Business Associations: Improvements to EU Regulations on Customer Investments

In a letter to Frank Wetzel, Parliamentary State Secretary at the Federal Ministry for Economic Affairs and Energy (BMWE), the business associations expressly welcome the fact that, at Germany’s initiative, the issue of customer-owned systems has been incorporated into the Council’s negotiating position. At the same time, however, they warn that the Council’s current position would have significant negative consequences for numerous companies. According to the Alliance, many existing customer-owned generation facilities would in the future be classified as regular grids—resulting in significant additional costs, extensive bureaucratic requirements, and legal uncertainty. The associations are particularly critical of the proposed rigid thresholds. For example, a customer-owned facility would retain its privileged status only if at least 90 percent of the energy generated is consumed on-site and no more than 20 customers are supplied. However, these limits are frequently exceeded—particularly at industrial sites, in collaborations with third-party companies, or in the shared use of energy infrastructure—even though such models are expressly desired for the efficient use of grid connections and the expansion of a climate-neutral energy supply.

Customer-Owned Systems: Associations Warn Against Rigid EU Thresholds

The associations also reject the Council’s alternative proposal, which would limit customer installations to purely residential neighborhoods with fewer than 100 households. Modern neighborhood and commercial concepts thrive precisely on the combination of different uses. Rigid restrictions would unnecessarily complicate innovative energy supply concepts and slow down the energy transition at the local level. From the associations’ perspective, the European Parliament’s position offers a significantly more balanced solution. It avoids the rigid restrictions of the Council’s proposal and would largely preserve the existing legal framework. The associations therefore call on the German federal government to clearly advocate for the Parliament’s position in the ongoing trilogue negotiations. The ZVO will closely monitor the further legislative process together with the alliance of associations. For many companies in the surface technology sector, high-performance and economically viable customer-owned facilities are a key component of a secure, efficient, and competitive energy supply.