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nucleareurope responds to public consultation on Clean Industrial Deal State aid framework (CISAF)

On 24 April 2025, nucleareurope submitted its response to the European Commission’s public consultation on the New State aid Framework accompanying the Clean Industrial Deal Communication (“CISAF”). The proposed State aid framework has been introduced to simplify State aid rules to accelerate the roll-out of clean energy sources, deploy industrial decarbonisation and ensure sufficient capacity of clean tech manufacturing in Europe.

In its response to the consultation, nucleareurope insists on the nuclear sector’s contributions to the energy transition, highlights the importance of accelerating the State aid approval process for nuclear projects and raises key concerns regarding the exclusion of low-carbon hydrogen and the nuclear value chain in the current project.

Specifically, nucleareurope stresses that the nuclear sector will be delivering significant investments in the coming years: current National Energy and Climate Plans and publicly available information point towards an installed nuclear capacity that could reach 143 GW by 2050. In this regard, the new State aid framework should facilitate the timely assessment of nuclear projects, in its response to the consultation, nucleareurope details concrete solutions to facilitate this timely assessment. These solutions include the treatment of all nuclear State aid notifications as priorities, as is the case for renewables; the possibility for some nuclear projects to be considered as presumptively meeting some State aid conditions; and the recognition of nuclear’s contributions to the energy transition. The response further notes that the existing legal framework provides a sufficiently robust basis for such an approach for nuclear projects.

On the topic of hydrogen production, nucleareurope calls for all forms of low-carbon and decarbonised hydrogen to be eligible for support, noting that the CISAF disproportionately prioritises renewable hydrogen, potentially undermining the principle of technology neutrality. In line with the Net-Zero Industry Act, nucleareurope also calls for all clean manufacturing capacities and for the nuclear supply chain to be supported by the CISAF.

Finally, nucleareurope’s response outlines the contributions of the European nuclear sector to the energy transition, and insists on the need for the CISAF to explicitly list nuclear as a key technology to support industrial sectors’ decarbonisation efforts.

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