Position Paper
07.05.2025

Eurogas response to the Clean Industrial Deal State Aid Framework

The Commission is preparing the groundwork for a Clean Industrial Deal State Aid Framework (CISAF). This was announced as part of the Clean Industrial Deal in February and published for consultation in March.

Eurogas recently submitted its response to the consultation on the CISAF draft.

It is welcome that the document aims to adopt a technology-neutral approach, especially when multiple solutions can contribute to achieving net-zero. Renewable and low-carbon technologies should all have equal access to state aid support.

However, the current focus does not reflect the full range of viable decarbonisation pathways. Renewable and low-carbon gases, as well as CCUS (Carbon Capture, Utilisation and Storage), must be recognised for their role in reducing emissions.

These technologies are still in the early stages of market development, it is essential to provide them with sufficient support to help launch the market, while also carefully avoiding potential market distortions or cumulation risks.

To ensure coherence with other EU policies, the definitions, thresholds and criteria used in the state aid framework should align with those found in existing EU legislation such as REDIII, NZIA or the EED.

Investors require clear, stable, and long-term rules to make decisions about complex and capital/operational-intensive decarbonisation projects. We recommend that the state aid framework provide support aligned with the EU’s 2050 climate neutrality objective and with the principle of technology neutrality.

Read our responses to the CISAF consultation below.