ORLEN Position on the Post 2030 Renewable Energy Legal Framework (RED III revision)

ORLEN emphasises that future regulations should balance climate ambition with energy security, economic competitiveness, technological neutrality, and the diverse starting points of EU Member States.

Key challenges identified by ORLEN:

• The need to balance decarbonisation objectives with security of supply, particularly in fossil fuel-dependent economies.
• Significant disparities across Member States in terms of energy mix, infrastructure, and electrification levels.
• Constraints on electromobility linked to system-wide insufficient infrastructure and the carbon intensity of electricity.
• Risks related to feedstock availability for biofuels and growing dependence on imports.
• High costs and limited availability of renewable hydrogen (RFNBO) and its impact on industrial competitiveness.

ORLEN underlines that an effective energy transition requires:

• a technology-neutral approach, allowing all emission-reducing solutions, including biofuels, gaseous fuels, biomethane, and low-carbon hydrogen,
• realistic and gradual targets aligned with infrastructure readiness, feedstock availability, and market conditions,
• strengthening the role of biofuels and biomethane as key decarbonisation tools for hard-to-abate sectors,
• simplified RFNBO hydrogen rules, including more flexible regulatory requirements reflecting regional conditions,
• improved accounting for renewable electricity in transport, including guarantees of origin and private charging,
• support for industrial competitiveness, through flexible regulation and reduced burden on energy-intensive sectors,
• regulatory coherence and investment support, prioritising financial incentives alongside regulatory measures,
• alignment of RES targets with infrastructure deployment, reflecting the actual pace of implementation of regulations such as AFIR.

Files: