Bellona Europa supports the Clean Industrial State Aid Framework (CISAF) accompanying the Clean
Industrial Deal (CID) as a fundamental measure to close the financial gap needed to decarbonise industries and enhance the competitiveness of European industry.

The CISAF establishes simpler compatibility conditions than those in other State aid guidelines. While this
approach is justifiable by the urgency of tackling climate change, it is crucial that all the provisions included in the Framework are carefully evaluated and clarified. This is essential to ensure that aid effectively mitigates climate change and supports industrial decarbonisation, while preventing funds from being directed toward solutions that could harm the climate or the environment. We support the inclusion of specific sections in the Framework addressing the acceleration of the rollout of renewable energy, the deployment of industrial decarbonisation, increasing manufacturing capacity in clean technologies, and reducing risks of private investments in the three categories. Our contribution under this consultation focuses on the first two sections.

Despite being a limited resource, renewable electricity is the most efficient and rapid way to reduce carbon emissions from industrial processes. Its efficient deployment and use must therefore be prioritised to ensure maximum impact and strategically allocated to avoid wasteful usage. Additionally, their full potential can only be realised through the development of a modernised grid infrastructure , flexibility and adequate storage systems. Without these, renewable energy deployment will face bottlenecks that could slow down industrial decarbonisation efforts. Bellona welcomes the fact that these aspects have been considered in the Framework.

Bellona also supports the provisions on industrial decarbonisation and stresses the importance of ensuring that they are well-defined to avoid unintended negative consequences. Specifically, we recommend clarifications regarding thresholds, clear differentiation between Carbon Capture and Storage (CCS) and Carbon Capture and Utilisation (CCU), the explicit integration of the additionality principle for renewable hydrogen, and enhanced clarity to improve the Framework’s long-term durability while preventing the lock-in of fossil-based projects.

Finally, stronger safeguards are needed around the conditions Member States have to follow when
designing State aid measures. In the draft Framework, Member States are merely “encouraged” to include
additional “social, environmental or resilience policy objectives” when designing aid schemes (point 15).
Given the critical role of State aid projects in delivering social and climate benefits beyond greenhouse gas (GHG) reduction and energy efficiency, these additional objectives should be mandatory.
These safeguards are even more critical since the “Do No Significant Harm” (DNSH) principle is absent from three out of the four sections of the Framework. In the draft published for consultation, Member States are required to ensure compliance with the DNSH principle only for renewable energy projects, and even then, the language remains vague. We recommend that the Commission requires compliance with this principle for all aid under the Framework, with stronger language to provide legal certainty. This would be consistent with the approach in other State aid guidelines such as the CEEAG, which this Framework is called to complement. It is essential to ensure that projects under the Framework do not undermine the EU’s broader environmental objectives or inadvertently lead to investments in fossil infrastructure, which could result in long-term lock-in effects. Strengthening the DNSH principle will ensure that all State aid measures contribute to sustainable industrial transformation in line with the EU’s climate goals.

Read or download our full response in the PDF.