Climate Lobbying Overview: BusinessEurope has predominantly actively opposed EU climate policy ambition since 2018 and appears to continue to lobby against various aspects of increased climate policy stringency proposed under the EU Green Deal and the Fit for 55 package.

Top-line Messaging on Climate Policy: BusinessEurope appears to be supportive in its top-line messaging on climate policy, albeit with major exceptions. It has stated support for net-zero emissions in the EU, but in 2020-21 regularly associated this with a timeline of “around mid-century”, rather than by 2050 specifically, in position papers, leadership messaging and organizational messaging. In 2022-23, BusinessEurope regularly emphasized the risk of deindustrialization in relation to the EU Green Deal, for example, in a letter to the EU Environment Council Chair in February 2023. The association has consistently stressed the burdens on industry and the risks of unilateral action stemming from European climate policy in 2018-23, for example, in a position paper in November 2022 and a newsletter in December 2022, although it did broadly advocate for a climate club based on a global carbon floor price and international standardization. BusinessEurope supports the UN Paris Agreement but has consistently stressed the ambition gap between the EU’s Nationally Determined Contribution and other countries, in a November 2022 position paper it stated that] the EU should only increase its NDC on the condition that other major emitters also increase their targets.

Engagement with Climate-Related Regulations: BusinessEurope does not seem to support ambitious climate regulation in the EU. Since 2018, BusinessEurope has directly lobbied policymakers in opposition to ambitious reforms to the European Emission Trading Scheme (EU ETS). The association supported a weaker reform of the EU ETS, advocating in particular for a staggered rebasing of the emissions cap in a July 2022 newsletter, and in a December 2022 press release quoting the Director General. However, in the same press release he seemed to support an ETS for road transport and buildings including private households. In a December 2022 letter to Members of European Parliament BusinessEurope opposed extending the scope of the EU ETS to extra-EU flights, and did not support including non-CO2 emissions. In a December 2022 press release, the Director General stressed the impacts on companies’ international competitiveness from the Carbon Border Adjustment Mechanism, and advocated for export rebates to be included, supporting a gradual application of the CBAM until the mid-2030s, a position which is misaligned with the EU Commission.

In a response to an EU public consultation in November 2021 the association did not support several reforms to the Energy Efficiency Directive (EED), including the increase in the energy savings obligation and the exclusion of energy savings from fossil fuels to reach the obligation, and in a July 2022 tweet it suggested that the EED could lead to deindustrialization. In November 2021 in response to an EU public consultation, BusinessEurope was unsupportive of certain reforms in the revision of the Renewable Energy Directive, including the review of the bioenergy criteria, and advocated against “overly prescriptive consumption targets.” In December 2022, in a letter to Members of European Parliament, the association did not support higher national targets in the ReFuelEU Aviation policy, advocating for voluntary measures, and a flexibility mechanism for Sustainable Aviation Fuels.

In a February 2023 letter to the Chair of the EU Environment Council the association opposed implementing mandatory requirements on GHG emissions through the Industrial Emissions Directive reform, stressing double regulation with the EU ETS. However, in a November 2022 position paper on COP27, BusinessEurope supported methane regulation such as performance standards.

Positioning on Energy Transition: BusinessEurope seems to take mostly unsupportive positions on the energy mix. In a letter to the EU Council in December 2022, the association supported decarbonizing the EU using renewable, low-carbon and nuclear additional capacities, as well as fossil gas, whilst emphasizing the risks of deindustrialization. In a position paper in December 2022, BusinessEurope advocated for policymakers to weaken the ambition of proposals for aviation infrastructure in the Alternative Fuels Infrastructure Regulation, but supported increasing recharging infrastructure. However, in a letter to the Chair of the EU Competitiveness Council in February 2022, the association did not support policies to scale up electric vehicles including the EU’s 2035 CO2 standard for light duty vehicles. In a newsletter in March 2022, the association did not support the FuelEU Maritime regulation, suggesting that over-regulation would cause carbon leakage. In a March 2022 meeting with EU Commissioner Sinkevicius, BusinessEurope supported diversifying the energy mix in Europe away from dependency on Russian fossil fuels by delaying the coal phase out. Furthermore, in response to the US Inflation Reduction Act BusinessEurope has consistently and actively advocated for EU regulations to decarbonize industry to be weakened to “lower the regulatory burden” by, for example, reducing energy taxes and levies, in messaging from leadership, letters to EU policymakers, newsletters and position papers in February and March 2023. In a letter to the President of the EU Economic Council in March 2023, the association supported weakening the revision of the Energy Taxation Directive to lower rates of taxation for synthetic fuels as well as renewable hydrogen.