EU Energy Council Meeting

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

To: Energy and Environment Ministers of EU Member States

Cc: Commission President, Executive Vice-President for the Clean, Just and Competitive

Transition, and Commissioners for Energy and Housing, Environment, Water Resilience and a

Competitive Circular Economy, Climate, Net Zero and Clean Growth, and the Chair of the

European Parliament Committee on Industry, Research and Energy

Re: Input to the EU Energy Council Meeting, Brussels, 17 March 2025

Brussels, 14 March 2025

Dear Minister,

On behalf of the European Environmental Bureau, I am writing to share with you our views on the issues

on the agenda of the forthcoming EU Energy Council. We invite you to take our concerns into account

during the final official level preparations, as well as at the meeting itself. We have structured the letter

according to our understanding of the 17 March Council Agenda and outlined our vision of what is

needed to ensure the European Union achieves long-term resilience and decarbonisation of its energy

system, with secure and affordable energy for both industrial and domestic users.

Affordable Energy Action Plan

While we welcome several positive elements in the Affordable Energy Action Plan (AEAP) — notably, the

emphasis on accelerating renewable energy deployment and clean flexibility, such as the swift

implementation of the Renewable Energy Directive, as well as promising steps on energy efficiency,

including the proposed EU guarantee scheme and the Energy Savings Certification — we believe that a

much broader focus on energy savings is urgently needed. At the same time, investments in new LNG

infrastructure and nuclear assets are misguided: they risk becoming stranded assets or arriving too late

to provide meaningful relief in the current energy price crisis.

We are particularly concerned that, although the AEAP identifies electricity taxation as a key issue, only

few EU countries seem convinced to take effective steps in this direction. Without reform in this area,

we miss a critical opportunity to ease pressure on citizens’ energy bills and accelerate the electrification

of sectors like heating and cooling — sectors that are currently locking us into fossil fuel dependency.

A forward-looking approach would prioritise measures that not only deliver immediate relief but also

strengthen Europe’s long-term energy sovereignty and industrial competitiveness.

We call on the Energy Council to take decisive and forward-looking action to strengthen Europe’s

energy independence, resilience, and social cohesion:

▪ Swiftly implement the short-term measures recommended by the European Commission in

the AEAP to lower taxation on electricity and reduce the burden of network costs for both

industrial and residential energy users.

▪ Foster a coalition of the willing among Member States to lead a voluntary shift of taxes and

levies away from electricity used for heating, cooling, and mobility, and onto fossil energy

carriers such as gas and gasoline. This smart fiscal shift would send a clear and timely signal to

citizens and businesses to adopt clean, renewable solutions.

▪ Further to that, resume the negotiations on the Energy Taxation Directive and aim at

adopting the new text as soon as possible, taking into consideration the Commission’s

recommendations in the AEAP and the European Parliament’s ITRE Committee opinion.

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

▪ Make the full transposition and implementation of the RED an urgent priority to accelerate

renewable energy deployment and adopt strategic policy decisions to facilitate the

development of nature- and community-friendly renewables and grids in the EU’s rural areas.

▪ Integrate and strengthen energy sufficiency and efficiency policies across both industrial

and residential sectors. This will not only drive demand for clean, high-performance products,

but also support the growth of a robust, EU-based value chain for energy efficiency

technologies.

▪ Call on the EU Commission to explore the inclusion of a 0% VAT rate for heat pumps and

other clean heating and cooling technologies. This measure would directly stimulate demand

for EU-manufactured solutions and reinforce Europe’s technological sovereignty in this critical

sector.

▪ Request the Commission to put forward a legislative proposal to frontload part of the

ETS2 revenues to expand and strengthen the Social Climate Fund. This is essential to ensure a

just and rapid transition to EU-sourced, renewable energy.

EU’s Energy Security Architecture

The EU’s current energy security architecture remains overly reliant on fossil fuels, including LNG and

nuclear energy, which perpetuate dependency on unreliable partners and undermine the bloc’s long-

term resilience. While the Commission’s focus on storage and infrastructure is important, it fails to

address the root causes of energy insecurity: fossil fuel dependency and insufficient investment in

renewable energy, energy efficiency, and demand-side solutions. A truly secure energy system must

prioritize 100% renewable energy production, energy efficiency, and decentralized solutions that

empower citizens and communities. The EU must phase out fossil fuels and nuclear energy, which are

not only costly and risky but also incompatible with the bloc’s climate and security goals.

We call upon the Energy Council to:

▪ Accelerate the phase-out of fossil fuels, including LNG, by rejecting new long-term contracts

and infrastructure investments that lock in dependency. The EU must prioritize renewable

energy and energy efficiency as the cornerstone of its energy security strategy.

▪ Reject nuclear energy as a solution to energy security, given its reliance on uranium imports

from fragile third countries and service contracts with Rosatom. Instead, invest in renewables,

energy savings, and flexibility to replace nuclear capacity and ensure a secure, decarbonized

energy system.

▪ Promote decentralized energy systems, including energy communities, building-integrated

solar, and heat pumps, to enhance resilience and reduce dependency on centralized fossil fuel

and nuclear infrastructure.

▪ Enhance system flexibility through demand-side management, decentralized energy

systems, and cross-border electricity interconnections, reducing reliance on centralized fossil

fuel-based generation.

▪ Strengthen energy efficiency and demand-side measures as the first line of defence

against price shocks and geopolitical volatility. This includes setting binding energy efficiency

targets and expanding demand management systems across the EU.

▪ Establish a European Energy Agency to improve monitoring, transparency, and coordination

of energy security measures, ensuring that the transition to a renewable-based system is both

efficient and equitable.

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

Energy situation in Ukraine

The ongoing war in Ukraine has severely damaged the country’s energy infrastructure, leaving millions

without reliable access to electricity. As Ukraine works to rebuild its energy system, it is crucial to

prioritize renewable energy and decentralized solutions that enhance resilience, reduce

dependency on fossil fuels, and align with the rapidly evolving EU’s electricity grid.

Initiatives like EEB Member Ecoclub’s Solar Aid for Ukraine demonstrate the potential of community-

driven renewable energy projects to provide both immediate relief and long-term security of supply,

even in the most challenging conditions. The EU must seize this opportunity to support Ukraine in

building a modern, sustainable, and interconnected energy system that serves as a model for post-

crisis recovery.

We call upon the Energy Council to:

▪ Support Ukraine’s transition to a renewable energy system by providing financial and

technical assistance for decentralized solar, wind, and energy storage projects to facilitate the

integration of renewable generation into Ukraine’s grid.

▪ Ensure that EU funding for Ukraine’s energy sector is directed toward renewable energy and

energy efficiency projects, avoiding investments in fossil fuel or nuclear assets as these would

prove too costly, projects would come too late, and they would not improve the resilience of an

already strained national grid.

▪ Facilitate knowledge exchange between EU and Ukrainian stakeholders to accelerate the

deployment of renewable energy solutions

▪ Accelerate the interconnection of Ukraine’s electricity grid with the EU, including fast-

tracking the synchronization of Ukraine’s grid with ENTSO-E and expanding cross-border

transmission capacity. This will enable Ukraine and the EU to exchange surplus renewable

generation, mutually enhancing energy security and providing energy users with affordable

energy.

We hope that the above insights and recommendations help you in your Environment Council

deliberation and decisions and wider responsibilities. We also hope that our recommendations for the

next legislative cycle in The European Pact for the Future, signed by 320 organisations and 1085

individuals, including a range of MEPs, are useful for you. Further details of our visions can be found in

our recently launched Action Plan for the Pact, and the Industrial Blueprint

We remain available to discuss with you these practical visions and look forward to working together

to help create an agenda of hope.

Yours sincerely,

Patrick ten Brink

Secretary General, European Environmental Bureau (EEB)

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

To: Energy and Environment Ministers of EU Member States

Cc: Commission President, Executive Vice-President for the Clean, Just and Competitive

Transition, and Commissioners for Energy and Housing, Environment, Water Resilience and a

Competitive Circular Economy, Climate, Net Zero and Clean Growth, and the Chair of the

European Parliament Committee on Industry, Research and Energy

Re: Input to the EU Energy Council Meeting, Brussels, 17 March 2025

Brussels, 14 March 2025

Dear Minister,

On behalf of the European Environmental Bureau, I am writing to share with you our views on the issues

on the agenda of the forthcoming EU Energy Council. We invite you to take our concerns into account

during the final official level preparations, as well as at the meeting itself. We have structured the letter

according to our understanding of the 17 March Council Agenda and outlined our vision of what is

needed to ensure the European Union achieves long-term resilience and decarbonisation of its energy

system, with secure and affordable energy for both industrial and domestic users.

Affordable Energy Action Plan

While we welcome several positive elements in the Affordable Energy Action Plan (AEAP) — notably, the

emphasis on accelerating renewable energy deployment and clean flexibility, such as the swift

implementation of the Renewable Energy Directive, as well as promising steps on energy efficiency,

including the proposed EU guarantee scheme and the Energy Savings Certification — we believe that a

much broader focus on energy savings is urgently needed. At the same time, investments in new LNG

infrastructure and nuclear assets are misguided: they risk becoming stranded assets or arriving too late

to provide meaningful relief in the current energy price crisis.

We are particularly concerned that, although the AEAP identifies electricity taxation as a key issue, only

few EU countries seem convinced to take effective steps in this direction. Without reform in this area,

we miss a critical opportunity to ease pressure on citizens’ energy bills and accelerate the electrification

of sectors like heating and cooling — sectors that are currently locking us into fossil fuel dependency.

A forward-looking approach would prioritise measures that not only deliver immediate relief but also

strengthen Europe’s long-term energy sovereignty and industrial competitiveness.

We call on the Energy Council to take decisive and forward-looking action to strengthen Europe’s

energy independence, resilience, and social cohesion:

▪ Swiftly implement the short-term measures recommended by the European Commission in

the AEAP to lower taxation on electricity and reduce the burden of network costs for both

industrial and residential energy users.

▪ Foster a coalition of the willing among Member States to lead a voluntary shift of taxes and

levies away from electricity used for heating, cooling, and mobility, and onto fossil energy

carriers such as gas and gasoline. This smart fiscal shift would send a clear and timely signal to

citizens and businesses to adopt clean, renewable solutions.

▪ Further to that, resume the negotiations on the Energy Taxation Directive and aim at

adopting the new text as soon as possible, taking into consideration the Commission’s

recommendations in the AEAP and the European Parliament’s ITRE Committee opinion.

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

▪ Make the full transposition and implementation of the RED an urgent priority to accelerate

renewable energy deployment and adopt strategic policy decisions to facilitate the

development of nature- and community-friendly renewables and grids in the EU’s rural areas.

▪ Integrate and strengthen energy sufficiency and efficiency policies across both industrial

and residential sectors. This will not only drive demand for clean, high-performance products,

but also support the growth of a robust, EU-based value chain for energy efficiency

technologies.

▪ Call on the EU Commission to explore the inclusion of a 0% VAT rate for heat pumps and

other clean heating and cooling technologies. This measure would directly stimulate demand

for EU-manufactured solutions and reinforce Europe’s technological sovereignty in this critical

sector.

▪ Request the Commission to put forward a legislative proposal to frontload part of the

ETS2 revenues to expand and strengthen the Social Climate Fund. This is essential to ensure a

just and rapid transition to EU-sourced, renewable energy.

EU’s Energy Security Architecture

The EU’s current energy security architecture remains overly reliant on fossil fuels, including LNG and

nuclear energy, which perpetuate dependency on unreliable partners and undermine the bloc’s long-

term resilience. While the Commission’s focus on storage and infrastructure is important, it fails to

address the root causes of energy insecurity: fossil fuel dependency and insufficient investment in

renewable energy, energy efficiency, and demand-side solutions. A truly secure energy system must

prioritize 100% renewable energy production, energy efficiency, and decentralized solutions that

empower citizens and communities. The EU must phase out fossil fuels and nuclear energy, which are

not only costly and risky but also incompatible with the bloc’s climate and security goals.

We call upon the Energy Council to:

▪ Accelerate the phase-out of fossil fuels, including LNG, by rejecting new long-term contracts

and infrastructure investments that lock in dependency. The EU must prioritize renewable

energy and energy efficiency as the cornerstone of its energy security strategy.

▪ Reject nuclear energy as a solution to energy security, given its reliance on uranium imports

from fragile third countries and service contracts with Rosatom. Instead, invest in renewables,

energy savings, and flexibility to replace nuclear capacity and ensure a secure, decarbonized

energy system.

▪ Promote decentralized energy systems, including energy communities, building-integrated

solar, and heat pumps, to enhance resilience and reduce dependency on centralized fossil fuel

and nuclear infrastructure.

▪ Enhance system flexibility through demand-side management, decentralized energy

systems, and cross-border electricity interconnections, reducing reliance on centralized fossil

fuel-based generation.

▪ Strengthen energy efficiency and demand-side measures as the first line of defence

against price shocks and geopolitical volatility. This includes setting binding energy efficiency

targets and expanding demand management systems across the EU.

▪ Establish a European Energy Agency to improve monitoring, transparency, and coordination

of energy security measures, ensuring that the transition to a renewable-based system is both

efficient and equitable.

European Environmental Bureau

Rue des Deux Églises 14-16, 1000 Brussels, Belgium ● ☏ +32 228 91090 ● [email protected] ● www.eeb.org

Association internationale sans but lucratif (AISBL) ● EC register for interest representatives ID number: 06798511314-27

BCE ID number: 0415.814.848 ● RPM Tribunal de l’entreprise francophone de Bruxelles

Energy situation in Ukraine

The ongoing war in Ukraine has severely damaged the country’s energy infrastructure, leaving millions

without reliable access to electricity. As Ukraine works to rebuild its energy system, it is crucial to

prioritize renewable energy and decentralized solutions that enhance resilience, reduce

dependency on fossil fuels, and align with the rapidly evolving EU’s electricity grid.

Initiatives like EEB Member Ecoclub’s Solar Aid for Ukraine demonstrate the potential of community-

driven renewable energy projects to provide both immediate relief and long-term security of supply,

even in the most challenging conditions. The EU must seize this opportunity to support Ukraine in

building a modern, sustainable, and interconnected energy system that serves as a model for post-

crisis recovery.

We call upon the Energy Council to:

▪ Support Ukraine’s transition to a renewable energy system by providing financial and

technical assistance for decentralized solar, wind, and energy storage projects to facilitate the

integration of renewable generation into Ukraine’s grid.

▪ Ensure that EU funding for Ukraine’s energy sector is directed toward renewable energy and

energy efficiency projects, avoiding investments in fossil fuel or nuclear assets as these would

prove too costly, projects would come too late, and they would not improve the resilience of an

already strained national grid.

▪ Facilitate knowledge exchange between EU and Ukrainian stakeholders to accelerate the

deployment of renewable energy solutions

▪ Accelerate the interconnection of Ukraine’s electricity grid with the EU, including fast-

tracking the synchronization of Ukraine’s grid with ENTSO-E and expanding cross-border

transmission capacity. This will enable Ukraine and the EU to exchange surplus renewable

generation, mutually enhancing energy security and providing energy users with affordable

energy.

We hope that the above insights and recommendations help you in your Environment Council

deliberation and decisions and wider responsibilities. We also hope that our recommendations for the

next legislative cycle in The European Pact for the Future, signed by 320 organisations and 1085

individuals, including a range of MEPs, are useful for you. Further details of our visions can be found in

our recently launched Action Plan for the Pact, and the Industrial Blueprint

We remain available to discuss with you these practical visions and look forward to working together

to help create an agenda of hope.

Yours sincerely,

Patrick ten Brink

Secretary General, European Environmental Bureau (EEB)