IOGP Europe’s response to the Public consultation on the renewable energy framework (post-2030 RED) for the decade ahead

The following excerpts are taken from IOGP Europe's response to the public consultation on the renewable energy framework for the decade ahead.

Download the document to view the full response.

Question 1: How important are the following factors in hindering or slowing down progress towards a higher share of renewables in the EU?

• Complexity of the EU legislation: 5 - Very important
• Gaps in the EU legislation: 5 - Very important
• Insufficient or uncertain business case (economic viability): 5 - Very important
• High costs of renewable energy technologies: 5 - Very important
• High cost of electrification solutions: 5 - Very important
• High cost of renewable fuel solutions, including price of renewable fuels: 5 - Very important
• Unfavourable electricity-to-fossil price ratio: 1 - not important

Question 2: In the context of the revision of the Governance Regulation, the Commission has asked for evidence in the period between 18 December 2025 and 19 March 2026 on the preferred target architecture for the energy post-2030 framework.

IOGP Europe believes that the priority option should be Option 3: Define a single, overarching clean energy target for the EU, with embedded minimum thresholds for key energy parameters (e.g. renewable energy)

• The post-2030 energy framework should build on the existing structure, preserving continuity and certainty for companies and ongoing projects, while introducing the necessary adjustments to improve flexibility and coherence. Technology openness, anchored in lifecycle GHG intensity rather than pathway-specific criteria, is essential to provide industry and Member States with affordable options to competitively decarbonise, capitalising on the best-suited technologies available in their context. Investments already made under REDIII must not be stranded and the market retained, including the refinery route, which should remain as a clear and valid compliance option for RFNBOs beyond 2030. For industry in particular, low-carbon hydrogen volumes should be deductible from the denominator used to calculate the hydrogen mandate, ensuring all pathways meeting the 70% GHG emissions reduction can contribute. This should be reflected under existing provisions Art. 22a under REDIII.

Question 3 - Question 5: No response

Question 6: How important are the following measures for increasing market-driven investments in renewable energy projects in the EU?

• Strengthen the guarantees of origin framework with additional information and rights for consumers: 3 - Neutral
• Simplify the guarantees of origin system and enable more flexibility for Member States to exercise their responsibilities: 4 - Important
• Remove barriers to energy purchase agreements including Power Purchase Agreements (PPAs): 4 - Important
• Remove barriers to revenue stacking and the combination of multiple revenue streams at EU and/or national level: 5 - Very important
• Reinforce support for demand-side measures (e.g. electrification of end-uses): 5 - Very important
• Maintain the current framework: 3 - Neutral

Comment or specify other measures you would propose, if any:

• Technology-inclusive funding: Financing and support schemes should be designed to accommodate all technologies that support the climate objectives based on lifecycle assessment.
• Blending of funds: Ensure mutual recognition of eligibility criteria, cumulation rules and unique reporting rules between funds with similar scope.
• Align European and state aid funding across the full hydrogen value chain: production, transport, and end use, to address key bottlenecks, particularly the lack of hydrogen infrastructure that is a prerequisite for scaling hydrogen imports.
• Demand-side measures: Complement funding schemes inflation/carbon-price indexation mechanisms and demand-side measures (public procurement commitments, clean product standards, offtake guarantees)

Question 7: How important are the following measures for accelerating the integration of renewable energy generation into the electricity system?

Comment or specify other measures you would propose, if any:

• The fundamental challenge of integrating record volumes of variable renewable generation into the EU electricity system requires dispatchable, flexible backup capacity that storage technologies and demand response alone cannot yet provide at the scale and speed required. Natural gas infrastructure, including pipelines, storage facilities and gas-fired generation, remains the most immediately available and system proven flexibility enabler, capable of absorbing renewable variability, preventing curtailment, stabilising grid frequency, and ensuring security of supply during periods of low renewable output. Beyond gas infrastructure being recognized as a transitional asset, the post-2030 framework should explicitly recognise its role in enabling higher penetration of RES electricity, and ensure that energy system integration policy reflects the full multi-energy system (natural gas, CO2, H2 and electricity) as the most cost-effective pathway to a resilient, decarbonised energy system.

Question 8: How important are the following measures for accelerating the electrification of energy consumption/demand sectors?

Comment or specify other measures you would propose, if any:

• A multi-energy system approach combining electricity, gas networks, hydrogen and CO2 infrastructure would enable significant system cost savings compared to electricity-centric pathways, while reducing overall flexibility needs, alleviating pressure on grid expansion. Beyond its role in system integration, renewable and low-carbon hydrogen should be recognised as a strategic contributor to EU energy security and resilience, diversifying energy supply, reducing import dependence, and enhancing security of supply across Member States with fundamentally different resource endowments and infrastructure constraints. The framework should therefore assess hydrogen policy not only on its carbon credentials but on its full contribution to supply resilience, ensuring alignment between the RED and the EU's broader energy security objectives.

Question 9: How important are the following measures for accelerating the uptake of renewables in industry after 2030?

• Improve EU financing solutions/instruments - Uptake of renewable hydrogen and derivatives in industry: 5 - Very important

Comment or specify other measures you would propose, if any:

• Energy-intensive industries operate under fundamentally different technological, operational and geographical conditions - from integrated ammonia facilities dependent on continuous hydrogen feedstock supply, to chemical complexes requiring high-temperature process heat, to refineries and steel plants with specific molecular feedstock needs - that electricity cannot directly substitute. Imposing uniform, electrification-centric compliance pathways on industries operating in MSs with different carbon-intensity grids, limited access to RES, or less developed H2 infrastructure, risks accelerating industrial relocation and carbon leakage instead does not accelerate decarbonization. A technology-open approach, anchored in lifecycle GHG performance rather than prescribed energy vectors, would allow each industrial installation to pursue the most cost-effective and technically feasible decarbonisation route available in its specific context, be it renewable or low-carbon H2, CCS.

Question 10 - Question 18: No response

Download the document to view the full response.