Climate Lobbying Overview: EDF seems to take predominantly positive positions on climate change policy, with high engagement on a range of key policy streams, including particularly strong support for the EU Emissions Trading System (ETS). However, the company retains active membership of associations lobbying negatively on climate policy such as MEDEF and Eurogas.

Top-line Messaging on Climate Policy: EDF supported limiting temperature rise to 1.5°C on its corporate website in 2021, and in its 2019 Universal Registration Document stated support for the European Green Deal. In a presentation in 2020 the CEO stated that the goals of carbon neutrality in France and Europe are its “raison d’être.” EDF seems to support government regulation to respond to climate change: in feedback on the 2030 Climate Target Plan in 2020, EDF advocated that policies at European and national level become aligned with the climate neutrality objective. However, in its 2019 Universal Registration Document the company suggested that changes to climate policy could hinder the group’s development, and in its 2019 Sustainable Development Indicators report supported the need to maintain voluntary action on reducing emissions.

Engagement with Climate-Related Regulations: EDF appeared to strongly support the reforms made to the EU ETS under the EU’s Fit for 55 legislative climate package. In a LinkedIn post on the Fit for 55, the company reinforced the EU’s commitment to the EU ETS remaining the cornerstone of EU climate policy, and supported reforms such as increasing the linear reduction factor and strengthening the marginal stability reserve to increase the scheme’s effectiveness. In response to the 2030 Climate Target Plan in 2020, EDF supported the extension of the ETS to the maritime sector, and conditionally supported the extension to the road and buildings sectors in tandem with existing national policies under the Effort Sharing Regulation. The group stated support for a carbon price floor in the ETS in its 2019 Universal Registration Document. In a 2021 joint letter to EU policymakers, EDF stated support for the EU’s Carbon Border Adjustment Mechanism, advocating for the inclusion of the hydrogen sector, but did not specify a position on removal of existing carbon leakage protection for exposed sectors under the EU ETS.

In a 2021 consultation response, EDF advocated for the EU’s Energy Efficiency Directive to increase in ambition to align with other EU climate objectives. In a 2021 joint CEO letter, EDF stated support for the EU’s Renovation Wave energy efficiency initiative, advocating for greater efficiency improvements in buildings and an expansion of heat pumps. Alongside stating support for the revision of EU’s Renewable Energy Directive, the company appeared to advocate for greater recognition for nuclear and low-carbon hydrogen in its Fit for 55 statement on LinkedIn. Responding to the EU’s 2030 Climate Target Plan in 2020, EDF strongly supported an increasing the EU’s emission reduction target to 55% and supported emissions standards to reduce emissions in the transportation sector. In feedback on the Effort Sharing Regulation (ESR) Amendment Roadmap in 2020, EDF supported the continuation of national policies under the ESR alongside the ETS. The company has also advocated support for the EU’s Methane Strategy, to set measures in policy for tackling methane emissions from fossil fuels in a 2021 consultation response on the strategy.

Positioning on Energy Transition: EDF strongly supports the transition of the energy mix. In response to the roadmap on the revision of the Trans-European Energy Infrastructure (TEN-E) regulation, the company supported the electrification of buildings, transportation and industry, while advocating against the construction of fossil gas infrastructure. In an annual report on the 2019 European Affairs Division, EDF supported the decarbonization of the energy sector, and in feedback on the EU Climate Law the company advocated for the removal of fossil fuel subsidies. EDF appeared to support France’s RE 2020 energy efficiency legislation for buildings, which aims to phase out fossil gas an energy source for buildings, and advocated for decarbonization of housing, according to La Tribune in 2021. In its 2021 Fit for 55 LinkedIn response, the company strongly supported decarbonization and electrification of the economy, including transport and buildings, while advocating for EV infrastructure targets and an expansion of nuclear energy.

Industry Association Governance: EDF, in a 2019 annual report on the European Affairs Division published in 2020, disclosed a list of European trade associations of which it is a member, but did not describe their positions on climate policy, nor how EDF influences the groups. Despite its membership of WindEurope and SolarPower Europe, associations which have supported EU climate policy, EDF is also a member of Business Europe, Eurogas, and is an active member of MEDEF, who appear to aggressively oppose various strands of climate and energy policy. The company has not as of February 2021 published a report regarding misalignment of positions on climate policy.