Opinion of the European Economic and Social Committee – Phasing out fossil fuel subsidies while ensuring European competitiveness, mitigating the cost of living crisis, and promoting a just transition (own-initiative opinion)
Date: 2025-04-30
Institutions: European Economic and Social Committee
Subjects: adaptation to climate change, competitiveness, cost of living, economic independence, economic support, fossil fuel, inflation, regulatory policy, single market, social impact








C_202503191EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/3191


2.7.2025






Opinion of the European Economic and Social Committee

Phasing out fossil fuel subsidies while ensuring European competitiveness, mitigating the cost of living crisis, and promoting a just transition


(own-initiative opinion)

(C/2025/3191)


Rapporteur: 
Corina MURAFA BENGA






Advisor


Olivier VARDAKOULIAS




 


 




Plenary Assembly decision


5.12.2024




Legal basis


Rule 52(2) of the Rules of Procedure




Section responsible


Agriculture, Rural Development and the Environment




Adopted in section


1.4.2025




Adopted at plenary session


30.4.2025




Plenary session No


596




Outcome of vote
(for/against/abstentions)


145/13/10






Preamble



This opinion is part of a wider package of EESC opinions on the cost-of-living crisis. With this package, the EESC is examining the different facets of this policy challenge and presenting a comprehensive and wide-ranging set of recommendations to European and national policy-makers, civil society organisations and other stakeholders. The package includes seven ‘sectoral opinions’
            
             (1)
, each dedicated to issues in a specific relevant policy area. In addition, an ‘umbrella opinion’
            
             (2)
presents the overarching policy recommendations to address the cost-of-living crisis as a whole and build resilience against future crises.

1.   Conclusions and recommendations









1.1.


The phase-out of fossil fuel subsidies (FFSs) must be part of a broader tax and policy package, tailored to individual Member States. It should involve broad and inclusive social and civil dialogue to assess whether compensation schemes supporting low-carbon transitions should be introduced and, if so, which ones. The most environmentally and socially harmful FFSs should be phased out first. Untargeted subsidies should be removed, while targeted subsidies, based on household income or enterprise vulnerability, where needed, may be phased out more gradually and replaced by incentives for decarbonisation.












1.2.


The EESC recommends that the European Commission clarify in detail – in the country-specific recommendations under the European Semester – the actions Member States need to take to phase out FFSs as quickly as possible. In addition to including clear final and interim phase-out deadlines in their National Energy and Climate Plans (NECPs), Member States should also have specific milestones, targets, prioritisation measures and objectives for the phase-out, bearing in mind the individual contexts of the Member States.












1.3.


The European Commission, in partnership with stakeholders and the EESC, should set up an open, multi-stakeholder exchange platform, including civil society actors, for the Member States in order to share best practices on FFSs phase-out measures and programmes.












1.4.


The EESC recommends that protection mechanisms for jobs and working conditions should be put in place, including collective bargaining and social dialogue to ensure a balanced FFSs process.












1.5.


To overcome the definitional barriers detailed in this opinion, in the revision of the Energy and Climate Governance Regulation, the European Commission should propose a clear definition of FFSs, which is based on the IMF’s system and therefore also includes indirect subsidies, and should issue reporting guidelines for the Member States. Furthermore, the Commission should refine its reporting on FFSs by not only tracking statistics but also highlighting best practices for phasing them out.












1.6.


The revision of the Energy Taxation Directive (ETD) is a critical opportunity to support the FFSs phase-out in the EU. The EESC is worried about the delays in closing this file and calls on the European Parliament to adopt a position on the ETD revision as soon as possible. While leeway is needed to reflect the individual circumstances of the Member States, ambitious minimum taxation rates across the EU are essential to drive competitive decarbonisation. Exemptions should be optional and used with prudence.












1.7.


As part of the UNFCCC process, the European Union should continue to uphold the vision of an FFSs phase-out globally, to promote a level playing field for European companies and speed up decarbonisation, strengthening partnerships and mutual learning with countries that have made progress in this field recently.












1.8.


All forms of financial support for new fossil fuel infrastructure should be permanently removed across the totality of funding instruments under the 2028-34 multiannual financial framework. We instead recommend earmarking R&D funding for clean fuels, respecting strict criteria in line with the EU Taxonomy.












1.9.


The EESC recommends revising the State aid rules to help speed up the energy transition by no longer granting State aid support for fossil fuel-based energy projects.




2.   General comments









2.1.


Energy subsidies and government interventions are designed to lower costs for consumers below market prices, raise prices for producers above market levels or support energy infrastructure projects to lower the cost of capital. They include direct cash transfers to producers or consumers, indirect support mechanisms such as tax exemptions and credits, and market-based approaches that facilitate cross-subsidies among economic actors.












2.2.


The European Commission tracks such subsidies in the EU by means of the Subsidy Inventory. Fossil fuel subsidies (FFSs) thus cover various forms of financial support for all primary fossil energy and electricity generated by burning fossil fuels. Between 2020 and 2021, they doubled to EUR 136 billion, slightly decreasing to EUR 111 billion in 2023, representing over a third of all existing energy subsidies. Preliminary 2024 figures suggest a drop of total energy subsidies (fossil and non-fossil) to EUR 78 billion, as most of the crisis subsidies are expected to expire by 2025 (3). However, indirect subsidies – caused, for example, by externalising costs (e.g. healthcare costs, damage to buildings and infrastructure) – are not covered.












2.3.


These implicit subsidies, i.e. estimations of the social cost of carbon, the health costs from air pollution and other externalities such as traffic congestion and accidents, are included in the IMF’s corresponding calculation methodology. According to this methodology, FFSs in the EU are substantially higher than the Commission’s estimation, amounting to around USD 300 billion a year (4). Despite methodological differences, some Member States such as the Netherlands have come up with similar FFS estimates to the IMF. The EESC encourages the Commission to adopt or to develop a new, similar methodological approach, in addition to the current inventory.












2.4.


The steady level of FFSs contradicts existing political commitments to the phase-out of fossil fuels. International initiatives to rationalise and phase out FFSs were announced as early as 2009 by the G7 and G20, and more recently at the UNFCCC. Encouraging diplomatic efforts, such as the Agreement on Climate Change, Trade and Sustainability (ACCTS), should inspire the efforts of the EU in the upcoming UNFCCC COPs, where the Dutch-initiated Coalition on Phasing Out Fossil Fuel Incentives including Subsidies, joined by other EU Member States, should be actively promoted.












2.5.


The EU has taken the lead in implementing a set of tools and actions to effectively phase out FFSs, but so far, as the numbers show, the impact of these actions has been limited. The Regulation on the Governance of the Energy Union and Climate Action (2018) requires the Member States to report annually on progress in eliminating energy subsidies, particularly FFSs. This commitment was reinforced by the EU Climate Law (2021), which mandates the phase-out of subsidies that conflict with the 2050 climate neutrality goal. The European Commission is tasked with developing standardised methodologies and frameworks for reporting on FFSs and other environmentally harmful subsidies (5). The EESC invites the Commission to reflect on the social dimensions of harmful subsidies. Additionally, the proposed revision of the Energy Taxation Directive under the Fit for 55 package aims to align energy product taxation with climate objectives.












2.6.


FFSs have several detrimental effects, violate the ‘polluter pays’ principle, encourage continued reliance on fossil fuels and undermine the competitiveness of renewable energy. They therefore hinder the transition to renewable energy sources and exacerbate environmental degradation – including air pollution and biodiversity loss – and climate change. Thus, they blatantly contradict EU climate policy. Evidence shows that one million more heat pumps could have been installed in the EU in 2023 if the subsidies for fossil fuel boilers had been used for heat pumps (6).




3.   Specific comments on the impact of fossil fuel subsidies on competitiveness









3.1.


Beyond geopolitical considerations, the EU’s structural dependence on imported fossil fuels has a negative effect on the trade and current account balances of the EU, hence negatively impacting net exports and wider macro-economic performance (7). FFSs consequently increase the EU’s reliance on imports, slowing the energy transition. Furthermore, price volatility associated with fossil fuel imports is contributing to inflation episodes, such as the one experienced following the Russian invasion of Ukraine, undermining business competitiveness (especially for energy-intensive industries).












3.2.


From a fiscal policy standpoint, FFSs are reducing the fiscal space of Member States to finance other priorities, including support for businesses to invest in the energy transition or social expenditure. For example, FFSs remain higher than subsidies for renewable energy sources, despite the large ‘investment gap’ for achieving the 2030 energy transition and climate targets (8). Given the fiscal constraints resulting from the revised EU fiscal rules, redirecting FFSs towards climate objectives is crucial to bridge the climate investment gap.












3.3.


High energy costs hurt EU competitiveness with EU companies paying 2-3 times more for electricity than those in the US, and 4-5 times more for gas. While some FFSs exist to alleviate the cost of energy for businesses, they delay investments in alternatives and distort price incentives.




4.   Specific comments on the impact of fossil fuel subsidies on the cost of living









4.1.


Inflation triggered by Russia’s invasion of Ukraine has had a disproportionate impact on employees, with real wages in the EU declining by 5,1 % at the peak of the crisis in 2022. Concerning the energy sector, inflation disproportionately impacts vulnerable households which spend a larger proportion of their income on energy. In the medium term, only decarbonising the electricity system by transitioning to clean energy sources can reduce the cost of energy which triggered the cost of living crisis.












4.2.


Beyond the negative aggregate impact on government budgets, evidence suggests that FFSs are poorly targeted, predominantly benefiting wealthier social groups, and are therefore socially regressive (9). Finally, subsidising fossil fuel use is generating broader adverse social costs, such as premature mortality and morbidity due to air pollution, hitting vulnerable social groups in particular (10).












4.3.


Many subsidies were introduced to offer short-term relief, but fail to target low-income households or tackle the underlying causes of energy inflation. To effectively address the regressive impact of high energy prices on households, a two-legged approach anchored in just transition principles is required. First, more targeted direct income support for vulnerable households in the short-term; second, redirecting subsidies towards durable solutions, by mobilising funds for investments in decarbonised electricity and heating systems, while also renovating the housing stock, in order to reduce prices.












4.4.


Phasing out FFSs should go hand in hand with tighter control of the energy market, to protect vulnerable groups and avoid excessive price increases. Access to clean energy should be a constant concern, especially in rural areas.




5.   Specific comments on fossil fuels quantification and reporting









5.1.


A clear definition of what constitutes a fossil fuel subsidy, distinguishing efficient from inefficient ones, must be enforced at EU level, alongside specific guidelines for measurement and disclosure to address data coverage and quality for monitoring and measurement. This can be done in the upcoming revision of the Energy Governance Regulation. This definition may be based on the WTO typology of subsidies, currently used by the OECD, IRENA and UNEP. Furthermore, the incorporation of ‘implicit’ subsidies, as per the IMF’s definition, should also be considered in the medium term, especially for sectors that are not covered by the Emissions Trading System (ETS).












5.2.


Only 12 Member States have contributed to improving the data collected at EU level, leaving experts to rely on fragmented, incomplete and confusing national information. In general, the commitment to phase out FFSs at Member State level is weak, with only Denmark having a specific plan in place to do so. According to a preliminary assessment of the NECPs, as of 2023 only six of the 27 EU Member States had expressed their intention to fully phase out FFSs in their national budgets, with no specific end dates. Based on this assessment and other national plans and announcements, less than half of 2022 fossil fuel subsidies have a planned end date before 2025, 1 % are planned to be phased out between 2025 and 2030, while 52 % do not have an end date set even for after 2030 (11). The reporting methodology under NECP must be improved and streamlined.












5.3.


FFS phase-out aligns with the Sustainable Development Goals agenda, in particular target 12.C to remove market distortions that encourage wasteful consumption by rationalising inefficient fossil-fuel subsidies. Indicator 12.c.1 (12), namely the amount of FFSs (production and consumption) per unit of GDP is grossly miscalculated as tax expenditure and is optional for countries to report. To improve European competitiveness by creating a level playing at global level, EU Member States and the European Commission, in their diplomatic engagement process with the Inter-Agency and Expert Group on Sustainable Development Goal Indicators (IAEG-SDGs), should advocate for a mandatory inclusion of tax expenditure in the reporting.












5.4.


Transparency in fossil fuel subsidy inventories is critical for creating a constructive and inclusive dialogue with civil society. Good practices include Italy’s Catalogue of Environmentally Friendly Subsidies (EFS) and Environmentally Harmful Subsidies (EHS) and France’s Green Budget reporting, publicly disclosing the increasing gap between environmentally harmful and environmentally positive subsidies.












5.5.


At EU level, 83 % of all FFSs are meant to support energy demand. This offers the opportunity to replace demand-driven subsidies with other income support measures for consumers, in order to shift demand towards carbon-free alternatives.












5.6.


While energy prices remain high in Europe, they are far below crisis levels. However, by and large FFSs continue to occupy the same fiscal space as before the crisis, indicating a missed opportunity to invest funding in long-lasting, sustainable and more productive policy measures to alleviate the cost of living crisis and increase medium-term business competitiveness. Many of the temporary measures designed to cushion the effects of the energy price hike from 2022 are expected to be discontinued by the end of 2024/2025. The EESC recommends that the Commission vigilantly monitor the implementation of the agreed plans to discontinue the measures by Member States and identify, where needed, alternative, targeted support mechanisms for vulnerable groups. The EU should aim to have unified fiscal reforms to eliminate the use of fossil fuels.












5.7.


The European Commission and the European Environmental Agency should refine their reporting on FFSs by not only tracking statistics but also highlighting policies and best practices for phasing them out. This categorisation on the basis of their social, economic and environmental impact can guide the timeline and method for the phase-out, with transitional measures like parallel incentives, targeted exemptions, and scaffolding for a smooth transition, bearing in mind the 2030 and 2040 climate targets (13).




6.   Specific comments and principles for the phase out of FFSs

6.1.   Criteria and principles for the phase-out









6.1.1.


As a rule of thumb, any FFSs phase-out process should be part of a broader tax and policy package, to help consumers and businesses shift towards low-carbon alternatives, primarily where the shift is technologically available. All FFSs should be evaluated on a case-by-case basis and specific alternatives and/or compensatory schemes should be established, reflecting individual circumstances in the Member States.












6.1.2.


All FFSs phase-out processes should involve broad and effective social and civic dialogue, including all of the stakeholders affected, and be supported by a pan-European platform to exchange good practices and to foster mutual learning.












6.1.3.


FFSs should be evaluated according to their individual social and economic return, through systematic cost-benefit analyses (CBAs) for each subsidy, prioritising subsidies with low social and economic returns but taking up significant financial resources. On a similar note, the EU has committed to phase-out ‘inefficient’ FFSs in several multilateral fora, but failed to define what they are in practice. As such, the European Commission should, among other things, step up mutual learning with Canada, in light of its recently released Assessment Framework for Inefficient Fossil Fuel Subsidies (14).












6.1.4.


Similarly, FFSs should be evaluated based on their impact by income group, with subsidies disproportionately benefiting higher income groups phased out more quickly, and progressive taxation based on redistributive justice to enable the phasing out of FFSs.












6.1.5.


While certain agricultural activities may benefit from renewable energy sources, the broader agricultural sector, particularly in the field of operations (e.g. agricultural machinery), remains heavily dependent on fossil fuels. Large-scale agricultural machinery, including tractors, harvesters and fishing vessels, currently lacks commercially viable alternatives that can operate with the same efficiency and reliability as diesel-powered equipment. A transition strategy that accounts for technological readiness and economic feasibility is necessary to ensure that the agricultural and fishing sectors remain productive and competitive while progressively adopting sustainable energy solutions. An increased role for circular and sustainable bio-based products and services could provide an opportunity to address multiple challenges and help replace fossil fuels (15).












6.1.6.


In cases where an FFS scheme is deemed necessary for the time being for economic reasons, the scheme should run in tandem with a parallel scheme to support decarbonisation. For example, in the case of VAT refunds on diesel for farmers and transport entrepreneurs, the beneficiaries should be able to claim the same refund or a higher refund to support investment in machinery and vehicles running on electricity or renewable and low carbon fuels. Farmers and business players who embark on decarbonisation should receive incentives to do so.












6.1.7.


Untargeted subsidies should be removed, while targeted subsidies, based on household income or enterprise vulnerability, where needed, may be phased out more gradually and replaced by incentives for decarbonisation. The key principle should be that energy subsidies take the form of direct income support, not indirect support (such as price caps and tax exemptions), allowing households and enterprises to invest in new technologies that would enable them to wean themselves off fossil fuel dependency. The replacement of (untargeted) FFSs with (targeted) income support measures has been successfully implemented in several countries, including in the Global South, as documented (inter alia) by IMF and OECD reports.




6.2.   Safeguarding economic competitiveness while phasing out FFSs









6.2.1.


To mitigate the potential negative effects of phasing out FFSs on the competitiveness of European businesses, the Committee recommends redirecting revenues from high-benefit subsidies and carbon pricing to low-carbon technologies, helping businesses eliminate fossil fuel dependence.












6.2.2.


Taxation and decarbonisation policies, at Member State level and Europe-wide, should incentivise businesses to electrify all of their energy consumption when it is technologically feasible. The agricultural sector requires a distinct approach as it lacks viable, cost-effective replacements for fossil fuel-powered equipment. Financial incentives are needed to meet expensive infrastructure costs and prevent European agricultural producers from being put at a disadvantage. At the same time, prices and taxes for fossil fuels should signal to users the need to switch from polluting energy (e.g. gas) to low-carbon energy (e.g. electricity, hydrogen).












6.2.3.


Rather than relying on FFSs, businesses in Europe need and demand options, fuel-switching and locally produced renewable energy as the energy of choice. Under these circumstances it is regrettable that the European legislation on energy communities is not fully operational in many Member States.




6.3.   Safeguarding a just transition pathway for phasing out FFSs









6.3.1.


A Just Transition Policy Framework (16) must guide FFSs phase-out policies, with social compensation for disproportionately affected groups. Phasing out FFSs should not be an argument for redundancies or poorer working conditions. Protection mechanisms for jobs and working conditions, collective bargaining and social dialogue must remain a priority when phasing out FFSs. The EESC suggests compensation through direct investment subsidies in low-carbon technologies rather than universal income support, which may be ineffective and become an indirect FFS. For example, Austria’s Klimabonus (17), which rebates 100 % of the carbon tax to all residents, reduces inflation but lacks targeted support for those most in need of transition help and fails to encourage investment in low-carbon solutions.












6.3.2.


Due to the reliance of the Member States on tax-related FFSs, bearing in mind that any tax reform has a distributional impact, the potentially short-term regressive impact of the reform must immediately be remedied by rechannelling the revenue obtained towards social groups in difficulty. Similarly, the ‘greening’ process in the EU, through subsidies and tax advantages, should also target the most vulnerable sections of society and avoid regressivity in the agri-food sector (18) and beyond.












6.3.3.


In many Member States, such as France, recent public resistance to removing FFSs highlights the need for a direct redistribution initiative. The Social Climate Fund serves as a blueprint of how targeted financial support can help vulnerable households manage energy costs resulting from energy taxation reform, as long as the bulk of the fund is spent on structural measures. However, it still does not go far enough.












6.3.4.


As FFSs are phased out, the EESC recommends redirecting some of these funds to protecting jobs and reskilling programmes for workers in traditional industries, through transparent social dialogue. This will help them transition to new, green economy sectors, minimising job losses and fostering sustainable growth.




7.   Specific comments on EU policy levers for phasing out fossil fuel subsidies

7.1.   The role of the Energy Taxation Directive









7.1.1.


The updated Energy Taxation Directive (ETD) will establish new minimum fuel taxation rates across the EU, aligning them with a fuel’s pollution level per unit of energy, rather than economic, social and political factors. Energy taxation is currently at a level that poses challenges to the renewable transition. The price of electricity remains significantly higher than that of gas – three to four times more – making electrification uncompetitive in many sectors, such as heating, industrial processes and transport. Evidence shows that taxation and network charges play a crucial role in this disparity (19). In the transport sector, for example, the existing tax rates disincentivise the shift to zero-emission (electric) vehicles in corporate fleets (company cars) in several EU Member States (20).












7.1.2.


The ETD must be swiftly aligned with the European Green Deal. It must offer the necessary flexibility to Member States, while abiding by the principle whereby each form of energy is taxed according to the harm it does to the environment, with zero-carbon energy being incentivised via taxation measures.












7.1.3.


Given the pivotal importance of this piece of legislation for phasing out FFSs while upholding competitiveness and mitigating the cost-of-living crisis, the EESC urges the Council presidency to finalise the revision process. We also call on the European Parliament to adopt a position on the ETD revision as soon as possible, for the legislative process to be able to advance.




7.2.   The role of the multiannual financial framework (MFF)









7.2.1.


Although the majority of FFSs in the EU come from national budgets, EU funds are important for the provision of investment subsidies for new energy infrastructure, which risk locking the EU’s energy model in fossil fuels for decades, hampering its geopolitical position. The possibilities to finance fossil fuel investments through EU budget instruments have progressively been tightened in the 2021-27 EU budget through the permanent exclusion of EU financial support for coal and oil investments. However, selected midstream and downstream fossil gas investments (e.g. gas boilers and gas distribution) are still eligible in the largest EU funds, namely cohesion policy funds and the EUR 750 billion strong Recovery and Resilience Facility (RRF). Furthermore, instead of a further tightening of conditions for financing fossil fuel projects, the introduction of RepowerEU resulted in widening the scope of eligible gas investments by including LNG-related infrastructure that was previously ineligible in the RRF.












7.2.2.


Ahead of the upcoming European Commission proposal for the 2028-34 MFF regulations, and associated inter-institutional negotiations, the EESC calls on the European Commission to fully exclude all forms of financial support for fossil fuel infrastructure across the totality of funding instruments under the 2028-34 MFF, in its MFF Regulation proposal. These investment subsidies do not address social and distributional concerns, and their permanent phase-out is unlikely to result in adverse distributional impacts.




7.3.   The role of the European Semester









7.3.1.


The phase-out of FFSs has not been streamlined in the European Semester country reports or in the country-specific recommendations (CSRs) issued to the Member States, and the European Commission is currently considering ways of better integrating FFSs into the Semester process. Although Member States’ compliance with CSRs has so far been weak (21), this may change with the planned reforms to the EU Economic Governance Framework and new reform-linked instruments in the 2028-2034 multiannual financial framework. The EESC believes Member States should be steered more towards implementing concrete steps for phasing out FFSs. We believe the European Semester process can now serve such a purpose.












7.3.2.


Thus the EESC calls on the European Commission to streamline the reform and phase-out FFSs within the Semester process, including through dedicated CSRs.




7.4.   The role of the State aid rules









7.4.1.


As part of the Clean Industrial Deal and Omnibus initiatives, the State aid rules are expected to be revised in order to enable, inter alia, a faster deployment of renewable energy sources and industrial decarbonisation (22). A reform of the EU’s State aid framework must incorporate tighter rules for the provision of State aid to fossil fuel activities through national budgets whilst catalysing a faster deployment of clean energy infrastructure. The current rules still allow support for fossil fuels via both the Climate, Energy and Environmental Aid Guidelines (CEEAG) and the General Block Exemption Regulation (GBER) to a lesser extent (23). The current framework is notably being used to provide significant subsidies to fossil-based electricity producers via capacity mechanisms (a specific type of State aid) (24).












7.4.2.


As part of the future revision of State aid rules, the EESC calls on the Commission to include a roadmap for excluding support for fossil fuel-based energy projects and activities, in order to align State aid support with the EU’s commitment to phasing out FFSs.






Brussels, 30 April 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





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(2)  ECO/660 Recommendations of organised civil society to address the cost-of-living crisis (ongoing).

(3)  European Commission (2025), 2024 Report on Energy subsidies in the EU, COM(2025) 17 final, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0017.

(4)  Black, Simon, Antung Liu, Ian Parry, and Nate Vernon, 2023, IMF Fossil Fuel Subsidies Data: 2023 Update, Working Paper, IMF, Washington, DC. https://www.imf.org/en/Publications/WP/Issues/2023/08/22/IMF-Fossil-Fuel-Subsidies-Data-2023-Update-537281.

(5)  
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(6)  Study by Trinomics for the European Environmental Bureau and Coolproducts, available at https://www.coolproducts.eu/wp-content/uploads/2023/07/mission-possible-full-report.pdf.

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(9)  OECD Inventory of Support Measures for Fossil Fuels 2023, OECD Publishing, Paris, https://doi.org/10.1787/87dc4a55-en.

(10)  The Health and Environment Alliance (HEAL) released a report entitled, ‘
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(11)  
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(12)  
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(14)  
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(15)  Opinion of the European Economic and Social Committee – Aligning the circular economy and the bioeconomy at EU and national level (own-initiative opinion) (OJ C, C/2025/109, 10.1.2025, ELI: http://data.europa.eu/eli/C/2025/109/oj).

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(17)  
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(19)  Regulatory Assistance Project, available at https://www.raponline.org/knowledge-center/some-like-it-hot-moving-industrial-electrification-from-potential-to-practice/.

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(21)  European Court of Auditors (2020), The European Semester-Country Specific Recommendations address important issues but need better implementation, https://op.europa.eu/webpub/eca/special-reports/european-semester-16-2020/en/.

(22)  European Commission (2025), The Clean Industrial Deal: A joint roadmap for competitiveness and decarbonisation, COM(2025) 85 final. https://commission.europa.eu/document/download/9db1c5c8-9e82-467b-ab6a-905feeb4b6b0_en?filename=Communication%20-%20Clean%20Industrial%20Deal_en.pdf.

(23)  ClientEarth, The new State aid guidelines for climate, environmental protection and energy 2022, 2021, https://www.clientearth.org/media/vw1ea11b/legal-briefing-on-the-ceeag-final-24-12-2021-corrected.pdf.

(24)  
            https://auroraer.com/wp-content/uploads/2025/01/Capacity-Remuneration-Mechanisms-Report-Aurora_BFF_January-25.pdf.


ELI: http://data.europa.eu/eli/C/2025/3191/oj
ISSN 1977-091X (electronic edition)