Revision of the General Block Exemption Regulation

ClientEarth argues that the GBER lacks effective environmental safeguards and continues to permit harmful subsidies, particularly for fossil gas. The organisation proposes introducing horizontal conditionalities, such as the 'Do No Significant Harm' principle and the 'Energy Efficiency First' principle, and calls for the removal of block exemptions for fossil gas activities and tax reductions on fossil gas-fired electricity. Additionally, it suggests creating a tailored block exemption to support small-scale coastal fishing.

• The GBER lacks effective horizontal environmental safeguards, which ClientEarth argues is a violation of the 'integration' principle requiring environmental protection to be integrated into all Union policies. To address this, they propose that the GBER exclude aid measures that violate EU environmental law and explicitly require compliance with the 'Do No Significant Harm' (DNSH) principle across all aid objectives.
• The 'Energy Efficiency First' principle is not currently implemented in the GBER's design or conditions. ClientEarth recommends that Member States should be required to declare that environmental aid is only granted if the same objectives cannot be achieved through non-aid energy efficiency policies or if energy efficiency aid is insufficient.
• Publication obligations for aid awards exceeding EUR 100,000 are poorly respected by Member States and poorly enforced by the Commission. ClientEarth suggests introducing alternative, more limited sanctions—such as temporary withdrawal of block exemption benefits—to incentivise compliance, as the current power to withdraw the benefit entirely is rarely used.
• The GBER continues to support fossil gas through various categories, including high-efficiency cogeneration, gas-fired district heat/cooling networks, and gas infrastructure. ClientEarth argues this creates lock-in effects and contradicts EU emission targets, recommending that fossil gas aid be removed from the GBER and subject only to prior notification.
• Article 48 of the GBER regarding fossil gas infrastructure is deemed ambiguous, specifically the term 'dedicated' to hydrogen or renewable gases, which ClientEarth claims does not require actual use. They propose strict guardrails, including a requirement for 100% renewable hydrogen or gas conversion by 2035 and a guarantee that conversion costs will not use public financing.
• ClientEarth opposes the use of GBER Article 36 to support Carbon Capture, Utilization, and Storage (CCUS), arguing it is commercially unproven and fosters fossil fuel use. They suggest that if CCUS remains, it should be restricted to hard-to-abate sectors with a minimum capture rate of 95% and permanent storage.
• Article 44 of the GBER allows tax reductions on electricity from biomass and fossil gas-fired CHP, which ClientEarth argues undermines the 'polluter pays' principle. They note that aid under Article 44 amounted to over EUR 14.59 billion of the EUR 22.05 billion spent on environmental and energy aid under the GBER and urge the removal of fossil gas and biomass from this scope.
• There is a perceived gap in aid for small-scale coastal fishing. ClientEarth proposes revising GBER Article 1.3(a) to allow aid for processing and marketing specifically for small-scale fishers, covering investments in digitalisation, circular economy, and representation in European bodies.

APA

ClientEarth (2025). Revision of the General Block Exemption Regulation. https://www.clientearth.org/media/or5nbxhl/clientearth-reply-to-call-for-evidence-gber-final.pdf

Chicago

ClientEarth. Revision of the General Block Exemption Regulation. 2025. https://www.clientearth.org/media/or5nbxhl/clientearth-reply-to-call-for-evidence-gber-final.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Revision of the General Block Exemption Regulation |date=October 2025 |url=https://www.clientearth.org/media/or5nbxhl/clientearth-reply-to-call-for-evidence-gber-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025revision, author = {{ClientEarth}}, title = {{Revision of the General Block Exemption Regulation}}, publisher = {ClientEarth}, year = {2025}, month = oct, url = {https://www.clientearth.org/media/or5nbxhl/clientearth-reply-to-call-for-evidence-gber-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }