Climate Lobbying Overview: EnBW is strategically engaged on various climate change policy streams with predominantly positive lobbying positions, for example strongly engaging with the EU’s Climate Law and the EU Emissions Trading System. However, the company also appears to be unsupportive of the EU Energy Efficiency Directive and the EU Sustainable Finance Taxonomy, through its promotion of the long-term role of fossil gas in the mix.

Top-line Messaging on Climate Policy: EnBW's top-line messaging on climate policy is positive. The company stated support for the EU’s 2050 climate neutrality target in a March 2022 public consultation response, and has previously stated support for the EU’s Green Deal, and climate neutrality targets in the EU and Germany in its Integrated Annual Reports from 2021 and 2020. The organization appeared to state support for the Paris Agreement on its corporate website, accessed in November 2022. EnBW appears to support the need for climate regulation, particularly the introduction of a minimum CO2 price across sectors, stating this in its previous three Integrated Annual Reports, most recently March 2021.

Engagement with Climate-Related Regulations: EnBW has strongly supported the EU’s Emissions Trading Scheme (ETS), and has on several occasions advocated for reforms to increase its effectiveness. This includes calling for the scheme to be aligned with the EU’s climate goals, the linear reduction factor to be increased and the market stability reserve to be strengthened in a February 2021 consultation response, and a June 2021 position paper. Since 2018, the company has repeatedly advocated for the introduction of a minimum carbon price floor in the EU ETS to support renewable energies and safeguard investment, most recently stating support in its 2020 Integrated Annual Report, published in March 2021. In its 2021 Annual Report, published in March 2022, the company broadly supported reforms to the EU Renewable Energy Directive, but suggested further adjustments were still required to the green hydrogen criteria and biomass sustainability criteria, without specifying what this would include.

On its corporate website, accessed in November 2021, EnBW advocated against increasing ambition in the EU Energy Efficiency Directive, specifically advocating against the inclusion of high-efficiency criteria for combined heat and power plants that would restrict fossil gas capacity. EnBW appeared to support a more ambitious 2030 GHG emission target in the EU, suggesting increasing the target from at least 55% to 60%, but with the caveat that it should be accompanied by sufficient carbon leakage protection. The company appeared to advocate for weaker ambition in the EU Methane Regulation for the energy sector in an April 2022 consultation response, by advocating for weaker leak detection and repair measures. In a June 2021 position paper, EnBW appeared to advocate against the introduction of the EU Carbon Border Adjustment Mechanism, and opposed the phase out of free emission allowances stating carbon leakage concerns.

Positioning on Energy Transition:EnBW appears to take mixed positions on the energy transition, supporting a continued role for fossil fuels alongside renewable energy expansion. The company stated support for transitioning the energy mix on its corporate website, accessed in November 2022. Former company CEO Frank Mastiaux also appeared to support a greater role for green hydrogen alongside other renewables in the energy mix, whilst appreciating the nascent stage of the technology in an interview with Handelsblatt in January 2021. On its corporate website, accessed November 2022, the company appeared to support the role of hydrogen without specifying a production method, instead advocating for all forms of hydrogen production.

EnBW has repeatedly supported the weakening of the EU Sustainable Finance Taxonomy, by advocating for the inclusion of fossil gas, for example in its 2021 Annual Report, published in March 2022, and in a February 2022 Reuters article. Former CEO Frank Mastiaux appeared to advocate for an increase in LNG and fossil gas imports to diversify Europe’s energy mix away from Russian fossil fuels in a March 2022 Reuters article. The company also appeared to advocate in favor of fossil gas and hydrogen blending in the EU Hydrogen and Gas Decarbonization Package in a March 2022 consultation response, but emphasized the need to transition quickly to 100% hydrogen soon after. On its website, accessed in November 2022, the company also advocated for new investments in fossil gas infrastructure, on the basis of its later use for hydrogen.

The company position on the role of coal appears to be unclear. In January 2020, EnBW appeared to support Germany’s Coal Exit Law, but advocated for more clarity and linearity with the coal exit strategy published by the so-called “coal commission”. However, on its corporate website, accessed in November 2022, the company appeared to advocate for the continued role of coal, oil and gas in the energy mix on the basis of energy security.

Industry Association Governance: EnBW discloses a limited number of its industry association memberships but does not detail any indirect climate-related lobbying activities including positions of industry associations or how the company is attempting to influence these positions. The company has not published an audit of its alignment with industry links. In its disclosure, EnBW states membership to trade associations positively engaged on climate policy including WindEurope, but does not include Federation of German Industries (BDI), an association negatively engaged on climate policy.