The following comments were submitted on the 20th of November 2025 to the European Commission’s public consultation on the Electrification Action Plan. This initiative aims to accelerate cost-effective, system-friendly electrification across transport, industry, and buildings in the EU.

Introduction

Climate Leadership Coalition (CLC) welcomes the opportunity to contribute to the European Commission’s Electrification Action Plan. Electrification is essential not only for reducing greenhouse gas emissions but also for reinforcing Europe’s resilience and competitiveness. At its best, electrification lays the foundation for economic renewal and sustainable growth across the continent.

Ambitious targets for emission reductions and electrification growth set out the framework for the transformation of the electricity system and to provide investors with the necessary confidence that these long‑lived investments require. In this respect, the 90% climate target for 2040 and the 32% electrification target set in the Affordable Energy Action Plan frame the policy landscape in a commendable way.

Although 70% of EU electricity was already decarbonised by 2024, electricity share of final energy consumption has stagnated at around 23%. This share must increase significantly to meet the EU’s climate goals. Eurelectric estimates that achieving these targets will require an
electrification rate of 51% by 2040 and 62% by 2050.

Raising this share is also vital for safeguarding competitiveness. The global clean technology market is expected to expand from roughly $700 billion today to about $2 trillion by 2035. Building a strong domestic market will enhance the ability of European companies to compete successfully in these rapidly growing markets.

Targeted measures are therefore needed to accelerate progress and remove barriers. Electrification is not simply a technical solution; However, we must strive to strengthen each member state’s inherent competitive advantages. Only this will enable the EU to achieve its emission targets while at the same time enhancing its resilience and competitiveness in global markets.

Key messages:

• Electrification is essential for Europe’s future – not only to cut emissions but also to strengthen resilience, competitiveness, and enable long‑term economic
  renewal.
• Climate targets and target for electrification provide the framework – electrification must be anchored in EU’s climate and energy objectives, providing security for long term investments.
• Strong demand creation is critical – industrial electrification requires certainty of demand for low‑carbon products and favourable tax treatment. Public procurement should promote the demand for low‑ carbon materials. Similarly, tax treatment should favour electrification over the use of fossil fuels.
• Infrastructure and flexibility must be anticipated – transmission and distribution grids, firm and flexible electricity generation capacity, charging networks, and storage solutions require sufficiently early‑ stage planning and investments
• Clean baseload power is indispensable – it ensures stability, security of supply, and competitiveness in a system increasingly reliant on variable renewables. Adequate clean baseload capacity must be secured.
• The Action Plan should explicitly commit to a market-based approach. Clear and reliable price signals are essential to attract investments in clean generation, flexibility, and storage.

Synchronised development of the electricity system

The electricity system is an integrated whole, where demand, supply, and infrastructure must evolve in a timely and coordinated manner. Industrial electrification projects will not materialize without certainty that demand for low‑carbon products is sufficient, that affordable clean electricity is available in adequate quantities, and that transmission networks enable its utilization. The Electrification Action Plan must therefore promote planning and regulation that support this synchronization.

Rapid reinforcement and digitalization of transmission and distribution networks are critical to enable synchronised development. The Action Plan together with the upcoming European Grids Package should accelerate permitting for grid projects and promote advanced digital solutions, including AI-based optimization and demand-side flexibility, to ensure efficient system integration across Member States.

Europe has considerable potential for rapid increase of electrification with proven, mature technologies, for example, on electrification of industrial process heat. Ambitious targets for emission reductions and electrification growth set the framework for the transformation of the electricity system and to provide investors with the necessary confidence that these long‑lived investments require. In this respect, the 90% climate target for 2040 and the 32% electrification target set in the Affordable Energy Action Plan frame the policy landscape in a commendable way.

Lead markets, renewable electricity-based hydrocarbons and adjustment of taxation to support demand for clean electricity

Industrial electrification must be supported through predictable frameworks that safeguard competitiveness and encourage investment. Without a strong demand outlook, change will not happen. Adequate demand for low carbon materials like steel chemicals and concrete is a necessary factor for investments to materialize. Creating a lead market to secure demand for industrial low‑carbon products is essential.

Public procurement, product standards, and labelling should reward materials and components with verified low‑carbon footprints — starting with steel, aluminium, chemicals, batteries and extending to electricity-based fuels and intermediates where relevant.

Such a lead market not only promotes demand for low‑carbon products but also sends a signal to strategically important industrial sectors to invest in European production, thereby creating the necessary economic added value for the continent.

Recognising the strategic importance of renewable-electricity-based hydrocarbons within the Action Plan ensures that Europe is not limited to a single pathway but instead deploys both direct and indirect electrification in a balanced, coherent, and economically efficient manner.

For consumers, the Action Plan should promote smart solutions and demand response programs, empowering households and businesses to actively participate in the energy transition.

Fossil Fuel Phase‑Out

The plan should also actively promote the phase‑out of fossil energy to avoid fossil lock‑in as the current capital stock of fossil energy production ages, steering towards alternatives that utilize clean electricity.

In this respect, a phased approach in which support for new fossil solutions is or their deployment prohibited is, in our view, justified. A good example of this is the ban on supporting fossil heating solutions under the Energy Performance of Buildings Directive.

The phase-out strategy should be aligned with strong market signals to avoid unintended distortions. In several European countries, electricity remains disproportionately taxed, making electricity use uncompetitive against the fossil fuels, especially gas. Electricity taxation should promote the transition from the use of fossil fuels (especially gas) to the use of electricity.

While setting clear timelines for fossil fuel exit, the Action Plan must ensure that flexibility and baseload solutions are developed through competitive mechanisms rather than subsidies.

Infrastructure Readiness

The success of electrification requires that the capacity of the electricity grid—both transmission and distribution networks—and other necessary infrastructure, such as charging networks and storage solutions, are anticipated and implemented in time.

Infrastructure readiness requires not only physical reinforcement but also digital modernization. The Action Plan should include measures to accelerate permitting and incentivize smart grid technologies that enable real-time system management and integration of distributed resources.

Building infrastructure can take several years, which is why proactive planning and long‑term investment programmes are indispensable.

Flexibility and Baseload Power

One of the key features of the future electricity system is flexibility, which arises from a combination of demand response, onsite storage, and thermal storage. Strengthening flexibility can also, to some extent, serve as an alternative to building new networks.

Flexibility resources—such as storage, demand-side response, and interconnections—should be prioritized through market-based signals. The Action Plan must avoid over-reliance on capacity mechanisms and instead strengthen the electricity market design to reward flexibility and secure adequate baseload through competitive investment frameworks.

At the same time, clean baseload power remains the cornerstone of the electricity system. It ensures security of supply, stability, and competitiveness in a situation where the share of renewable energy is increasing, and production varies according to weather conditions. Therefore, the Electrification Action Plan should secure also adequate clean baseload power.

Conclusions

The Electrification Action Plan is a decisive opportunity to accelerate Europe’s energy transition. By anchoring the plan in climate objectives, creating strong demand for low‑carbon products, phasing out fossil fuels, anticipating infrastructure needs, strengthening flexibility, and securing clean baseload power, the EU can ensure that electrification delivers both climate neutrality and a competitive, resilient European economy.

The Electrification Action Plan must combine ambition with market-based implementation. By aligning infrastructure, digitalization, and consumer engagement with strong price signals, and the strengthening of member states’ competitive advantages, Europe can deliver a cost-effective and resilient pathway to climate neutrality.

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