The new State aid Framework to support the Clean Industrial Deal

ClientEarth's response to the CISAF consultation emphasizes the need for horizontal integration of the 'Do No Significant Harm' (DNSH) principle and the removal of aid for fossil gas in industrial decarbonisation. The organization warns that proposed 36-month project completion deadlines may compromise environmental permitting and public participation. It further advocates for stricter conditions on carbon capture and hydrogen aid, suggesting that support be limited to 100% renewable hydrogen and hard-to-abate sectors.

• ClientEarth argues that State aid policy lacks 'environmental mainstreaming', which creates a deficiency in safeguards against aid that harms the environment. They propose that the 'Do No Significant Harm' (DNSH) principle be 'horizontally integrated across State aid policy' and apply to all CISAF categories, not just renewable energy.
• The organization strongly opposes the use of State aid to support fossil gas for industrial decarbonisation, citing risks of 'lock-in effects', the displacement of public funds from fossil-free alternatives, and the creation of stranded assets.
• ClientEarth warns that the proposed 36-month deadline for renewable energy projects to start operating could lead Member States to prioritize speed over 'proper permitting processes or safety- and reliability-related infrastructure upgrades', potentially increasing legal risks and delays.
• Regarding non-fossil flexibility technologies, ClientEarth argues that current capacity mechanisms disproportionately benefit fossil fuel plants. They cite a report showing that since 2015, capacity markets in six European countries awarded €43.51 billion to gas plants and €7.41 billion to coal, compared to only €2.17 billion for demand-side response.

APA

ClientEarth (2025). The new State aid Framework to support the Clean Industrial Deal. https://www.clientearth.org/media/adloxhgv/clientearth-reply-to-cisaf-public-consultation.pdf

Chicago

ClientEarth. The new State aid Framework to support the Clean Industrial Deal. 2025. https://www.clientearth.org/media/adloxhgv/clientearth-reply-to-cisaf-public-consultation.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=The new State aid Framework to support the Clean Industrial Deal |date=April 2025 |url=https://www.clientearth.org/media/adloxhgv/clientearth-reply-to-cisaf-public-consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025new, author = {{ClientEarth}}, title = {{The new State aid Framework to support the Clean Industrial Deal}}, publisher = {ClientEarth}, year = {2025}, month = apr, url = {https://www.clientearth.org/media/adloxhgv/clientearth-reply-to-cisaf-public-consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }