Brussels, 24 June 2025
Dear President Ursula von der Leyen,
Dear Executive Vice-President Teresa Ribera,
Dear Members of the College of Commissioners,
EREF, the European Renewable Energies Federation, warns that the final version of the
Clean Industrial Deal State Aid Framework (CISAF), despite some technical improvements,
could seriously undermine the credibility of the EU’s Clean Industrial Deal.
The Commission’s 2025 NECP assessment shows that greenhouse gas reductions
are just on track, while the projected 2030 renewables share falls short of the 45 percent
ambition. In this context, CISAF sends a contradictory signal. The inclusion of fossil- and
nuclear-based technologies, paired with weak safeguards on low-carbon fuels, contradicts
the trajectory of measures under Fit for 55 towards a renewables-driven transformation.
EREF acknowledges some technical improvements such as partially clearer language
concerning the design of renewable energy support schemes and for bioenergy storage.
However, the overall direction of the leaked final framework is deeply concerning.
The decision to extend support to fossil-derived so-called low-carbon fuels and nuclear
technologies marks a major shift from the draft version. These changes should have
triggered a new public consultation under the EU rules of better regulation.
The absence of this step opens the door for legal challenges.
The final CISAF enables Member States to channel support to fossil fuels and nuclear
energy under the pretext of industrial decarbonisation. This is unjustified. Renewable
technologies are already the most cost-efficient and the market is adjusting accordingly.
There is no market failure to correct. Instead, the framework appears to open the door
to de facto rescue aid for outdated and polluting technologies. Fossil gas and coal
should be limited to reserve capacities in the energy system, not subsidised as solutions
for industrial competitiveness.
“The CISAF should be the necessary support for a future-proof European industry.
Instead, it allows legacy interests to dictate the rules. The inclusion of fossil-based fuels
and nuclear risks locking in pathways that contradict the Green Deal and the spirit
of fair competition. The Commission should correct this trajectory, the Collège of the
Commissioners need to reject these Guidelines,” said Dörte Fouquet, EREF Director.
This framework risks significantly impeding the rapid deployment of renewables
and efficiency technologies as well for related system changes in grids and storage.
Europe catapults itself back to centralised power and against the established, open,
democratic and competitive world based on renewable technologies. In the context
of recent narrative shifts on energy and climate policy in certain Member States,
these immature CISAF guidelines further risk the achievements of the EU Commission
over the last years under the Fit For 55-programme.
Martin Bursík, EREF President adds: “It is deeply ironic that CISAF would allow continued
public support for fossil fuels, while trying to become strategically more energy independent.
From the weaponisation of gas supplies from Russia to the risk of disruptions of global trade,
fossil and uranium imports are a persistent threat to Europe’s stability and competitiveness.
Supporting these fuels in the CISAF sabotages the Union’s own efforts to build a resilient
industry. Only renewables can deliver energy security, price stability and climate protection
at once.”
The introduction of temporary electricity price relief for energy-intensive users also
raises concerns. In the current CISAF version, support may be granted irrespective of the
electricity’s source, without safeguards against fossil lock-in or incentives for renewables.
In addition, past versions of such support have proven fiscally costly without lasting
benefit and do little to accelerate structural change.
EREF welcomes the Commission’s confirmation that Member States may adopt general
economic measures outside state aid control. These may offer a more stable path to
market-wide investment in clean industry. As it stands, the CISAF is not fit for purpose.
The Commission needs to reopen the consultation process and align the framework
with the EU’s long-term climate, energy and competitiveness goals.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org