In response to the dual imperatives of transition and competitiveness of Europe’s production base, facilitating investment in the deployment of solutions for decarbonising industry is crucial.
In this context, AFEP welcomes the draft CISAF, which has many positive aspects:
- presumption of conformity principle of the aid,
- continuum with the TCTF for the aid dedicated to the manufacturing capacity of clean technologies,
- possibility to refer to the level of state aids allocated in countries outside the EU, to lead to a decision at EU level, although it could be further simplified,
- possibility to allow automatic decarbonisation aid for project budgets inferior to €200 million while respecting the aid intensity level,
- faculty to set up simplified tenders for industrial decarbonisation based on the criteria of avoided emissions,
- integration of aid dedicated to the derisking of private investments in favour of the energy and climate transition.
However, this draft also raises some reservations and points for improvement, as:
- it does not bring enough simplicity to trigger investments in the EU at the fast pace and at the level required;
- it does not fully respect the principle of technological neutrality;
- the positioning of the draft CISAF within all other still applicable State Aid Frameworks and the NZIA should be more consistent.