Recommendations for the General Block Exemption Regulation (GBER)
On 23 April 2026, Zero Emissions Platform (ZEP) responded to the European Commission’s public consultation on the draft for a new General Block Exemption Regulation (GBER). ZEP welcomes the European Commission’s initiative to revise the GBER with the aim of simplifying it, bringing it into line with social, market and technological developments, and streamlining it by addressing inconsistencies and improving readability.
About the response
The GBER forms part of a larger set of EU state aid rules, including:
- The General Block Exemption Regulation (GBER) allows Member States to grant certain types of State aid without prior Commission approval, provided certain conditions are met and thresholds not exceeded. It is a fast and streamlined procedure that supports smaller projects.
- The Climate, Environmental Protection and Energy Aid Guidelines (CEEAG) provide the framework for larger and more complex aid measures. The Commission assesses CCEAG requests on a case-by-case basis, and Member States are often required to carry out a public consultation.
- The Clean Industrial State Aid Framework (CISAF) is a temporary framework designed to accelerate support for clean industrial investments and decarbonisation in response to the current economic and geopolitical conditions. ZEP provided inputs on the draft Communication establishing the CISAF last year.
- Important Projects of Common European Interest (IPCEIs) enable coordinated, large-scale cross-border projects of strategic importance, with more flexible aid rules to support innovation and first-of-a-kind deployments.
ZEP’s recommendations
ZEP’s analysis and recommendations focus on legal clarifications needed to ensure that the GBER can effectively support industrial carbon management (ICM) projects. The eligibility of CDR technologies (DACCS and BioCCS), in particular, remains uncertain under the proposed text. ZEP’s feedback also addresses ICM definitions, the scope of eligible CO2 infrastructure, R&D provisions, links with other EU instruments (e.g. InvestEU, Horizon Europe, NZIA), aid cumulation rules, and aid intensity thresholds.
More specifically, ZEP’s comments relate to the following legal provisions:
Chapter I – Common Provisions
- Article 2 – Definitions of terms that first appear in Chapter I and Section 6 of Chapter III
- Article 3 – Conditions for exemption
- Article 8 – Incentive effect
- Article 9 – Cumulation
Chapter III – Section 4: Aid for research and development and innovation
- Article 32 – Aid for research and development projects
- Article 33 – Aid for projects awarded a Seal of Excellence quality label
- Article 35 – Aid for co-funded research and development projects, feasibility studies or research infrastructure or testing and experimentation infrastructure
- Article 38 – Investment aid for research infrastructure and testing and experimentation infrastructure
Chapter III – Section 6: Aid for environmental protection
- Article 51 – Investment aid for climate protection
- Article 66 – Aid for energy infrastructure
Chapter III – Section 10: Aid involved in financial instruments and budgetary guarantees supported by the InvestEU Fund and the InvestEU Instrument of the ECF
- Article 81 – Scope and common provisions
- Article 82 – Conditions for aid involved in financial instruments and budgetary guarantees supported by the InvestEU Fund and the ECF InvestEU
Authors
Aymeric Amand is Policy and Research Director at ZEP. He advises EU institutions and national authorities on industrial carbon management – covering the technical, economic, and regulatory dimensions of CO₂ capture, transport, storage, and utilisation, as well as of carbon dioxide removal (CDR) methods. He oversees ZEP’s analytical and policy outputs and represents ZEP in technical forums, including Commission Expert Groups. His expertise spans EU climate and industrial policy, carbon pricing, CDR governance, and EU funding instruments.
Aymeric also ensures feedback from industry, academia and civil society is reflected fairly in EU policy design. He helps build fair, workable compromises by weighing options against scientific evidence, project experience, regulatory requirements, and public-acceptance considerations. He promotes knowledge sharing and contributes to defining European R&I priorities for industrial carbon management. Trained in climate science, geography, and EU political science, he applies data analysis and GIS tools to quantify options and inform policy choices. He works in English and French.