Response to the European Commission’s consultation on the draft Clean Industrial Deal State Aid Framework (CISAF)

How can we make Europe's Clean Industrial Deal truly deliver for industry, climate, and competitiveness?

We have submitted our response to the European Commission’s public consultation on the draft Clean Industrial Deal State Aid Framework (CISAF). The CISAF is a key initiative aimed at supporting the EU’s industrial decarbonisation efforts, while enhancing Europe’s competitiveness and energy resilience. 

In our contribution we stress the importance of ensuring that the framework remains technology-neutral, clear, and predictable, allowing all effective decarbonisation solutions — including low-carbon hydrogen, carbon capture and storage (CCS), and flexible gas-based technologies — to compete fairly based on their greenhouse gas (GHG) emission reduction potential. 

We also call for greater coherence between CISAF and other major EU funding instruments, flexible timelines that reflect the realities of industrial project development, and a more comprehensive approach to supporting the full CCUS value chain. Without these adjustments, there is a risk of creating unnecessary barriers to investment and innovation at a time when rapid action is needed. 

By refining the CISAF along these lines, Europe can ensure that its industries have the tools they need to decarbonise efficiently and competitively, while maintaining energy security and technological leadership. 

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