Climate Lobbying Overview: The Federation of German Industries (BDI) is strategically engaged on climate change policy in the EU and Germany. The organization's top-line statements on climate policy have improved since 2018, but it appears to remain negatively engaged on key strands of EU climate policy, such as the Carbon Border Adjustment Mechanism (CBAM), the reform of the EU Emissions Trading Scheme (ETS), and CO2 Standards for Light Duty Vehicles. The association has extensively promoted fossil fuels in the energy mix.

Top-line Messaging on Climate Policy: BDI's top-line messaging on climate policy is mixed. In a May 2022 policy paper, the association supported carbon-neutrality by the ‘mid-century’ in line with IPCC timelines, as well as advocating for government policy like carbon pricing and a global carbon price floor to reach those targets. In a May 2021 consultation response, BDI did not support increasing the ambition of Germany's climate neutrality to 2045, questioning its feasibility and arguing that it would lessen ambition among other European nations. However, in a November 2021 briefing, the association appeared to accept the new target. The entity did not support the ‘Fit for 55’ package proposals in a November 2021 briefing, describing them as “massively price-increasing” without carbon leakage protections. The association has communicated support for the Paris Agreement goals and implementing NDC commitments in June 2022, and criticized the lack of progress made at COP27 in a tweet in November 2022.

Engagement with Climate-Related Regulations: BDI’s overall engagement with climate-related regulations in the EU appears to be mostly negative. The association did not seem to support the EU’s 2030 GHG emissions reduction target in a September 2021 joint statement. In November 2021 in response to an EU public consultation, BDI opposed the EU's carbon border adjustment mechanism (CBAM), describing the proposal as "premature" and stating its position as "generally skeptical to the unilateral introduction of CBAMs", advocating for the continuation of the free allocation of emissions allowances in the EU ETS until 2030. Additionally, in a position paper published in September 2022, BDI advocated for the CBAM to only be applied to sectors that support it and emphasized the carbon leakage risk of reducing the number of free emissions allowances in the EU ETS, and not supporting the extension of the EU ETS for the aviation sector to international flights.

In a September 2021 briefing BDI supported tax subsidies for energy efficiency in Germany, but argued that regulation should be considered a “last resort” in an October 2021 briefing. In December 2022, BDI seemed to generally support the inclusion of energy efficiency in buildings standards to the German energy savings campaign, however, in a press release in November 2022 the association did not fully support the proposed German energy efficiency law, suggesting that absolute energy efficiency targets are not desirable. In a November 2021 report, the association did not support proposed reforms to the EU Energy Efficiency Directive (EED), arguing that the proposed energy savings target of 1.5% was "unrealistic." In addition, in a September 2022 position paper BDI did not support an energy consumption cap in the EED and was not supportive of Minimum-Energy-Performance-Standards (MEPS) in the EU’s Energy Performance of Buildings Directive (EPBD).

In November 2021 in response to an EU public consultation, BDI opposed the proposed zero emission standard within the EU CO2 Standards for Light Duty Vehicles, stating that “German industry rejects a de facto ban on vehicles with internal combustion engines” and advocating for a 90% reduction target instead in a June 2022 press release.

Positioning on Energy Transition: BDI has been highly supportive of an increased role for fossil gas in Germany and Europe. In a January 2022 press release, BDI President Siegfried Russwurm supported "massive" fossil gas expansion in Germany without placing conditions on the need for CCS. The association subsequently supported the inclusion of fossil gas in the EU Sustainable Finance Taxonomy in a February 2022 press release. This follows a November 2021 report in which the association did not support the proposed change of taxation for fossil gas in the Energy Taxation Directive, stating that it would "jeopardize the competitiveness of energy intensive industry."

Following the Russian invasion of Ukraine, Siegfried Russwurm was quoted in a February 2022 Handelsblatt interview questioning the feasibility of bringing forward the phase-out of coal without endangering security of energy supply and in a press release in August 2022, Russwurm supported the re-connection of already phased out coal plants. However, in a March 2022 briefing the association supported the decarbonization of industry, advocating for carbon contracts for difference to aid industrial decarbonization in steel, cement and chemical products. In a December 2021 press release, BDI supported the decarbonization of transport via rail and the transition to a low-carbon energy sector via renewable hydrogen, although it advocated for "pragmatic" regulations on what hydrogen is considered sustainable.