KEF, Alm.del - 2024-25 - Bilag 387: Orientering om svar på Europa-Kommissionens høring af meddelelse om investeringsplan for bæredygtig transport, fra klima-, energi- og forsyningsministeren

Klima-, Energi- og Forsyningsudvalget 2024-25
KEF Alm.del Bilag 387
Offentligt

1 September 2025

Response of the Danish Government to the

Commission’s call for evidence

- Sustainable

Transport Investment Plan (STIP)

Introduction

On 7 August 2025, the Commission initiated a call for evidence to

gather input for an upcoming Sustainable Transport Investment

Plan (STIP). The purpose of the plan is to provide a strategic

framework for the green transition of all modes of transport focus-

ing specifically on the aviation and maritime sectors.

For road transport, electrification with battery electric vehicles is

well under way due to technological advancement and supported

especially by the CO

-standards for light and heavy-duty vehicles

as well as Member States’

initiatives.

However, in aviation and

maritime transport, direct electrification with the current techno-

logical readiness level is in many cases unable to meet the high en-

ergy density requirements. Instead, renewable and low carbon

fuels are needed and it is important that the production and uptake

of these fuels is ramped up quickly, globally and in the EU. The

production and availability of green fuels in the EU is not only im-

portant

to deliver on the EU’s climate ambitions, it

can also help

reduce air pollution if taking into consideration in the development

of the fuels. In addition, production of renewable and low carbon

fuels improves the EU’s

energy security.

The Danish Government agrees with the Commission that a guid-

ing framework on how to support the production of renewable and

low carbon fuels for the aviation and maritime sectors is indeed

necessary and helpful in furthering and accelerating the transition.

Such a framework can address distinct investment barriers associ-

ated with each mode of transport and also increase the competi-

KEF, Alm.del - 2024-25 - Bilag 387: Orientering om svar på Europa-Kommissionens høring af meddelelse om investeringsplan for bæredygtig transport, fra klima-, energi- og forsyningsministeren

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tiveness of the clean tech manufacturing sector in line with the rec-

ommendations of the Draghi-report. Currently, we see e-fuel man-

ufacturing projects being delayed or not reaching final investment

decision. This has mainly been due to the inability of these projects

to secure financing due to high perceived risk of investment in e-

fuel manufacturing. This is despite of the ReFuelEU Aviation and

FuelEU Maritime regulations requiring the use of e-fuels already

from 2030.

However, dynamics in the fuel market and policy uncertainty in-

creases the perceived risk of investing. Producers of e-fuels need

offtake agreement for 10 to 15 years in order to obtain financing.

Airlines and ship owners on the other hand operate on so thin mar-

gins that they cannot risk locking in a higher price on e-fuels than

their competitors for 10 years and are therefore only willing to en-

gage in short offtake agreements.

In addition, market participants rely on the stability of the man-

dates in the ReFuelEU Aviation and FuelEU Maritime regulations.

If the market doubts whether the mandates will remain or if fines

will not be imposed as stipulated in the regulations, then invest-

ment in e-fuels manufacturing becomes risky. Therefore, new

mechanisms are needed to initiate the market for production of

green fuels as the pricing challenge seems unlikely to be solved by

market power alone.

Reiterate and reduce uncertainty in existing regulation

The Danish Government encourages the Commission to reiterate

its commitment to the existing mandates in the ReFuelEU Aviation

and FuelEU Maritime regulation. Together with a guiding frame-

work of de-risking investment in production of renewable and low

carbon fuels this could bolster market trust and incentivise more

investment in these types of fuels.

Unfortunately, there has been uncertainty regarding the right of

Member States to introduce national mandates for the aviation

sector when transposing the revised Renewable Energy Directive

(III). This has resulted in a heterogeneous landscape of aviation

mandates across the EU. Denmark therefore encourages the Com-

mission to provide clear and consistent guidance on the extent to

which Member States may introduce mandates and support the

uptake of sustainable fuels in the aviation sector. In general, Den-

mark advocates for a uniform and simple regulatory landscape

across sectors.

KEF, Alm.del - 2024-25 - Bilag 387: Orientering om svar på Europa-Kommissionens høring af meddelelse om investeringsplan for bæredygtig transport, fra klima-, energi- og forsyningsministeren

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The Danish Government suggests that the Commission ensure co-

herence between EU regulation and future international measures,

including a potential fuel standard adopted at the International

Maritime Organisation (IMO). It should also address the interac-

tion between EU regulation, including FuelEU Maritime and the

EU ETS, and the potential fuel standard under IMO.

Introduce de-risking mechanisms

The Danish Government agrees with the Commission that de-risk-

ing investments in renewable and low carbon fuels manufacturing

is the appropriate tool. Neither the EU-budget nor the Member

States can accomplish the task of bridging the entire cost difference

between fossil fuels and green fuels, which alone for e-SAF could

reach several billion euro per year. Private capital needs to be mo-

bilised and the transitions ought in general to be driven by the

market and privately financed.

The role of policy is thus to create a framework where the risk of

investment in production facilities is as low as possible. The Danish

Government welcomes the Commission’s focus on different mecha-

nisms that can reduce the risk, such as, but not limited to, double-

sided auctions or contract for difference. Financing new initiatives

will be difficult and we therefore support the Commission’s

effort to

analyse how current funding mechanisms can be used.

Continue the work on simplifying the state-aid rules

In assessing novel policy mechanisms, if these are to be imple-

mented by the Member States’

it is important to give the Member

States’ the best

and most simple possible tools to do so. This in-

volves making sure the state aid rules allow for speedy approval of

these new policy mechanisms. We therefore support the Commis-

sion’s

ongoing work to simplify and clarify the state aid rules for

example with the newly adopted CISAF, and the focus in this

framework on de risking private investments related to clean in-

dustrial deal objectives. This work on simplification could also look

into whether support for renewable and low carbon fuels and/or

battery electric or hydrogen powered aviation could usefully be in-

cluded in the General Block Exemption Regulation (GBER) making

state aid tools easier to implement.

It is also important that the new policy tools are aligned with other

regulations in this field. For example, Denmark has, to date, been

unable to obtain a clear answer from the Commission on whether

e-SAF subject to state aid can count towards the mandates set out

in ReFuelEU Aviation. Such uncertainty regarding state aid rules

KEF, Alm.del - 2024-25 - Bilag 387: Orientering om svar på Europa-Kommissionens høring af meddelelse om investeringsplan for bæredygtig transport, fra klima-, energi- og forsyningsministeren

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hinders the ability of Member States to efficiently support the scal-

ing up of domestic e-SAF production.

Coordination is important

The Danish Government recognizes that a coordinated EU effort is

beneficial. The aviation and maritime sectors are by default inter-

national. A coordinated framework in the EU for supporting re-

newable and low carbon fuels can help secure alignment with the

mandates of the ReFuelEU Aviation and FuelEU Maritime regula-

tions as well as limit the fragmentation of regulatory requirements

that investors need to comply with in different Member States.

The Danish Government thanks the Commission for the oppor-

tunity to contribute input and looks forward to assessing the solu-

tions outlined in the Sustainable Transport Investment Plan.