Climate Policy Engagement Analysis
Climate Policy Engagement Overview: The French Association of Large Companies (AFEP) is actively engaging with climate policy and holds broadly negative positions. The association does not appear to support the need for stringent climate policy in the EU, and consistently engages on EU carbon pricing legislation with negative positions. AFEP seems to support the energy transition with exceptions.
Top-line Messaging on Climate Policy: AFEP does not appear to support climate policy in its top-line messaging. In an April 2024 position paper, AFEP advocated for a revision of policies adopted under the EU Green Deal, suggesting ambition and timelines should be revised to protect industry competitiveness. In another position paper published in January 2025, the association suggested that legislation adopted under the EU Fit for 55 Package would lead to a loss of European competitiveness. InfluenceMap did not detect positions from AFEP on climate science, IPCC-demanded emissions reductions, or the UN Paris Agreement in 2023-25.
Engagement with Climate-Related Policies: AFEP appears to have mostly negative engagement with EU climate-related policies in 2023-25. In an April 2024 position paper, the association advocated for a review of the EU Emissions Trading System (ETS) and appeared to promote reforms that would weaken the climate ambition of the policy such as postponing the phase-out of free emissions allowances. Further, AFEP did not support conditionality rules for the allocation of free emissions allowances in the ETS in a January 2025 position paper. In the same position paper, and in misalignment with the EU Commission’s original policy ambition, the association appeared to advocate for a delayed phase-out of carbon leakage protection measures under the EU ETS, and conditioned its support for a phase-out on the effectiveness of the EU Carbon Border Adjustment Mechanism (CBAM). AFEP also appeared to promote a delayed entry into force and the inclusion of export rebates in the CBAM in an April 2024 position paper, which is not aligned with the EU Commission’s original climate ambition.
Positioning on Energy Transition: InfluenceMap detected supportive engagement from AFEP on the energy transition in 2023-25 with some exceptions. The association broadly supported the decarbonization of transport in a position paper published in April 2024, in which it promoted investments in rail infrastructure, charging infrastructure for electric vehicles, and an increased use of sustainable aviation fuel (SAF). In the same position paper, AFEP advocating for a variety of measures to decarbonize the EU economy, including investments in hydrogen and carbon capture infrastructure, however, without stating the need to fully decarbonize, nor the intended sectors. The association did not appear to support decarbonization of industry in the same April 2024 position paper, advocating for a slower implementation of the EU Net Zero Industry Act targets.