while allowing organizations and companies to follow a transition path to a sustainable and economic business model. RWE regards the current reporting requirements as robust, but we welcome improvements concerning the comparability and comprehensibility of the information. As one of the world’s leading providers of renewable energy, RWE is fully committed to the European Union’s goal to transform Europe into the first low-carbon, resilient, and climate-neutral continent. Placing sustainability reporting on a similar level as financial reporting reflects the increasing importance of sustainability aspects. While ambitious and forward-looking reporting can unleash a huge potential for sustainable investments, reporting organizations might be faced with some challenges in adjusting their present reporting to new requirements, especially when only a limited timeframe is given for internal preparatory processes. It would be helpful to allow an adequate implementation phase. The aim to a better understanding of companies and their business activities beyond the financial focus is addressed by e.g. the materiality definition. Clarifying materiality is surely a good starting point to a harmonized reporting throughout the EU. A harmonized reporting standard like the EFRAG standard will strengthen the transparency and comparability of key sustainability aspects. It is very beneficial to include experience by well-known standard-setting organizations like GRI in preparation for the EFRAG standard. RWE welcomes a robust EU and global standard as comparability is crucial for a level playing field. Sector-specific standards will further ensure detailed comparability among sectors. Harmonization of reporting requirements should be kept at the European level as different implementations across the Member States would lead to competitive disadvantages for some companies. Consistent regulatory frameworks need to be ensured. With regard to the CSRD, harmonization with various directives is already addressed. We consider this as an efficient approach to avoid mismatched pieces of legislation. Reporting requirements should reflect future-oriented key metrics. As we see an increasing demand for sustainability information from various stakeholders, the selection of key metrics should reflect this demand. Reporting requirements should not result in disproportionate additional work for companies without actually creating added value for data users. For instance, reporting companies should retain flexibility in their choice of publication. A requirement to publish non-financial information in the management report could lead to time pressure and thus to imperfect reporting of the sustainability data. Extending assurance requirements beyond the limited assurance level would also lead to increased expenses. At the current status, we are lacking to see major benefits from a European Single Access Point (ESAP). For reporting organizations, this approach would lead to an increased effort while information is already published within the non-financial report. We are convinced that an ESAP would not decrease requests by e.g. rating agencies. Implementation of potential ESAP requirements in the companies will be much more complicated and unnecessarily expensive without creating added value. We suggest shifting this point of discussion after gaining experience from reporting according to the CSRD. Our first assessment concentrates on the CSRD and did not include amendments to the Accounting Directive, Audit Directive, and Transparency Directive. For further getting clarity on various details, we would appreciate a timely draft of the EFRAG standard(s).
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

As one of the world’s leading providers of renewable energy, RWE fully supports the European Green Deal as an ambitious framework and long-term strategy for making the European Union climate-neutral by 2050 while maintaining European competitiveness. As part of the European Green Deal, Sustainable Finance will play a central role in achieving the ambitious 2030 and 2050 emission reduction targets. RWE welcomes the consultation on the draft delegated act on the reporting obligations according to article 8 of the Taxonomy Regulation. The implementation of article 8 is an important milestone for the Sustainable Finance framework and the application of the Taxonomy Regulation. While ambitious and forward-looking reporting can unleash a huge potential for sustainable investments, the reporting requirements should not be too granular with limited added value, unnecessary complexity, and disproportionate additional reporting costs. Please find attached our comments and recommendations to the draft delegated act.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

1 Jun 2021 · Hydrogen

Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

16 Mar 2021 · Hydrogen

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WindEurope and

1 Feb 2021 · Meeting with the European offshore wind industry on the follow-up of the EU offshore renewable energy strategy adopted in November 2020

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

RWE is fully committed to an ambitious Taxonomy Regulation as a cornerstone of Sustainable Finance and an important pillar of the European Green Deal. We welcome the publication of the draft delegated act and appreciate the work done by the TEG and the Commission. However, we see room for improvement in some aspects: - DNSH criterion for climate change adaptation - Electricity generation from wind power - Manufacture of hydrogen - Electricity generation from hydro power - Storage of electricity. You'll find our detailed feedback on the issues mentioned above in the attached file.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans)

2 Oct 2020 · Sustainable finance

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

8 Sept 2020

RWE welcomes the roadmap on Taxonomy-related disclosures by undertakings reporting non-financial information and the opportunity to comment on it. As one of the world’s leading providers of renewable energy, RWE is fully committed to the European Union’s goal to transform Europe into the first low-carbon, resilient, and climate-neutral continent. While an ambitious and forward-looking taxonomy can unleash enormous potential, the classification system and the overall Sustainable Finance Strategy must sufficiently recognise the significant challenges to the successful transformation of the energy system. It is mission-critical for the European Green Deal, that companies with the highest decarbonization potential can access enough funds to continue investing in green technologies and being attractive to investors. Keeping this in mind, the European Commission should take into account the following issues, when drafting the regulatory standard for the Taxonomy-related disclosures: • The Reporting Requirements in the Taxonomy Regulation should reflect that future-oriented metrics are key for investors when taking their investment decisions in a sustainable way as intended by the EU’s Sustainable Finance Agenda. As the pathway a company is following is driven by its investments and as investments of a company are measured by its CapEx, this metric should be used whenever possible. In order to make the energy transition work tremendous investments are needed. These need to come from all players in the market. The investments into the energy transition are perfectly measured by the CapEx criteria – consequently this should be the dominant criteria for steering purposes – the other criteria are only descriptions of the status quo and cannot serve the purpose of putting investments/CapEx at work. While three metrics need to be reported according to the Taxonomy Regulation, the Commission and investors should clearly focus on CapEx when working on the implementation of the reporting requirements as well as in future legislations. • In order to create a level-playing-field for all European companies, the reporting requirements as set out in the Taxonomy Regulation should be harmonized at European level. Different implementations across Member States would lead to competitive disadvantages for some companies. • Sustainable Finance is a European topic and thus needs an EU-wide framework. National solutions alone will not be able to meet the challenges. We further see a need for harmonization in particular in the case of sometimes varying definitions between EU and national legislation, especially regarding the aspect of materiality or ‘adverse effect’ / ‘significant harm’. It must be avoided that parallel regulatory developments result in mismatched pieces of what should be one consistent and coherent Sustainable Finance framework. The best way to ensure a consistent application of the materiality principle would be a common definition of the materiality aspects within the upcoming revision of the NFRD. • Moreover, reporting requirements should not result in disproportionate additional work for companies without actually creating added value. For instance, reporting companies should retain flexibility in their choice of publication. A requirement to publish non-financial information in the management report could lead to time pressure and thus to imperfect reporting of the non-financial data. • In addition, the reporting requirements should be implemented according to already existing accounting standards. This could be done via a close cooperation with the accounting standard setting bodies. Otherwise, the implementation in the companies will be much more complicated and unnecessary expensive.
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Response to Offshore renewable energy strategy

13 Aug 2020

RWE welcomes the European Green Deal and the target to make the European Union as a whole climate neutral by 2050. This implies a fundamental transformation of all sectors of the European economy. RWE support the initiative of the European Commission for an Offshore Renewable Energy Strategy as offshore wind has an enormous growth potential in the EU and allows for generating high shares of renewable electricity with high load factors and at continuously decreasing costs. Offshore wind should be recognized as valuable industry and its importance in the context of the COVID-19 recovery as it provides a significant contribution to jobs and GDP in the European Union. For RWE six points are crucial for the EU offshore wind strategy: 1. For climate neutrality in 2050 Europe needs at least 400 GW offshore wind. 2. To finance this 400 GW offshore wind Europe needs appropriate auctioning schemes such as the 2-sided CfD (contract for differences) 3. Enhance grid development – national and cross border 4. More cross-border cooperation and coordination between Member States 5. Identify and resolve permitting obstacles – not only for offshore wind, also for grid connections. 6. Ensure better co-existence of different stakeholders around offshore sites
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Response to Strategy for smart sector integration

8 Jun 2020

RWE AG is one of the major European power generators operating a portfolio of around 43 gigawatts of generation capacity. In its new constellation following the completion of the transaction with E.ON, RWE has a generation capacity from renewables including hydropower and biomass of approximately 10 gigawatts. The company intends to further expand this position by making a net investment of up to 5 billion euros in onshore and offshore wind power, photovoltaics and storage by 2022. In addition, RWE produces electricity from gas, hard coal, lignite and nuclear fuel. In order to spur the energy transition, RWE is investing in innovative projects such as heat storage power plants, the generation and use of hydrogen as an energy source, and Power-to-X processes. We have a clear goal to be carbon-neutral by 2040. You'll find RWE's comments on the Strategy for smart sector integration attached.
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Response to A EU hydrogen strategy

8 Jun 2020

RWE AG is one of the major European power generators operating a portfolio of around 43 gigawatts of generation capacity. In its new constellation following the completion of the transaction with E.ON, RWE has a generation capacity from renewables including hydropower and biomass of approximately 10 gigawatts. The company intends to further expand this position by making a net investment of up to 5 billion euros in onshore and offshore wind power, photovoltaics and storage by 2022. In addition, RWE produces electricity from gas, hard coal, lignite and nuclear fuel. In order to spur the energy transition, RWE is investing in innovative projects such as heat storage power plants, the generation and use of hydrogen as an energy source, and Power-to-X processes. We have a clear goal to be carbon-neutral by 2040. You'll find RWE's comments on the EU hydrogen strategy attached.
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Response to Union renewable Financing mechanism

3 Jun 2020

RWE welcomes the European Commission’s proposal for an EU Financing Mechanism for Renewables. In general, it is a good initiative to achieve the goals set, especially for Member States that cannot take advantage of high renewables resources.. However, some aspects of the proposal raise concerns and could be improved or clarified: • The proposal could lead to a piece-meal approach. A more aligned platform for RES auctions, where all Member States can participate as host or requester would be more transparent. We encourage the European Commission to establish a level-playing field for all parties. Auctions - especially of 2-sided CfDs to give high investment security - can achieve the ensured development of additional renewable generation to lowest possible costs. • Decisions on the more concrete design elements should be guided by the Member States. Hosting Member States shall be incentivized to participate in the mechanism and provide more space for RES development rather than stick to their national support schemes. • It is not fully clear, what Member States receive for their voluntary payments. Will it be a certain project or rather an appreciation of a share of all projects under support? Will average criteria (Levelized Cost of Energy, MWh produced) be applied? We recommend the latter, since all participating Member States would benefit to the same degree. • The addition of a second parameter “innovation” to the auction is difficult to measure in a transparent and robust way. We rather encourage the European Commission to establish technology-specific auctions for the most innovative and less mature technologies with the aim to foster the development and thereby achieve learning curves and cost decreases.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

23 Apr 2020 · European Green Deal priorities, RWE investment in clean energy sources, coal phase-out and the role of natural gas as a transition fuel

Response to Climate change mitigation and adaptation taxonomy

17 Apr 2020

RWE welcomes the EU’s sustainable finance agenda as it is an important step on the path to a carbon-neutral European economy. The preparatory work of the TEG is remarkable. However, given the importance of the taxonomy regulation, RWE would like to stress some areas, where the TEG report still offers room for improvement. A one-size-fits-all emissions threshold is not sufficient for a coherent allocation of capital flows towards the most cost-efficient decarbonisation pathways. Hence, a systemic approach is needed. Modern gas-fired power plants are an important transitional technology and will play a decisive role in delivering security of supply at reasonable costs. They should be considered as taxonomy-eligible when they emit less direct emissions than 390 g CO2e / kwh for CCGT and 500 g CO2e / kwh for OCGT. The current restriction would prevent a successful pathway for the energy transition as gas has to play an important role to replace coal by sustaining security of supply at the same time. We support the current approach of the taxonomy, to positively incentivize sustainable investments, as this is the best way, to stimulate additional financing of the decarbonization agenda. We strongly reject a so-called “negative list” with unsustainable economic activities. Such a “negative list” tends to disregard the challenges faced by companies in transition in contributing to the decarbonization agenda. Dynamic companies are rated best using future-oriented metrics. Assessing where a company wants to be in the future and which path and speed it will choose to get there is more important than just looking at the status quo. Companies with a historically high CO2 footprint are seeking sustainable growth, while still having emission intensive assets in their portfolio. Nonetheless, these companies contribute substantially to Europe’s decarbonization agenda. Thus, wherever possible, the Capex should be used to weight different activities within a company rather than the turnover, which , as a matter of fact, is a fundamentally backward-oriented metric. The timeline for the reporting requirements for companies is very ambitious. To report valid figures for the financial year 2021, all internal reporting mechanisms need to be in place during 2020. This is not feasible, given the complexity of the given reporting structure and systems currently used. The rules for reporting are also not due to be finalized until the middle of 2021 which could prevent the collection and verification of sufficiently accurate data for the whole year. The reporting requirements should be designed in a more flexible way and auditing requirements should not apply for the first reporting periods. Requirements for audited figures should not be introduced without a lead time of at least 18 months to allow the required procedures to be put in place. RWE believes that the various transparency requirements for companies need to be better coordinated. The planned revision of the non-financial reporting directive on EU level should be mentioned here. The constantly changing requirements for corporate sustainability reporting make it very difficult to establish stable and future-oriented processes. The recycling provisions for the DNSH criteria must be clarified, especially for wind energy. Submitting recycling contracts for the turbine at the time of installation, as mentioned in the TEG report, seems not to be possible. In practice, no company will sign a contract with a specific recycling partner more than 20 years in advance. A more reasonable approach would be to provide for a dismantling concept with a provision for dismantling. RWE welcomes the power density criterion of 5W /m² for hydro power plants. However, more clarity on the calculation methodology is needed, especially on the water surface of a hydro power plant. Pump storage facilities should not be discriminated against other energy storage facilities, by the need to fullfil extra criteria.
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Meeting with Günther Oettinger (Commissioner)

28 Nov 2017 · Energy Union

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

20 Nov 2017 · clean energy package

Meeting with Günther Oettinger (Commissioner)

5 Sept 2017 · digitisation of energy sector

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

5 Jul 2017 · Clean Energy Package

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

1 Mar 2017 · Clean Energy for All Package

Meeting with Maroš Šefčovič (Vice-President) and

19 Jan 2017 · Energy Winter Package

Meeting with Věra Jourová (Commissioner) and

30 Aug 2016 · GDPR and Consumer protection in the energy sector

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

6 Oct 2015 · European energy policies

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

17 Sept 2015 · Renewables promotion in Spain

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 Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

2 Sept 2015 · Financial Markets Regulations

Meeting with Maroš Šefčovič (Vice-President) and

20 Apr 2015 · Gas storage

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

5 Feb 2015 · Presentation RWE

Meeting with Michael Hager (Digital Economy), Paula Pinho (Digital Economy)

19 Jan 2015 · Energy Policy

Meeting with Miguel Arias Cañete (Commissioner) and

14 Jan 2015 · Energy Union and Internal Market Energy

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

11 Dec 2014 · European Energy Policy priorities