Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules

ClientEarth argues that EU State aid rules must be transformed into sustainability instruments that prohibit support for fossil fuels and harmful biomass, while prioritizing energy efficiency and renewable energy. The document calls for the strict application of the 'Energy Efficiency First' principle, the exclusion of low-carbon (fossil gas-based) hydrogen from subsidies, and the removal of aid for high-efficiency combined heat and power (CHP) plants. It further recommends increasing support for energy communities, zero-emission vehicles, and energy efficiency in buildings, while introducing a 'greenwashing test' to ensure the environmental integrity of aid beneficiaries.

• ClientEarth proposes that the EEAG be transformed into sustainability guidelines where aid is only compatible with the internal market if the activity complies with all EU environmental law obligations and directly contributes to 2030 and 2050 climate targets.
• The document argues for a total ban on State aid for fossil fuels, including for electricity, heat generation, and infrastructure, stating such investments contradict the European Green Deal and the target to reduce greenhouse gas emissions by at least 55% by 2030.
• ClientEarth recommends that the 'Energy Efficiency First' (EE1st) principle be a mandatory priority baseline for assessing the necessity of any energy sector aid, requiring Member States to justify why energy efficiency or demand-response measures cannot replace the proposed aid.
• The organization calls for the exclusion of low-carbon (fossil gas-based) hydrogen from State aid, arguing it is inconsistent with the Paris Agreement and risks 'greenwashing' and 'lock-in effects of gas'.
• The document urges the Commission to stop supporting forest biomass and small hydropower plants, citing evidence that forest biomass can have higher carbon emissions per unit of electricity than coal and that small hydro causes significant river fragmentation.
• To prevent 'greenwashing', ClientEarth suggests a test requiring beneficiaries to substantiate sustainability claims with science, be specific about benefits, and use fair labels.
• The document recommends a specific State aid regime for energy communities (RECs and CECs), including higher thresholds for exemptions from bidding procedures, to allow smaller citizen-led projects to compete with large-scale players.
• ClientEarth proposes increasing aid intensity for energy efficiency measures in buildings to match those for renewable energies (up to 65% for small enterprises) to support the Renovation Wave Strategy.
• Regarding Carbon Capture and Storage (CCS), the document argues that aid should be restricted to 'hard to abate' industries like cement and agriculture, and prohibited for fossil fuel and biomass power plants.

APA

ClientEarth (2021). Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules. https://www.clientearth.org/media/w01ikefa/clientearth-reply-to-the-consultation-on-revision-of-eeag-07-01-2020.pdf

Chicago

ClientEarth. Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules. 2021. https://www.clientearth.org/media/w01ikefa/clientearth-reply-to-the-consultation-on-revision-of-eeag-07-01-2020.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules |date=January 2021 |url=https://www.clientearth.org/media/w01ikefa/clientearth-reply-to-the-consultation-on-revision-of-eeag-07-01-2020.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021revision, author = {{ClientEarth}}, title = {{Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules}}, publisher = {ClientEarth}, year = {2021}, month = jan, url = {https://www.clientearth.org/media/w01ikefa/clientearth-reply-to-the-consultation-on-revision-of-eeag-07-01-2020.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }