The EU’s TDI measures on renewable energy sources are clearly acting in opposition to the goals of the EU’s climate policy, which recognizes the potential in creating an open, competitive and demand-driven renewable energy sector.
At present, environmental aspects are not taken into account in the EU’s TDI investigations. This implies that the negative externalities of the imposition of TDI measures on renewable energy sources, i.e. the negative environmental impact, will technically be considered as not against the interests of the EU in TDI investigations. Accordingly, the measures will be imposed without considering the climate.
In the ‘modernization review’ of the EU’s TDI system, that is currently taking place, there may be the opportunity to include environmental aspects in the EU’s TDI investigations as part of the ‘Union interest test’ analysis.11 In addition, the requirement for the Directorate-General for Trade to consult internally with, for example, the Directorate-General for Climate Action, should be compulsory.12 It is vital that the EU has policies that are coherent in all fields.