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TOPSOE A/S

TOPSOE

Topsoe provides technology and solutions for the energy transition, focusing on decarbonization and transforming renewable resources into sustainable fuels and chemicals.

Lobbying Activity

Meeting with Pekka Toveri (Member of the European Parliament)

16 Dec 2025 · Security and defence topics

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and Siemens Energy AG and

8 Dec 2025 · Electrolyser industry – state of play

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Dec 2025 · Innovation Fund and European electrolyser market

Topsoe urges EU to back nuclear-powered hydrogen and heat

3 Dec 2025
Topic — EU consultation on the development and deployment of Small Modular Reactors in Europe.
Message — Topsoe requests that the EU recognize the role of nuclear heat in producing hydrogen. They advocate for a technology-neutral policy that treats nuclear-based fuels equally to renewable ones.12
Why — This would increase the efficiency and commercial viability of Topsoe's specialized electrolysis technology.3
Impact — Renewable fuel producers would lose their exclusive regulatory advantage over nuclear-based fuel alternatives.4
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Meeting with Kitti Nyitrai (Head of Unit Energy) and Unknown Organization and Unknown Organization

21 Nov 2025 · Trade of renewable gases

Meeting with Nicolás Pascual De La Parte (Member of the European Parliament) and Aula Europe

6 Nov 2025 · Introductory meeting

Meeting with Villy Søvndal (Member of the European Parliament)

5 Nov 2025 · Meeting on clean fuels for defence sector

Topsoe urges EU to adopt clean fuels for military

24 Oct 2025
Topic — The proposal establishes a regulatory framework to harmonise national rules impacting military mobility movements.
Message — Topsoe recommends that Member States set clear blending targets for clean military fuels. They also suggest committing to long-term procurement to support domestic fuel production.12
Why — Mandated targets would boost demand for Topsoe’s specialized clean fuel production technologies.3
Impact — Foreign fossil fuel suppliers would lose market share to domestic clean fuel producers.4
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Meeting with Kris Van Dijck (Member of the European Parliament)

23 Sept 2025 · EU Energy policy - EU competitiveness

Meeting with Wouter Beke (Member of the European Parliament)

16 Sept 2025 · Introduction

Topsoe urges 2040 target focus on EU technology investments

11 Sept 2025
Topic — The initiative amends the European Climate Law to establish a 2040 target.
Message — Topsoe supports a 90% target and calls for financial support for first-of-a-kind installations. They propose a dedicated target for permanent carbon dioxide removals to offset residual emissions. They warn that enhanced flexibility across sectors risks distorting investment signals in aviation.123
Why — New financial supports would help Topsoe scale up its first-of-a-kind technological installations.4
Impact — International carbon credit markets lose if the EU prioritizes internal technological investment.5
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Topsoe urges EU de-risking for sustainable aviation fuel investments

4 Sept 2025
Topic — The plan establishes a strategic framework for funding renewable fuel transitions in transport.
Message — Topsoe calls for a pilot market intermediary by 2026 to secure investment for e-SAF projects. They propose long-term purchasing contracts and suggest prioritizing only the most viable projects.123
Why — Securing long-term revenue certainty would allow Topsoe to finalize investments for its technologies.45
Impact — Smaller developers may lose funding if the EU prioritizes only a few projects.6
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Topsoe Urges Flexible Rules to Scale Chemical Plastic Recycling

19 Aug 2025
Topic — The initiative sets common rules for calculating and reporting recycled content in plastic bottles.
Message — Topsoe recommends permitting a company to transfer attributed amounts between sites on a like-for-like basis. They advocate for leveraging existing refineries as a cost-competitive pathway to scaling up chemical recycling. Effective enforcement is requested to place European recyclers on a level playing field.123
Why — Utilising existing infrastructure will ensure an affordable transition and reduce the EU's investment needs.45
Impact — European recyclers lose out to imports from regions that implement more flexible mass balance accounting.67
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Meeting with Pekka Toveri (Member of the European Parliament)

17 Jul 2025 · Security and defence topics

Meeting with Kitti Nyitrai (Head of Unit Energy) and Aula Europe

11 Jun 2025 · Discussion on electrolysers technologies and TOPSOE projects

Meeting with Radan Kanev (Member of the European Parliament)

11 Jun 2025 · Electrolytic hydrogen uptake

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

11 Jun 2025 · The role of sustainable aviation fuels and hydrogen in transport decarbonisation

Meeting with Kristoffer Storm (Member of the European Parliament)

4 Jun 2025 · Electrolytic hydrogen

Meeting with Dan Jørgensen (Commissioner)

26 May 2025 · Hydrogen

Meeting with Niels Flemming Hansen (Member of the European Parliament)

21 May 2025 · Meet the MEP

Meeting with Wopke Hoekstra (Commissioner) and

8 May 2025 · Site visit of TOPSOE

Meeting with Radan Kanev (Member of the European Parliament)

10 Apr 2025 · Green hydrogen and e-SAF markets

Meeting with Andreas Glück (Member of the European Parliament) and BASF SE

10 Apr 2025 · Climate and Energy Policy

Meeting with Morten Løkkegaard (Member of the European Parliament, Shadow rapporteur)

20 Mar 2025 · Biotechnology & Simplification

Meeting with Per Haugaard (Head of Representation Communication)

4 Mar 2025 · Discussion on an offer from SAS, CIP and Topsoe on Transporting the Commission for the Danish Presidency in a sustainable way.

Response to Implementing Act for guidelines on strategic projects

20 Feb 2025

Topsoe commends the European Commission for its commitment to strengthening Europe's net-zero technology manufacturing ecosystem and welcomes the opportunity to provide feedback on the Implementing Decision on strategic project selection criteria (the Implementing Decision). Topsoe is a global provider of technology and solutions for the energy transition. We help our customers and partners achieve their decarbonization and emission reduction goals. We are headquartered in Denmark with over 2,800 employees serving customers all around the world. Today, Topsoe is a leader in solutions and technologies for low-carbon hydrogen, ammonia, methanol, renewable diesel, and sustainable aviation fuel production. The company's technology leadership directly results from nearly 8% of annual revenue being dedicated to R&D. We are one of the very few companies to offer end-to-end solutions in e-fuels produced from renewable electricity and renewable fuels produced from biomass. These solutions are crucial for decarbonizing hard-to-abate sectors such as chemicals production, aviation, shipping, heavy transport, and heavy industry. The EU must become more competitive and open to innovation if it is to reduce import dependencies in net-zero technologies and their supply chains. To the extent that a net-zero technology manufacturing facility advances innovation and increases the EUs access to best available net-zero technologies, Topsoe believes such facilities should be designated as net-zero strategic projects. However, under the Commission's proposed guidelines some of these facilities may not qualify. One pathway for a facility to qualify for strategic project status is if contributes to resilience by increasing EU manufacturing capacity. Facilities manufacturing next-generation net-zero technologies are frequently constructed in multiple phases, producing smaller volumes initially and scaling up production over time. When these facilities apply for net-zero strategic status, their production capacities may fall below the threshold of what the draft guidance considers significant manufacturing capacity. While these facilities have other pathways to qualify for strategic project status under the Net-Zero Industry Act, they would need to meet additional requirements. Accordingly, Topsoe encourages the Commission to make the following changes to the Implementing Decision under its guidelines on significant manufacturing capacity: 1) Under point (b), clarify the meaning of equivalent type of net-zero technology manufacturing projects. Topsoe submits that next-generation technologies that go beyond state of the art in offering significant improvements in functional performance or energy efficiency, lower dependency on raw materials, or other significant energy and environmental gains should not be considered an equivalent type of technology. 2) Clarify that Member States, when determining whether a net-zero technology manufacturing facility provides significant manufacturing capacity in accordance with points (a) to (d), may also consider the facility's contribution to innovation in the technology itself.
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Topsoe welcomes the opportunity to provide feedback on the Draft Implementing Act on non-price criteria in renewable energy auctions under the Net-Zero Industry Act. Topsoe is a global provider of technology and solutions for the energy transition. Our company's technology leadership directly results from nearly 8% of annual revenue being dedicated to R&D. Headquartered in Denmark, we now have over 2,800 employees serving customers around the world. Today, Topsoe is a leader in solutions and technologies for green hydrogen, ammonia methanol and sustainable aviation fuel (SAF) production. We are one of the very few companies to offer end-to-end solutions in e-fuels produced from renewable power and renewable fuels produced from biomass. Our net-zero technology offerings include solid-oxide electrolyser cells (SOEC), next-generation lithium manganese nickel oxide (LMNO) cathode active materials, and eREACT. The electrolyser stack is the core working element of an electrolyser and should be viewed as distinct from other primarily used/main specific components. Similarly, the battery cell is the fundamental building block of battery packs and modules. Topsoe submits that reclassifying stacks and battery cells as final products can help the EU secure its electrolyser and battery value chains, as Article 7(1) of the Draft Implementing Act on non-price criteria (the Act) would then apply to these products. Adopting Topsoes proposal to reclassify stacks and battery cells as final products would require adding a new subparagraph to Article 7(1) to set out specific requirements for battery technologies, limiting the number of main specific components from a third country that can go into a battery cell. Articles 7(1) and 7(2) of the Act also includes a provision to address scenarios where the EUs dependence on a third country for a main specific component is sufficiently high, that strictly applying the resilience criterion would endanger security of supply for that component. Topsoe believes the 85% threshold for triggering this provision may need to be adjusted over time as the EU scales up its net-zero technology manufacturing capacity. We encourage the Commission to assess the adequacy of the threshold on an ongoing basis once the Act comes in force. Finally, Article 7(3) of the Act limits the inclusion of final products and main specific components from China in renewable energy projects, by requiring 75% of electrolyser technologies in an auction bid to meet the resilience criteria set out in Article 7(1), subclauses (b) through (d), and Article 7(2). Articles 7(1) and 7(2) are triggered under different conditions and each article imposes different restrictions on main specific components. The complexity of the resilience criteria creates challenges in comprehending how they will be applied to net-zero technologies from China. Topsoe proposes that simplifying the text in Article 7(3) so that 75% of the net-zero technologies that are part of the bid do not contain final products and more than two main specific components originating or assembled in the Peoples Republic of China will better mitigate the EUs risk of increased dependency on electrolyser imports.
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Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Topsoe welcomes the opportunity to provide feedback on the Draft Implementing Act on main specific components under the Net-Zero Industry Act. Topsoe is a global provider of technology and solutions for the energy transition. Our company's technology leadership directly results from nearly 8% of annual revenue being dedicated to R&D. Headquartered in Denmark, we now have over 2,800 employees serving customers around the world. Today, Topsoe is a leader in solutions and technologies for green hydrogen, ammonia methanol and sustainable aviation fuel (SAF) production. We are one of the very few companies to offer end-to-end solutions in e-fuels produced from renewable power and renewable fuels produced from biomass. Topsoe's net-zero technology offerings include solid-oxide electrolyser cells (SOEC), next-generation lithium manganese nickel oxide (LMNO) cathode active materials, and eREACT. With respect to electrolysers, Topsoe urges the Commission to reclassify stacks as a final product. The stack is the core working element of an electrolyser and should be subject to enhanced resilience criteria relative to other components. Topsoe also recommends the Commission add fuel-side contact component to the lists of primarily used components and main specific components for solid-oxide electrolysers. In an electrolyser stack, the component enforces physical and chemical contact between cells and other components, making it essential for enhancing stack performance and lifetime. Under battery technologies, Topsoe proposes the Commission reclassify battery cells as a final product. A fundamental building block of battery packs and modules, cells should be viewed as distinct from the other main specific components identified under battery technologies. Topsoe notes that battery packs and battery modules are currently listed as both final products and primarily used/main specific components in the Draft Delegated Act on primarily used components and Draft Implementing Act on main specific components, respectively. We suggest these items should only be listed as final products. Finally, with respect to sustainable alternative fuels technologies Topsoe strongly recommends the Commission amend the term thermochemical, chemical and biochemical/biological reactors to convert biomass into bio-intermediates and/or syngas, so that reactors that convert biogas into syngas also qualify as a primarily used component and main specific component. This can be achieved, for example, by expanding the term biomass to include biogas.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Topsoe welcomes the opportunity to provide feedback on the Draft Delegated Act on primarily used components under the Net-Zero Industry Act. Topsoe is a global provider of technology and solutions for the energy transition. Our company's technology leadership directly results from nearly 8% of annual revenue being dedicated to R&D. Headquartered in Denmark, we now have over 2,800 employees serving customers around the world. Today, Topsoe is a leader in solutions and technologies for green hydrogen, ammonia methanol and sustainable aviation fuel (SAF) production. We are one of the very few companies to offer end-to-end solutions in e-fuels produced from renewable power and renewable fuels produced from biomass. Topsoe's net-zero technology offerings include solid-oxide electrolyser cells (SOEC), next-generation lithium manganese nickel oxide (LMNO) cathode active materials, and eREACT. With respect to electrolysers, Topsoe urges the Commission to reclassify stacks as a final product. The stack is the core working element of an electrolyser and should be subject to enhanced resilience criteria relative to other components. Topsoe also recommends the Commission add fuel-side contact component to the lists of primarily used components and main specific components for solid-oxide electrolysers. In an electrolyser stack, the component enforces physical and chemical contact between cells and other components, making it essential for enhancing stack performance and lifetime. Under battery technologies, Topsoe proposes the Commission reclassify battery cells as a final product. A fundamental building block of battery packs and modules, cells should be viewed as distinct from the other main specific components identified under battery technologies. Topsoe notes that battery packs and battery modules are currently listed as both final products and primarily used/main specific components in the Draft Delegated Act on primarily used components and Draft Implementing Act on main specific components, respectively. We suggest these items should only be listed as final products. Finally, with respect to sustainable alternative fuels technologies Topsoe strongly recommends the Commission amend the term thermochemical, chemical and biochemical/biological reactors to convert biomass into bio-intermediates and/or syngas, so that reactors that convert biogas into syngas also qualify as a primarily used component and main specific component. This can be achieved, for example, by expanding the term biomass to include biogas.
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Meeting with Apostolos Tzitzikostas (Commissioner) and World Economic Forum and

22 Jan 2025 · Strategy Session: Flying Elephants in the Room: Airports of Tomorrow CEO Meeting

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

13 Jan 2025 · Exchange of views on Topsoe’s decarbonisation technologies and offtakers

Meeting with Andrea Wechsler (Member of the European Parliament)

10 Dec 2024 · EU Policy

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

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

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

19 Nov 2024 · Exchange on energy transition during Electrolysers Summit

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Ørsted A/S and

25 Oct 2024 · Speaker at network meeting with Danish companies on EU competitiveness

Topsoe urges flexible emissions rules for low-carbon fuel production

24 Oct 2024
Topic — The EU is defining how to calculate life cycle greenhouse gas emissions for low-carbon fuels.
Message — Topsoe requests that producers use project-specific data for upstream emissions and waste heat rather than default values. They also advocate for flexible emission allocation methods to support the scaling of low-carbon hydrogen.1234
Why — These adjustments would lower operational costs and make their fuel production technologies more competitive.56
Impact — Climate groups may see these rules as favoring fossil fuel-based production pathways over cleaner ones.78
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Meeting with Iuliu Winkler (Member of the European Parliament)

14 Oct 2024 · EU Trade/ Energy policy

Meeting with Pascal Canfin (Member of the European Parliament)

2 Oct 2024 · Clean Industrial Deal

Meeting with Kurt Vandenberghe (Director-General Climate Action)

3 Jul 2024 · concerning the EU’s objectives for domestic electrolyser and renewable hydrogen production capacity

Meeting with Maroš Šefčovič (Executive Vice-President) and

3 Jul 2024 · The meeting has been introduced by the Renewable Hydrogen Coalition and focused of the state of play of the current renewable hydrogen market.

Meeting with Héloïse Auplat (Cabinet of Executive Vice-President Margrethe Vestager), Simon Genevaz (Cabinet of Executive Vice-President Margrethe Vestager), Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager)

3 Jul 2024 · Exchange on technology solutions for the energy transition

Meeting with Maroš Šefčovič (Executive Vice-President) and

11 Jun 2024 · Hydrogen

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

7 Jun 2024 · Exchange on stage of EU electrolysers capacity and investment potential

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

23 May 2024 · to follow

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

15 Apr 2024 · Hydrogen, green innovation

Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Apr 2024 · Meeting WEF CEO Action Group for the European Green Deal

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

15 Apr 2024 · Discussion on hydrogen

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

22 Mar 2024 · Industrial policy

Meeting with Mohammed Chahim (Member of the European Parliament)

15 Mar 2024 · Hydrogen

Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Oct 2023 · Hydrogen

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

6 Oct 2023 · Energy Transition

Meeting with Margrethe Vestager (Executive Vice-President)

1 Apr 2022 · Discussed matters of how to accelerate the green and digital transitions.