Climate Policy Engagement Analysis
Climate Policy Engagement Overview: The Spanish Confederation of Business Organizations (CEOE) is actively engaged on climate change policy in the EU, taking mostly unsupportive positions on key regulations and emphasizing negative impacts on industry from climate policy, despite some consistent support for energy efficiency policy for buildings.
Top-line Messaging on Climate Policy: The Spanish Confederation of Business Organizations (CEOE) appears to broadly support top-line climate policy, yet emphasizes concern around its impacts on international competitiveness. In an April 2024 position paper on the EU 2024-29 policy cycle, the association stated support for climate policy and an EU Industrial Deal, without specifying what this would entail, and emphasized the risks of unilateral action and carbon leakage from climate policy which it advocated should be technologically neutral. In the same document, the President stated that the EU should place competitiveness and economic growth at the center of policies in the EU’s 2024-29 Policy Agenda. In a February 2025 LinkedIn post the President advocated to align the EU’s decarbonization policies with industrial competitiveness, without clearly linking this to the EU’s climate ambitions. The association appears to support the UN Paris Agreement, praising COP29’s outcomes in a December 2024 LinkedIn post.
Engagement with Climate-Related Policy: The Spanish Confederation of Business Organizations (CEOE) appears to take mostly negative positions on key climate policies in the EU. In an April 2024 position paper, the association did not support the reform of the EU Emissions Trading System (EU ETS), advocating against the proposed phaseout of the free allocation of emissions allowances before the EU Carbon Border Adjustment Mechanism (CBAM) is ‘proved effective.’ In the same position paper CEOE suggested that free allowances should remain for imports and exports alongside the implementation of a CBAM, a position which is misaligned with the EU Commission. A February 2025 press release disclosed that the association met with Spanish policymakers to discuss the CBAM, proposing to expand the scope of the policy while also emphasizing the potential negative impacts and administrative burden on companies. CEOE actively engaged in opposition to the EU Packaging and Packaging Waste Regulation (PPWR) in 2023-24, for example, in October 2023 the association reported in a press release that it met with EU policymakers to advocate for a review of the proposal while emphasizing that targets should be ‘realistic.’
However, CEOE seems to broadly support energy efficiency policy for buildings, supporting the Renovation Wave strategy in an April 2024 position paper. In a January 2025 position paper the association supported permitting reform to speed up the deployment of renewable energy.
Positioning on Energy Transition: The Spanish Confederation of Business Organizations (CEOE) seems to support the transition of the energy mix with some exceptions. In a July 2024 position paper, the association supported an industrial strategy which includes promoting low-carbon and renewable energy, along with decarbonization infrastructure and technologies, but did not clearly detail what this includes. CEOE supported scaling up the electrification of transportation in a meeting with the EU Commission in January 2025, however, it advocated for a technology neutral approach to decarbonizing the transport sector in an April 2024 position paper. In the same position paper it stated support for carbon capture and utilization (CCU) technologies, but did not state a clear position on the long-term role for fossil fuels and the conditions under which CCU should apply. In a November 2023 joint statement the President Antonio Garamendi supported new exploration and production of fossil gas alongside renewable, low-carbon and nuclear energy capacity.