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The Voice of Europe's Independent Energy and Mobility Suppliers

UPEI

UPEI represents European independent fuel suppliers and importers for transport and heating.

Lobbying Activity

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

20 Nov 2025 · Keynote address on the Clean Industrial Deal, its articulation with the 2019-2024 European Green Deal and the political/geopolitical/geoeconomic challenges the EU must face in this context. Q&A followed the speech.

Independent energy suppliers urge secure fuel infrastructure for military

24 Oct 2025
Topic — The regulation establishes a framework to harmonise national procedures for military mobility movements.
Message — UPEI demands that fuel supply networks remain operational during emergencies like cyber-attacks. They insist the military must still access traditional fuels despite wider climate goals. The group also wants the EU to fix cross-border infrastructure bottlenecks.123
Why — New infrastructure investments and clear crisis guidance would protect their business and operational stability.45
Impact — Unreliable foreign energy exporters lose market share as the EU prioritizes local refinery capacity.6
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Independent energy suppliers urge expansion of EU storage rules

13 Oct 2025
Topic — The European Commission is updating its framework to improve energy security.
Message — The associations call for storage laws to include modern fuels like hydrogen and biofuels. They also propose keeping current oil reserves and fast-tracking permits for energy facilities.123
Why — Mandating more storage types would increase the utilization and value of their facilities.4
Impact — Dominant energy producers could see reduced market share due to increased independent competition.5
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UPEI calls for technology-neutral approach to car CO2 standards

10 Oct 2025
Topic — Revision of European Union CO2 emission performance standards for new cars and vans.
Message — UPEI recommends replacing zero with net zero and introducing a Carbon Correction Factor. They propose a new vehicle category powered exclusively by carbon-neutral fuels.123
Why — This secures a future market for liquid fuels, benefiting independent energy suppliers.4
Impact — Pure electrification strategies lose their exclusive regulatory advantage over alternative fuels.5
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UPEI urges technology-neutral approach to EU heating strategy

9 Oct 2025
Topic — The EU is developing a strategy to accelerate the decarbonisation of heating and cooling.
Message — UPEI requests that electrification be accompanied by renewable liquid fuels and hybrid heating systems. They advocate for a technology-open pragmatic approach that avoids specific fuel or technology bans.123
Why — Their members could continue distributing fuels while avoiding the need for extensive renovation investments.4
Impact — The push for full electrification is weakened, potentially harming heat pump manufacturers and green groups.5
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UPEI demands technology neutrality in EU 2040 climate targets

16 Sept 2025
Topic — The initiative updates the European Climate Law by establishing a 2040 target.
Message — The group advocates for technology neutrality to allow internal combustion engines to continue using carbon-neutral fuels. They also seek a stable regulatory framework that reduces administrative burdens for independent suppliers.12
Why — Maintaining liquid fuels preserves the value and utility of their current infrastructure.3
Impact — Supporters of rapid, total electrification face competition from prolonged use of liquid fuels.4
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Response to European Affordable Housing Plan

4 Jun 2025

Dear Madam, dear Sir, You will find below a joint position paper established by four associations representing the classical and advanced liquid fuel sector. Best regards Pierre Lucas UPEI
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Response to Communication on the EU Stockpiling Strategy

9 May 2025

UPEI the voice of Europes independent fuel suppliers welcomes the opportunity to contribute to the European Commissions call for evidence on stockpiling strategies for energy. Recent geopolitical and energy market developments have exposed the fragility of the EUs current energy supply systems, reinforcing the need to strengthen resilience and preparedness. As independent suppliers serving diverse markets across Europe, UPEI members play a key role in ensuring energy accessibility and flexibility. In this context, we strongly support the EUs efforts to enhance energy security of supply. We believe that a robust and forward-looking stockpiling strategy, supported by efficient infrastructure, will be vital in managing future disruptions and supporting industrial competitiveness. We are pleased to share our perspective and highlight key considerations to inform future policy development in this critical area.
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

24 Mar 2025 · Biofuels

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and EPIA SolarPower Europe and

7 Mar 2025 · Security of Energy Supply

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

UPEI, the voice of Europes independent fuel suppliers, welcomes the publication of the Commissions proposal for a Delegated Act defining the components primarily used for the production of the final products listed as net-zero technologies in the Net Zero Industry Act (NZIA). UPEI strongly supports the aim of the Net Zero Industry Act to create enabling conditions for technologies that are critical to Europes decarbonization. More in our enclosed position paper ...
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Fuel and storage sectors urge EU carbon management strategy

31 Aug 2023
Topic — This initiative explores the deployment of EU-wide carbon capture and storage infrastructure.
Message — The associations call for a coordinated EU strategy including specific CO2 storage targets and funding to de-risk the value chain. They also request clear rules for accessing transport infrastructure and a competitive market.123
Why — Classification as an enabling activity would allow them to access favorable green financing.4
Impact — Industrial emitters prioritizing direct emission reductions could face increased competition for decarbonization funding.5
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UPEI urges EU to include renewable fuels in truck standards

16 May 2023
Topic — The European Commission is reviewing CO2 emission standards for heavy-duty vehicles.
Message — The organization urges policymakers to include renewable and low-carbon liquid fuels in the regulation. They argue for a technology-neutral approach that accounts for a vehicle's entire lifecycle emissions.12
Why — This would protect the business model of independent fuel suppliers and storage operators.34
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UPEI urges EU taxonomy inclusion for fuel storage infrastructure

24 Apr 2023
Topic — Establishing a classification for sustainable economic activities contributing to EU environmental objectives.
Message — Classify fuel storage and distribution as an activity that helps others go green. This ensures infrastructure can support the transition to low-carbon and renewable fuels.12
Why — This status helps secure private sector funding for high-cost infrastructure projects.3
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Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and Federation of European Tank Storage Associations

18 May 2022 · Sjöfartsfrågor

Independent fuel suppliers urge technology neutrality in CO2 standards

8 Nov 2021
Topic — The European Commission is revising CO2 emission standards for cars and vans.
Message — The group requests a shift from tailpipe-only monitoring to a well-to-wheel approach. They propose a voluntary crediting system for car manufacturers to use renewable liquid fuels.12
Why — This would protect their existing infrastructure and secure future demand for fuel products.3
Impact — Low-income families may lose access to affordable transport without these liquid fuels.45
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

15 Apr 2021 · Speech at their event about the Fit for 55 Package

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

UPEI supports measures to help decarbonise the heating sector, including the EPBD which contributes to higher-performance and comfortable buildings and reduced energy bills for citizens, as well as facilitates the acceptance of the energy transition. When assessing the impact of EPBD and its likely direction of revision, we recommend having a thorough analysis of: - Cost repartition and an overview of which parties will be paying for this transition, who will carry the financial burden and how this will impact vulnerable consumers and social acceptance? - What the impact would be on phased introduction of mandatory minimum energy performance standards from 2026 onwards and how this will fit with each Member State local circumstances. - If such mandatory minimum requirements are introduced before 2026, would those lead to a compliant increase in the use of renewables or a reduction in the energy performance of buildings? - The positive impact of other legislative proposals included in the “Fit for 55” package, such as the review of the Energy Taxation Directive and the Renewable Energy Directive that should unlock the deployment of renewable and carbon neutral liquid fuels, including in the heating sector. Please find our full contribution to the roadmap enclosed.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

13 Jan 2021 · Reflecting on the Sustainable and Smart Mobility Strategy: how to fuel the transition?

Independent fuel suppliers urge CO2 credits for renewable fuels

26 Nov 2020
Topic — The Commission is revising CO2 emission performance standards for passenger cars and vans.
Message — UPEI wants a Well-to-Wheel assessment instead of focusing only on tailpipe emissions. They propose a voluntary crediting mechanism for renewable fuels.12
Why — This allows suppliers to remain competitive by using their existing fuel distribution infrastructure.3
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Context Independent fuel suppliers have experienced a substantial impact on their business activities, as COVID-19 outbreak hit harshly fuels demand across Europe. This unprecedented challenge represents a pivotal opportunity to reshape the energy sector as we know it. To achieve this goal, an ambitious and stable policy framework is crucial. UPEI members are fully committed to provide flexible, affordable, and clean energy to consumers in order to meet Europe’s short- and long-term climate objectives. Relevance of the independent fuel suppliers’ sector UPEI members are in a unique situation within the fuel supply market. Today’s individual fuel suppliers bring expertise, sound consumer knowledge and an established, comprehensive infrastructure which already delivers low carbon, energy efficient products in an affordable and competitive manner. They have a strong track record in contributing to the EU climate protection objectives, being the first to supply renewables to Europe’s fuel market as early as 1992, showing their commitment to and flexibility in embracing new policies and delivering new solutions. Independent fuel suppliers are not producers of liquid fuels and therefore have the freedom to diversify the products that they supply. However, they need regulatory predictability and consumer demand as a guarantee for investments in renewable and low carbon fuels. General comments on the EU ETS reform and ESR reform In general, UPEI supports the EU ETS as a market-based and cost-effective tool to reduce GHG emissions, in light with the EU carbon neutrality objective. We see the ETS and ESR as complementary measures to address climate change. Avoiding parallel systems The Inception Impact Assessment for the revision of the EU ESR lists a number of options for the future of this regulation and sectors which directly affect independent fuel suppliers. Among these, the option of a parallel system that covers the emissions from the transport and buildings sectors under both the ESR and a new emissions trading system could result in negative consequences, primarily through increased administrative burden, potential for regulatory inconsistencies and complexity for operators to navigate the two parallel systems. Should the Commission consider the EU ETS to be the more appropriate system to regulate transport and building emissions, UPEI suggests to not chose to follow a parallel system with concurrent emission reductions under the ESR. If on the other hand the Commission’s impact assessment finds that the ESR system is adequate for the road transport and buildings sectors, and provides sufficient means for Member States to reach updated 2030 climate target, we are supportive of an ambition increase to the ESR to support the achievement of a higher 2030 target. UPEI and its members, representing nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, look forward to constructively working with the EU institutions to make Europe’s climate policy a success. Please find enclosed UPEI position paper the revision of the EU Emissions Trading System and the EU Effort Sharing Regulation.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

In general, UPEI supports the EU ETS as a market-based and cost-effective tool to reduce GHG emissions, in light with the EU carbon neutrality objective. We see the ETS and ESR as complementary measures to address climate change. In principle, the ETS applies to the organisations directly responsible for the actual CO2 emissions. Such an approach should be taken when extending the ETS to the maritime sector, by subjecting shipping companies to ETS obligations, in line with the existing Monitoring, reporting and verification (MRV) Regulation. However, we understand that the same approach cannot be fully implemented in the road transport and building sectors, given the very high number of emitters. Concrete suggestions regarding the prospect of expanding the use of emissions trading to buildings and road transport. UPEI calls upon the European Commission to give careful consideration to the following issues during the impact assessment and preparation of policy proposals: 1. A coherent policy framework 2. A suitable identification of the market players 3. A technology neutral approach 4. A proper assessment of potential effect on prices 5. Avoiding parallel systems These issues are further developed in the position paper enclosed.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

UPEI, the voice of Europe’s Independent Fuel Suppliers, welcome the opportunity the provide initial feedback to the roadmap on the Energy Efficiency Directive (EED). In this context, we would like to draw your attention to the following issues: 1. We agree that energy efficiency is the number one priority in the transition towards climate neutrality. As stated in UPEI 2050 vision (https://www.upei.org/upei-2050-vision), alongside technological and design developments to reduce fuel consumption of new appliances, more efficient supply systems will also make energy use more sustainable. More efforts on energy efficiency are therefore needed in light of the increased level of ambition for 2030 and 2050. 2. The revised EED has been adopted after a long and difficult negotiation in 2018, and has not yet been implemented. First and foremost, the focus should be on the proper enforcement of existing legislation. Then, it is important to raise the overall level of ambition by expanding the scope of the directive without questioning previously agreed principles, which would undermine the much needed regulatory stability for investments. 3. As market operators, we are experiencing issues linked to the diverging implementation of existing EED measures by Member States. In some countries, the system in place for energy savings certificates is very burdensome for example, affecting the competitiveness of certain players compared with their counterparts in other European countries. We call upon the European Commission to foster harmonisation among Member States, in view of the smooth functioning of the internal market 4. In the context of the evaluation of the EED, a special attention should be given to the assessment of overlaps, lack of effectiveness and disproportionate costs in the current framework. This is an essential starting point to ensure that the next review is effective and makes use of synergies. 5. When designing the approach to be taken, UPEI calls for a balance of the three energy and climate policy objectives: energy security, sustainability and affordability of energy prices. The approach should also be technology agnostic, i.e. setting energy efficiency targets without mandating which technologies and energies should be used and where, allowing for a fair competition based on the suitability and performance of different options. 6. There are many measures already in place to improve efficiency in the transport sector, covering the different sub-sectors. UPEI believes that an obligation for transport in the EED is not the best way to address its emissions, and the opportunity to remove this provision should definitely be considered. 7. Access to finance remains the major obstacle to achieve the full energy savings potential. Financial mechanisms and instruments should focus on upstream research and development and, on the other hand, on tax relieves for end users in order to incentivise a modernisation of heating systems. In particular, the Energy Taxation Directive should be revised to adequately support the uptake of alternative energies in the heating sector. Again, UPEI supports technology neutral mechanisms. *** UPEI represents nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, supplying Europe’s customers independently of the major energy producers. They are the interface between producers and consumers, using their own infrastructure and flexibility to supply existing demand for conventional and renewable liquid fuels, as well as non-liquid alternatives as part of the energy transition. They cover more than a third of Europe’s current demand. The organisation brings together national associations and suppliers across Europe. More on www.upei.org
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

UPEI and its members, representing nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, look forward to constructively working with the EU institutions to make Europe’s renewable energy policy a success. UPEI calls upon the European Commission to give careful consideration to the following issues in the process leading to the review of REDII: 1. REDII has been adopted after a long and difficult negotiation, and has not yet been implemented. It is important to raise the overall level of ambition by expanding the scope of the directive without questioning previously agreed principles, which would undermine the much needed regulatory stability for investments. For instance, setting up a technology open objective for airlines and shipping companies would be the most effective way to support the deployment of renewable fuels in the aviation and maritime sectors. Similarly, renewable fuels could be deployed in the NRMM sector, with the right incentives. 2. The way the REDII allows the use of multipliers may lead to a situation where the actual, physical share of renewable electricity and sustainable biofuels remains rather limited, and to distortions between different solutions. The current system should be reviewed to establish technology open multipliers, promoting the best renewable fuels based on the lifecycle carbon footprint. 3. Current blending walls in the Fuel Quality Directive should be lifted alongside the review of RED, to stimulate higher renewable content in fuels. 4. The majority of low-carbon and carbon-neutral fuels, such as advanced biofuels, e-fuels, and to a smaller extent hydrogen, e-gas and biogas, can be swiftly deployed thanks to the repurposing of the existing distribution infrastructure. The efficiency gain related to the availability of this infrastructure should be duly considered in the cost-benefit analysis of different technologies. 5. Current provisions on heating should be revised, with technology open approach, encompassing new technologies such as e-fuels, and not dismissing the potential of hybrid systems. All solutions should be counted as RES for heating alongside renewable fuels (e.g. HVO), letting the market decide on the allocation of different solutions. 6. Generally, the Directive should not restrict any opportunity to develop renewable energies, since strong sustainability and ILUC criteria are now in place. In particular, the cap on Annex IX Part B fuels should be removed, particularly if the overall renewable energy target in transport is raised significantly. 7. Although the renewable energy sector should not be dependent on subsidies, we support the establishment of an effective financial support system, allowing all players to take part, including SMEs. Equal access to funding is one of the prerequisites for independent fuel suppliers to be able to invest in the sector. 8. The success of the renewable energy regulatory framework will also depend on consumers awareness and empowerment. For example, unjustified negative consumers perceptions have adversely affected the roll-out of E10 blends in certain countries, affecting the deployment of fuels with higher blends of renewables more generally. UPEI supports measures providing factual information to consumers alongside incentives, to ensure societal acceptance of the significant changes the energy sector will undergo in the next decades. Please see the attached PDF file for more details and references about the recommendations above.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

17 Sept 2020 · Sustainable mobility and transport policy review

Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

UPEI and its members have embraced the EU ambition to reach a climate-neutral economy by 2050, and are fully committed to contributing to achieving this target through the supply of carbon-neutral fuels by 2050. The upcoming Sustainable and Smart Mobility Strategy will be a key strategic vision that will thoroughly influence the future of the transport sector by shaping the regulatory framework and providing investment pathways towards EU climate goals. In light of the current global economic uncertainties, it is essential that the economic recovery is guided by financial support for the EU’s transition towards a sustainable economy. The EU’s Recovery Instrument, the System Integration and the Hydrogen Strategies have all noted the crucial role that investments in low-carbon and carbon-neutral technologies such as hydrogen, advanced biofuels, biogases, e-fuels and recycled carbon fuels will play in achieving a cost-effective decarbonisation of the transport sector. UPEI calls on the Commission to ensure that the Smart and Sustainable Mobility Strategy demonstrates clear and comprehensive pathways, also unlocking necessary regulatory frameworks, to incentivise a rapid uptake of these technologies and investments into repurposing existing fuel distribution infrastructure to meet the demands of a greener Europe. There are a number of types of low-carbon and carbon-neutral fuels, with sustainable and low carbon biofuels being the most mature technologies, which can be deployed in an effective manner already today. Moreover, recycled carbon fuels, produced from industrial waste gases or based on non-recyclable plastics, can also contribute to the renewable energy target in transport. Similarly, as highlighted by the above-mentioned Strategies, hydrogen-derived synthetic fuels and gases (e-fuels) present a significant potential as carbon neutral energy carriers for a wide range of end-uses. We call on the Commission to ensure that the upcoming Strategy highlights the means and pathways for incentivising the uptake of these alternative low-carbon and carbon-neutral fuels for various end-uses in the transport sector. While our industry has rallied behind climate neutrality, this monumental ambition will have to be sustained by policies and regulatory frameworks that provide legal coherence, clarity and predictability. However, regulatory inconsistencies among existing legislation complicate investment certainty for independent fuel suppliers to reach this goal. These inconsistencies can be demonstrated in the particularly problematic relationship between the Fuel Quality Directive and the Renewable Energy Directive, the incomplete support of carbon neutral solutions under the CO2 Standards, the insufficient incentivisation of technology-neutral solutions under the Alternative Fuels Infrastructure Directive (AFID), and the sorely outdated Energy Taxation Directive giving very little stimulus to low-carbon technologies. Equally importantly, upcoming revisions should avoid regulatory U-turns that could endanger the positive impacts that alternative fuels can play in the energy transition. In particular, maintaining the current definition of alternative fuels in AFID would guarantee consistent policy making and a stable investment environment. In light of the above, UPEI would propose that these points are taken into account in the upcoming Strategy and the revision of EU transport policies: • Set out favourable regulatory framework and investment pathways for low-carbon and carbon-neutral technologies, such as hydrogen, advanced biofuels, biogases, e-fuels and recycled carbon fuels, and repurposing existing fuel distribution infrastructure to encourage rapid and deep decarbonisation of the transport sector. • Fixing regulatory inconsistencies in EU transport policies, as shown in the attached UPEI Paper on Regulatory Inconsistencies, to emphasise the most cost-effective transition towards climate neutrality in the transport sector.
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Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

27 Jul 2020 · European Green Deal; Renewables;Fuel Quality.

Response to FuelEU Maritime

24 Apr 2020

UPEI – Europe’s Independent Fuel Suppliers, welcomes the opportunity to provide initial comments to the Roadmap, and to be part of the preparatory process for the FuelEU Maritime initiative. UPEI embraces the European Green Deal and ambition to reach climate neutrality by 2050 and therefore supports measures that bring down fuel consumption as well as boosting the deployment of all low- and zero-carbon marine fuels, contributing to the reduction of GHG emissions. 1. UPEI views on the inception impact assessment UPEI calls for a unified approach to sustainable alternative fuels (SAF) for shipping and warns against a regulatory patchwork by which several pieces of legislation would set out diverging measures to respond to a similar policy objective, as we are experiencing in the road transport sector. Full consistency with REDII and AFID should be ensured. We however welcome the fact that the FuelEU initiative will include demand-side measures, which will be critical for the effective deployment of SAF. UPEI welcomes the reference to well-to-wake as a basis for assessing the performance of different technologies. In parallel, strong sustainability criteria should be established for all technology solutions, in line with REDII. Such approach should also be promoted at IMO level to harmonise methodologies. UPEI welcomes the reference to a mix of solutions, which should be able to compete on a level-playing field based on their overall environmental performance. As explained in UPEI 2050 vision, the use of existing technologies, drop-in SAF in particular, and the improvement of energy efficiency can reduce emissions immediately, while developing carbon neutral fuels to suit all needs and applications. Finally, we encourage the European Union to advocate for global solutions at the level of IMO. As marine fuels is a truly international market, global solutions are best to effectively reduce GHG emissions while ensuring a level playing field among all market players. In the context in the FuelEU initiative, the European Commission should carefully assess the risk of carbon leakage and protect the international competitiveness of European bunker suppliers. In particular, we would appreciate a clarification of what is meant by “flag neutral” measures. 2. UPEI recommendations for the impact assessment There is currently no mention of quality in the roadmap. UPEI recommends that the European Commission also assesses technology options in light of their quality and their compatibility with existing and future engines and supply infrastructure. In parallel, the ISO should develop tests and fuel specifications to guarantee constant quality and therefore to provide confidence to shipowners and operators. UPEI supports the further assessment of blending or GHG emission requirements applied to vessels, as they can provide SAF producers and suppliers with a much needed investment certainty. In addition, we recommend to look at complementary incentives and support measures. The impact assessment should take into consideration the development of SAF in other sectors of the industry and possible side-effects. It is important to development synergies, across transport modes in particular, and not to create a counter-productive competition for feedstocks and SAF. Contact: Cécile Nourigat │ Secretary General │ info@upei.org │ +32 2 740 2020 │ www.upei.org UPEI represents nearly 2,000 European importers and wholesale/retail distributors of energy for the transport and heating sectors, supplying Europe’s customers independently of the major energy producers. They are the interface between producers and consumers, using their own infrastructure and flexibility to supply existing demand for conventional and renewable liquid fuels, as well as non-liquid alternatives as part of the energy transition. They cover more than a third of Europe’s current demand. The organisation brings together national associations and suppliers across Europe.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

UPEI recognises the need for an Energy Taxation Directive and welcomes the European Commission’s intention to update it. This is needed to ensure that the ETD remains relevant by taking account of technological developments in the energy sector, resulting in the emergence of new products which currently do not fall within the scope of the directive, and address current issues related to the functioning of the internal market. Regarding the policy options set out in the inception IA: 1. Minimum excise rates Whilst the ETD sets minimum taxation rates, this has not resulted in significant harmonisation across the European Union, as there remain wide variations in levels of taxation. This can result in volatile distortions of the market affecting the supply chain, and creating uncertainties, notably in cross border situations where the consumer can benefit from lower taxation rates in countries of close proximity, also known a tax tourism. Setting minimum level of taxation for products used as motor or heating fuel are still fit for purpose. However, there are still significant variations between tax levels in the Member States as no ceiling is imposed. The range should be limited to avoid two extreme directions: very high and low levels. Setting fixed rates may not be realistic but UPEI suggests to properly assess the benefits for the single market of setting a range. 2. Sectoral tax differentiation The revised directive must leave room for tax exemptions and reductions to guarantee the flexibility that Member States need, while promoting more coherence at EU level. Any attempt to totally or partially remove the exemption for aviation and maritime fuel should be done with full consideration to the practical operation in these sectors, the potential impact on the sector, the risk of diversion and carbon leakage, and the compliance with international obligations. 3. Product coverage The ETD should be brought up to date to take account of new technologies that have been developed (electricity for transport) and are being developed such as e-fuels. In this respect, it is important to address the need for a taxation policy that promotes sustainable products whilst being mindful of the impact on taxation revenues that expected consumer behavioural shifts are likely to have in the longer term. In addition, optional exemptions may only be granted for a period of 6 years, after which they are treated as State Aid. This timeframe does not take account of the high risk and investment cost for developing biofuels and therefore undermines the development of the market, as the rate of return exceeds 6 years. In the case of advanced biofuels, a mandatory tax exemption for a period of 10 years of more would be coherent with the need to stimulate innovation and production in line with the targets agreed under RED II. 4. Internal market Distortions occur due to different national approaches to the conditions for granting reductions/exemptions, setting different rates, applying different procedures etc., creating legal uncertainty for operators, especially in cross-border situations. There are many ECJ rulings reflecting the lack of clarity on interpretation. The review of the ETD should in priority clarify the way that Member States have to interpret the provisions of the legislation. This is important in order to avoid distortion of the internal market and to ensure fair competition. Specific attention shall be given to the impact of potential legislative changes on SMEs. 5. Consistency with other policy instruments The revision of the ETD should be developed to complement and in coherence with other EU legislation promoting products and technologies with environmental benefits, such as RED II, DAFI and ETS. It is also important to avoid double taxation or equivalent effect. The EU Green Deal and the review of main pieces of legislation mid-2021 is a key opportunity to develop synergies and consistency.
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Response to Climate Law

6 Feb 2020

Climate Law recommendations UPEI is fully committed to contributing to achieving carbon neutrality through the supply of carbon-neutral fuels by 2050. This monumental ambition will have to be sustained by the regulatory consistency that businesses need to successfully deliver the transition to sustainable supply chains, mobilising funding for solutions that reflect changing market realities. Such regulatory framework will need to promote all forms of low carbon and carbon-neutral solutions, as this will be necessary to reach carbon neutrality efficiently. First, UPEI suggests to clearly define “carbon neutrality” in the proposed law in the interest of legislative certainty. UPEI supports raising the 2030 target to reflect Europe’s climate ambition. UPEI believes that any target should be equipped with clear and realistic emission reduction trajectories, providing the transparency and certainty needed to attract the necessary investments to reach climate neutrality by 2050. Targets will have to be set at realistically achievable levels, backed by science-based impact assessments, reflecting market realities without resorting to draconic future policy U-turns. Such approach will ensure both fairness and societal acceptance of the changes that Europe will have to undergo in the next thirty years. Furthermore, UPEI recommends a sober approach to revising the recently finalised Clean Energy Package, as early deep reviews would harm regulatory certainty and undermine the clear signals that the agreed legislation provides to investors. Instead, UPEI would advise to increase the level of ambition through complementary measures. These would include ambitious yet realistic revisions of e.g. the Alternative Fuels Infrastructure Directive, Fuel Quality Directive, the Energy Taxation Directive. These revisions would need to reflect market realities but also the need to diversify available fuel types by significantly promoting the roll-out of low carbon and carbon neutral fuels. Technology neutrality and energy efficiency The Climate Law should incentivise the development of a life-cycle approach to evaluate the carbon and environmental footprint of all solutions and emissions from all applications, allowing for a thorough comparison, and its swift implementation by amending existing legislation in a practical manner. Moreover, car manufacturers should be incentivised to further invest in energy efficiency improvements and vehicles powered by renewable and carbon neutral fuels. The Climate Law should also consider a shift in the definition of “efficiency”, towards “system efficiency” to factor in the cost efficiency of renewable fuels (“drop-in” benefit) versus standalone technologies requiring dedicated infrastructure and appliances. Favourable framework for innovation and investments in carbon-neutral fuels A successful transition to climate neutrality needs to be backed by framework that will advance technological development of all low-carbon and carbon neutral energy sources. UPEI promotes the use of alternative fuels and the improvement of energy efficiency to reduce emissions immediately, while developing carbon neutral fuels to suit all needs and applications in the longer term. These carbon neutral fuels are advanced biofuels and biogases, e-fuels and other solutions such as recycled carbon fuels. They offer many advantages: they feature a significant energy content, and can be moved, stored, and used in the existing distribution infrastructure and appliances. Their production and deployment must be stepped up to deliver their full potential to fight against climate change. UPEI equally calls for stable and predictable sustainability criteria for fuels from biomaterial origin beyond 2030, and robust sustainability criteria for batteries and e-fuels to give the right signal to the market to invest in necessary production facilities. Read more in the UPEI 2050 vision, enclosed.
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Independent energy suppliers urge technological neutrality in fuel infrastructure

20 Mar 2019
Topic — The Commission is evaluating the Directive on deploying alternative fuels infrastructure across Europe.
Message — UPEI advocates for a technology-neutral approach that supports all fuels contributing to decarbonization. They warn against building infrastructure that does not match actual consumer demand.12
Why — Promoting drop-in fuels allows members to leverage existing assets and minimize investment risks.34
Impact — Proponents of expensive new technologies may lose priority if funding shifts to existing systems.5
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Fuel suppliers back price comparisons but challenge purchasing links

28 Mar 2018
Topic — The EU is developing a methodology for comparing prices of alternative fuels.
Message — UPEI supports expressing fuel prices as price per 100km to help consumers compare technologies. They request deleting references to future purchasing choices to ensure accuracy.12
Why — This change would limit the regulation's role in steering consumers away from traditional fuels.3
Impact — Potential car buyers may lose a clear link between daily fuel costs and vehicle investment.4
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Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

6 Mar 2018 · to discuss the energy transition and clean mobility package and how the independent fuel supply sector can contribute and, in particular, aspects relating to infrastructure investments

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

10 Dec 2015 · Heating and cooling strategy and the future of the FQD

Meeting with Gonzalo De Mendoza Asensi (Cabinet of Vice-President Miguel Arias Cañete)

9 Jul 2015 · New developments in the context of the Energy Union Strategy