Brussels, 17 June 2011 | Europex welcomes the opportunity to take part in the CEER consultation on the “Draft Advice on the introduction of a Europe-wide Energy Wholesale Trading Passport”.
We welcome the efforts taken by CEER proposing an Energy Wholesale Trading Passport and we generally agree with the passport’s envisaged goals: improving security standards of energy markets (e.g. against VAT-fraud), harmonizing admission requirements and cut of entry barriers to national markets.
On the contrary we would like to point out that the possibilities of such a passport should not be overestimated. In so far we see the need that by defining the passport requirements in more detail it is clearly evaluated what can realistically be achieved and what might just create additional administrative burdens.
Please find the whole consultation response attached.