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Ember’s response to the call for evidence for the EU Electrification Action Plan

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Ember's response to the EU Electrification Action Plan call for evidence argues that while technology for electrification is available, high costs and disproportionate taxation of electricity compared to fossil fuels are major barriers. Ember recommends rebalancing energy taxation, incentivizing smart consumption via dynamic tariffs, reforming grid planning to prioritize fossil-fuel displacement, and expanding market access for battery storage to lower total system costs.

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  • Electricity currently accounts for less than a quarter of the EU's total final energy demand, specifically 23% in 2023. While technology readiness is not a barrier—with Ember research indicating that an additional two thirds of the EU's energy demand could be electrified using currently available technologies—high costs for consumers remain a primary obstacle.
  • Electricity in the EU is disproportionately taxed compared to fossil fuels; for instance, taxes and levies on mid-sized industrial electricity consumption are on average triple those of gas consumption. Ember recommends that the Electrification Action Plan prioritize the revision of the Energy Taxation Directive and shift fossil fuel subsidies toward electric technologies like electric vehicles and heat pumps.
  • To lower costs and manage demand peaks, the EU should incentivize 'smart' consumption through dynamic or time-of-use tariffs and ensure infrastructure is 'smart' by default. This includes adopting a regulatory approach based on total expenditure rather than just capital expenditure to reward non-wire solutions and flexibility.
  • The EU's current grid planning process is described as no longer fit for purpose. Ember suggests the Action Plan should strategically prioritize grid access for demand that displaces fossil fuels, specifically electrified housing, EV charging stations, and large industrial consumers.
  • To maintain low electricity costs, the EU must increase capacity for batteries and other storage solutions. Ember proposes that the Action Plan allow demand response and batteries to participate in all markets—including wholesale, capacity, balancing, ancillary service, and flexible local markets—and remove the double charging of grid fees for batteries.

Cite the original document

APA
Harrison, T., & Rosslowe, D. C. (2025). Ember’s response to the call for evidence for the EU Electrification Action Plan. Ember. https://ember-energy.org/app/uploads/2025/10/EAP-Call-for-Evidence.pdf
Chicago
Harrison, Tom, and Dr Chris Rosslowe. Ember’s response to the call for evidence for the EU Electrification Action Plan. Ember, 2025. https://ember-energy.org/app/uploads/2025/10/EAP-Call-for-Evidence.pdf.
Wikipedia
{{cite press release |last1=Harrison |first1=Tom |last2=Rosslowe |first2=Dr Chris |title=Ember’s response to the call for evidence for the EU Electrification Action Plan |publisher=Ember |date=8 October 2025 |url=https://ember-energy.org/app/uploads/2025/10/EAP-Call-for-Evidence.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{harrison2025embers, author = {Harrison, Tom and Rosslowe, Dr Chris}, title = {{Ember’s response to the call for evidence for the EU Electrification Action Plan}}, publisher = {Ember}, year = {2025}, month = oct, url = {https://ember-energy.org/app/uploads/2025/10/EAP-Call-for-Evidence.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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