We welcome the Commission’s efforts to initiate a structured process with the Network of Competent Authorities to develop guidance and recommendations that support a pragmatic and harmonised implementation across the Union. These efforts must now be translated, as a matter of urgency, into clear and detailed deliverables from both the Commission and Member States that businesses can rely on with legal certainty.
Our letter underlines the need to define and endorse the key elements required to provide clarity on compliance guidance. It also calls for clarification of the conditions under which security of supply related penalty suspensions can be invoked, together with a broader interpretation of penalty exemptions, including appropriate grandfathering. In addition, it stresses the importance of bringing forward the review of the Regulation, currently planned for 2028, and launching an assessment of its shortcomings as early as 2026.
