Climate Policy Engagement Analysis
Climate Policy Engagement Overview: FuelsEurope is strategically engaged on European climate policy, with a specific focus on transport-related policy including emissions standards. The association’s top-line communications state support for the 2050 net-zero target and the Paris Agreement, however the association appears to take both positive and negative positions on the need for climate-related regulations to respond to climate change. The association advocates for the continued role of internal combustion engine (ICE) vehicles through the use of biofuels and e-fuels in light duty road transport, and appears to oppose policies which solely promote electrification by calling for the inclusion of ‘low carbon’ or renewable fuels.
Top-line Messaging on Climate Policy: Top-line Messaging on Climate Policy: FuelsEurope’s top-line messaging on climate policy is mostly positive. In a November 2023 letter to Ditte Juul Joergensen, the Director General for Energy of the European Commission, FuelsEurope supported the objective of carbon neutrality by 2050 and in a February 2024 open letter, FuelsEurope Director General, Liana Gouta stated that the association stands behind the Paris Agreement. However, the association takes a mix of positive and negative positions on the need for climate-related regulations. For example, in a follow-up communication with the European Commission in December 2023, FuelsEurope advocated for policymakers to support a “clear and strong” EU Industrial Policy to transition to a decarbonized industry. However, on Twitter in February 2023, the then- Director General of FuelsEurope, John Cooper, qualified his apparent support for climate change regulation by advocating for it to be technology neutral and “preserve energy-intensive industries' competitiveness.”, Cooper similarly emphasized economic and competitiveness concerns around the Fit for 55 package, on a podcast in April 2023.
Engagement with Climate-Related Regulations: FuelsEurope appears to have predominantly negative positions on EU climate regulations, including renewable energy policy, energy efficiency policy, GHG emissions regulations, and land use policy. In regard to renewable energy and energy efficiency policy, the association did not appear to support measures to boost the deployment of renewables in the EU Electricity Market Design reform, submitting a February 2023 consultation response that appeared to advocate for power-purchase agreements and two-way contracts for difference for renewables to be voluntary and technology-neutral, thereby reducing the ambition of the policy. The association also appeared to advocate for weaker criteria for heating systems that are considered fossil fuels under the Energy Performance of Buildings Directive, in a March 2023 joint statement.
In regard to GHG emissions regulations, FuelsEurope Director General Liana Gouta published a January 2024 press release that appeared to advocate for a weakening of the EU's Heavy-Duty Vehicle (HDV) CO2 emission standards by calling for the inclusion of renewable fuels. The association also appeared to advocate for the inclusion of low-carbon fuels as a compliance pathway in this policy in a March 2023 letter to Frans Timmermans, submitted as consultation response. FuelsEurope subsequently submitted comments on the EU 2040 Climate Target in June 2023, in which the association appeared to advocate for the national targets under the Effort Sharing Regulation to be limited to GHG emissions not covered by the EU ETS and to be replaced by EU-wide sectoral legislation, which would reduce the ambition of the policy.
In regard to land use policy, in January 2023 feedback on the delegated act on Renewable Energy Directive (RED) Annex IX feedstocks, FuelsEurope appeared to oppose additional restrictions on ReFuelEU Aviation feedstocks for sustainable aviation fuels, which would reduce the stringency of the policy.
Positioning on Energy Transition: FuelsEurope appears to consistently advocate for the use of biofuels and e-fuels over widespread electrification in light duty road transport, with the aim of promoting the continued use of ICE vehicles. Although the association supports the electrification of transport, it appears to oppose policy which promotes solely electric light or heavy-duty vehicles, or renewables, and instead appears to advocate for a ‘technology neutral’ approach to policy that would enable the inclusion of ‘low carbon’ or ‘renewable fuels’.
For example, in a letter to Frans Timmermans submitted as a consultation response in March 2023, FuelsEurope appeared to advocate for a technology-neutral approach towards the decarbonization of HDVs and promoted a long-term role for ICE HDVs powered by carbon-neutral fuels. In a March 2022 open letter to the French President, FuelsEurope’s previous Director General, John Cooper, appeared to oppose the EU’s 2035 effective internal combustion engine (ICE) phase-out date, advocated for a long-term role for ICE and hybrid vehicles post-2035, and promoted the use of low-carbon fuels to achieve decarbonization over rapid electrification. In a joint letter to Frans Timmermans in February 2023, Cooper appeared to again advocate for a long-term use of biofuels/synthetic fuels alongside a transition to Zero Emissions Vehicles (ZEVs), and also emphasized concerns with a complete transition to ZEVs. In addition, in a July 2024 consultation response, accessed via freedom of information request, FuelsEurope opposed the introduction of mandatory zero-emission vehicle targets for corporate fleets, and advocated for a role for renewable fuels over a complete transition to zero-emission vehicles.
The association also appeared to advocate for extending the focus of the Net Zero Industry Act to all low-carbon and renewable energy sources, in comments submitted in May 2023, which would weaken the ambition of the policy. In a position paper in June 2023, FuelsEurope again appeared to advocate for list of strategic net-zero technologies under the EU Net-Zero Industry Act to include renewable and low-carbon fuels for use in road transport as well as Carbon Capture and Utilization (CCU).
FuelsEurope appeared unsupportive of the EU’s Electricity Market Design revision in a joint statement in May 2023, calling for energy to be supplied in a technology neutral manner and for renewable capacity to be expanded at a 'realistic' speed. The association also appeared to advocate for relying on industrial carbon removals, rather than GHG emissions reductions in the EU 2040 Target, in comments submitted on the policy in June 2023.
Please see here for InfluenceMap's response to FuelsEurope's September 2023 statement on its InfluenceMap assessment.