About the Clean Industrial Deal State Aid Framework (CISAF)

30 June 2025

The European Commission published on June 25th its 𝗖𝗹𝗲𝗮𝗻 𝗜𝗻𝗱𝘂𝘀𝘁𝗿𝗶𝗮𝗹 𝗗𝗲𝗮𝗹 𝗦𝘁𝗮𝘁𝗲 𝗔𝗶𝗱 𝗙𝗿𝗮𝗺𝗲𝘄𝗼𝗿𝗸 (𝗖𝗜𝗦𝗔𝗙).

Building on the experience with the Temporary Crisis and Transition Framework (TCTF), CISAF applies as of June 25th 2025 and 𝗿𝗲𝗺𝗮𝗶𝗻𝘀 𝗶𝗻 𝗳𝗼𝗿𝗰𝗲 𝘂𝗻𝘁𝗶𝗹 𝗗𝗲𝗰𝗲𝗺𝗯𝗲𝗿 𝟯𝟭𝘀𝘁 𝟮𝟬𝟯𝟬.

CISAF aims to help Member States effectively and efficiently support clean energy deployment, industrial decarbonisation roll-out, and clean technology manufacturing.

Of relevance for the European battery value chain industrial players, we see measures:
– Accelerating the rollout of clean energy
– Providing support for electricity costs for energy-intensive users
– Facilitating industrial decarbonisation
– Developing manufacturing capacity in clean technologies
– De-risking private investments

Unfortunately, there remain issues that will limit the impact of the revised rules and that are putting at risk the development and strengthening of European domestic players along the battery value chain:
– CISAF falls short of allowing Member States to provide output-based production support (similar to the US Inflation Reduction Act) known to boost clean tech output and competitiveness
– CISAF allows support in the form of (semi-)equity, which will not deliver the same benefits and will lead to issues (lack of transparency, favouritism, push back of investors, market distortion, etc.)
– CISAF encourages Member States to apply European preference and resilience criteria in clean tech support, but it does not mandate local content requirements
– CISAF continues to rely on funding gap calculation and claw-back mechanisms that are known to limit the effectiveness of State Aid support

𝘼𝙡𝙡 𝙞𝙣 𝙖𝙡𝙡, 𝘾𝙄𝙎𝘼𝙁 𝙞𝙨 𝙖 𝙢𝙞𝙨𝙨𝙚𝙙 𝙤𝙥𝙥𝙤𝙧𝙩𝙪𝙣𝙞𝙩𝙮 𝙩𝙤 𝙗𝙪𝙞𝙡𝙙 𝙩𝙝𝙚 𝙢𝙤𝙨𝙩 𝙚𝙛𝙛𝙚𝙘𝙩𝙞𝙫𝙚 𝙖𝙣𝙙 𝙚𝙛𝙛𝙞𝙘𝙞𝙚𝙣𝙩 𝙎𝙩𝙖𝙩𝙚 𝘼𝙞𝙙 𝙁𝙧𝙖𝙢𝙚𝙬𝙤𝙧𝙠 𝙩𝙤 𝙝𝙚𝙡𝙥 𝙀𝙪𝙧𝙤𝙥𝙚𝙖𝙣 𝙙𝙤𝙢𝙚𝙨𝙩𝙞𝙘 𝙥𝙡𝙖𝙮𝙚𝙧𝙨 𝙖𝙡𝙤𝙣𝙜 𝙩𝙝𝙚 𝙗𝙖𝙩𝙩𝙚𝙧𝙮 𝙫𝙖𝙡𝙪𝙚 𝙘𝙝𝙖𝙞𝙣.

𝙒𝙚 𝙝𝙤𝙥𝙚 𝙩𝙝𝙖𝙩 𝙩𝙝𝙚 𝙀𝙪𝙧𝙤𝙥𝙚𝙖𝙣 𝘾𝙤𝙢𝙢𝙞𝙨𝙨𝙞𝙤𝙣 𝙬𝙞𝙡𝙡 𝙘𝙤𝙧𝙧𝙚𝙘𝙩 𝙩𝙝𝙞𝙨 𝙬𝙞𝙩𝙝 𝙥𝙤𝙡𝙞𝙘𝙞𝙚𝙨, 𝙞𝙣𝙨𝙩𝙧𝙪𝙢𝙚𝙣𝙩𝙨 𝙖𝙣𝙙 𝙞𝙣𝙞𝙩𝙞𝙖𝙩𝙞𝙫𝙚𝙨 𝙖𝙩 𝙩𝙝𝙚 𝙀𝙪𝙧𝙤𝙥𝙚𝙖𝙣 𝙡𝙚𝙫𝙚𝙡, 𝙨𝙪𝙘𝙝 𝙖𝙨 𝙩𝙝𝙚 “𝘽𝙖𝙩𝙩𝙚𝙧𝙮 𝘽𝙤𝙤𝙨𝙩𝙚𝙧” 𝙢𝙚𝙣𝙩𝙞𝙤𝙣𝙚𝙙 𝙞𝙣 𝙩𝙝𝙚 𝙄𝙣𝙙𝙪𝙨𝙩𝙧𝙞𝙖𝙡 𝘼𝙘𝙩𝙞𝙤𝙣 𝙋𝙡𝙖𝙣 𝙛𝙤𝙧 𝙩𝙝𝙚 𝙀𝙪𝙧𝙤𝙥𝙚𝙖𝙣 𝘼𝙪𝙩𝙤𝙢𝙤𝙩𝙞𝙫𝙚 𝙎𝙚𝙘𝙩𝙤𝙧.

𝙎𝙝𝙤𝙪𝙡𝙙 𝙩𝙝𝙞𝙨 𝙘𝙤𝙧𝙧𝙚𝙘𝙩𝙞𝙤𝙣 𝙝𝙖𝙫𝙚 𝙩𝙤 𝙬𝙖𝙞𝙩 𝙩𝙞𝙡𝙡 𝙩𝙝𝙚 𝙣𝙚𝙭𝙩 𝙈𝙁𝙁, 𝙩𝙝𝙚𝙣 𝙞𝙩 𝙘𝙤𝙪𝙡𝙙 𝙗𝙚 𝙩𝙤𝙤 𝙡𝙖𝙩𝙚 𝙩𝙤 𝙧𝙚𝙖𝙡𝙡𝙮 𝙢𝙖𝙠𝙚 𝙀𝙪𝙧𝙤𝙥𝙚 𝙩𝙝𝙚 𝙝𝙤𝙢𝙚 𝙤𝙛 𝘾𝙡𝙚𝙖𝙣 𝙏𝙚𝙘𝙝 𝙖𝙣𝙙 𝙩𝙤 𝙠𝙚𝙚𝙥 𝙀𝙪𝙧𝙤𝙥𝙚 𝙤𝙣 𝙩𝙝𝙚 𝙜𝙡𝙤𝙗𝙖𝙡 𝙗𝙖𝙩𝙩𝙚𝙧𝙮 𝙢𝙖𝙥!