Climate Lobbying Overview: The Spanish Confederation of Business Organizations (CEOE) is actively engaged on climate change policy in Spain and the EU, with mostly unsupportive positions. Its stances on some key climate policy streams and top-line ambition appear to have improved since 2019, but it seems to be negatively lobbying on other legislation such as the EU’s 2030 Climate Target.

Top-line Messaging on Climate Policy: CEOE appears to broadly support top-line climate policy, yet emphasizes concern around its impacts on international competitiveness. In a November 2021 report, the association supported reaching climate neutrality by 2050, but stressed that this can only be achieved whilst maintaining competitiveness and preserving jobs. In response to an EU public consultation in April 2020, CEOE supported revising energy and climate policies to align with the EU’s increased 2030 Climate Target. However, in March 2022 in a report on the Fit for 55 package, the association advocated for a “reality check” due to the current energy price crisis.

Engagement with Climate-Related Regulations: CEOE appears to have predominantly negative engagement with key climate policies in the EU. In a report on the Fit for 55 package in March 2022, the association did not seem to fully support the increased 2030 GHG emissions reduction target, as it stressed the costs and challenges of achieving it. In the same March 2022 report, CEOE suggested that climate policy should protect against the asymmetry of the EU carbon price compared with the rest of the world, and supported the free allocation of emissions allowances. In April 2020, in response to an EU public consultation, the association did not support extending the EU ETS to the maritime sector, suggesting that global measures implemented under the International Maritime Organization were more suitable. In November 2021 CEOE’s President Antonio Garamendi signed a declaration which supported a Carbon Border Adjustment Mechanism in the EU alongside carbon leakage protection measures until the policy has proven its effectiveness, such as the free allocation of emissions allowances in the EU ETS. It also advocated for the inclusion of export rebates, a position which is misaligned from the EU Commission’s proposal. However, CEOE has shown more positive engagement advocating for government support for investment programs in energy efficiency, for example, in a November 2021 report. CEOE supported policies to facilitate the development of renewable energy in a position paper in December 2020.

Positioning on Energy Transition: CEOE seems to take a mixed position on the transition of the energy mix. In November 2021 CEOE’s President signed a declaration supporting measures to increase renewable and low-carbon energy in the energy mix, and El Diario reported that he was in favor of phasing out coal from Spain’s energy mix in September 2021. Furthermore, in a December 2021 press release, CEOE supported policy to improve electric vehicle charging infrastructure in Spain. However, in March 2022 in a report on the Fit for 55 package, the association advocated that measures to transition the energy mix must maintain the international competitiveness of industry and must be socially and economically viable. Furthermore, in an April 2020 response to an EU public consultation, CEOE supported preserving technology neutrality in the Energy Taxation Directive reform, which proposed to align energy taxation with the energy transition via increased taxation on fossil fuels. The association also supported technology neutrality in the reform of the Alternative Fuels Infrastructure Regulation, in a response submitted to an EU public consultation in April 2020.