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 key legislation particularly relating to the aviation industry.

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 a May 2022 position paper, CEOE supported the need for public policy to achieve decarbonization and incentivize investment, but advocated that the Fit for 55 package should include realistic timelines, and in March 2022 in a report on the Fit for 55 package, it advocated for a “reality check” due to the high energy prices. CEOE seems to support the UN Paris Agreement, stating in a video on its website that it supported COP26 and the finalization of the Article 6 rulebook in October 2021.

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 a May 2022 position paper CEOE advocated for technology neutrality in the CO2 standards for light duty vehicles, a position misaligned with the EU Commission.

In a May 2022 report, CEOE advocated for ‘sufficient’ carbon leakage protection measures in the EU Emissions Trading System and an adequate level of free allocation of emissions allowances. In a May 2022 position paper, CEOE advocated for a Carbon Border Adjustment Mechanism in the EU alongside carbon leakage protection measures, the free allocation of emissions allowances in the EU ETS, and in a March 2022 position paper, it advocated for the inclusion of export rebates, a position which is misaligned from the EU Commission’s proposal.

However, the association takes more positive positions on energy efficiency legislation, supporting the EU Green Deal to promote the renovation of buildings in a position paper in May 2022. In a November 2021 report CEOE advocated for government support for investment programs in energy efficiency. However, in November 2022 the news outlet El Mundo reported that the association was not supportive of the ReFuelEU Aviation policy as it stated it would cause job losses.

Positioning on Energy Transition: CEOE seems to take mostly unsupportive positions on the transition of the energy mix. In November 2022, the President signed a joint declaration supporting deploying additional fossil gas capacity in Europe as well as renewable, nuclear and low-carbon energy, whilst emphasizing the risk of deindustrialization. The President also did not support environmental taxes on the aviation sector under the Energy Taxation Directive reform, stressing it would be a burden for the competitiveness of the industry, in September 2022, and the news outlet El Mundo reported in November 2022 that CEOE did not support the transition to Sustainable Aviation Fuels, suggesting it would cause job losses. In a May 2022 report, the association supported breakthrough technologies in mobility and storage, and increasing renewables, hydrogen and sustainable fuels development. However, it also supported relaunching Iberian gas connections to diversify the European energy mix away from Russian fossil fuels.