USA Loosen CO₂ Emission Controls, EU Strengthens Climate Tools, Poland Accelerates in Renewables

The Environmental Protection Agency (EPA) published on February 12, 2026^[2] a final regulation that repeals the so-called Endangerment Finding from 2009^[1] for greenhouse gases emitted by vehicles. The document challenges the interpretation that the Clean Air Act grants EPA authority^[3] to regulate CO₂ emissions from new cars and trucks without explicit Congressional mandate. The rule applies solely to greenhouse gases and does not change standards^[22] for pollutants such as NOx or particulate matter. It will come into effect within 60 days of publication in the Federal Register, and lawsuits have already been announced against it by coalitions of states, NGOs, and parts of the automotive industry, including California, known for the strictest emission standards. The decision increases legal uncertainty around the long-term decarbonization of transport in the USA and may weaken pressure to reduce emissions in global automotive supply chains, which are also significant for Poland.

USA Withdraw Emission Regulation Basis

In the European Union, a team of economists from the European Central Bank (ECB) sharply criticized the project^[4] of simplified sustainable development reporting standards, the Omnibus ESRS, prepared by the European Commission and EFRAG. According to the bank, the reduction in indicators risks significantly worsening the quality^[6] and comparability of ESG data, vital for assessing climate risks in the financial system. The ECB warns of systemic costs^[16] in the form of poorer risk valuation and misallocation of capital, while some investors and NGOs demand maintaining more detailed requirements. For Polish companies, this implies risks of frequent ESRS adjustments and the need for rapid updating of reporting processes regardless of the compromise direction.

Tensions Surrounding EU ESG Reporting

Simultaneously, the European Banking Authority (EBA) is consulting on changes^[7] to the systemic risk buffer (SyRB) guidelines to allow targeted application to exposures with climate-related risks. As foreseen in CRD VI, this could allow national macroprudential authorities^[11] to impose additional capital requirements using more detailed NACE sector classifications and geographic divisions. ECB and EBA studies indicate that calibrating the climate SyRB could mobilize around 51 billion euros^[12] of additional capital in the euro area. The consultations will last until April 30, 2026^[8], and potential buffer implementation in Poland may increase capital costs for coal mining, high-emission energy, and parts of the real estate market.

New EU Financial and Industrial Instruments

The European Commission is also finalizing the Industrial Accelerator Act^[14] with publication planned for February 25–26, 2026. The act is to introduce minimum thresholds for ‘EU-made’ production^[17] and low-emission requirements for key technologies such as renewables, batteries, electric vehicles, cables, and hydrogen when used in public procurement or subsidies. For electric vehicle orders, the draft includes a requirement for assembly in the Union^[18] and at least 70% of component value (excluding batteries) made in the EU, and for subsidized aluminum at least 25% of low-carbon-footprint products made in Europe. For concrete, the threshold will be 5%. The regulation will also cover foreign investments exceeding 100 million euros in strategic sectors, especially when the investor’s country controls at least 40% of global production capacities in the technology. For Poland, this could strengthen producers of cables, steel constructions, and turbine or battery components but also increase costs on some infrastructure projects.

Philippines and Poland Speed Up Renewable Energy

In the Philippines, the Department of Energy (DOE) announced a 10‑year Green Energy Auction program^[19] designed to deliver at least 25 GW of new renewable capacity by 2035. The mechanism includes annual auctions for wind,^[29] ground-mounted and floating photovoltaic installations, PV systems with storage, biomass, geothermal and hydro, based on 20-year contracts with guaranteed prices. In the round concluded in November 2025, GEA-4 allocated already 10.2 GW of capacity^[19], including 4.1 GW ground PV, 2.3 GW floating PV, 2.2 GW wind, and 1 GW storage. The program aims to help achieve renewable energy shares of 35%^[23] in the mix by 2030 and 50% by 2040, reduce fossil fuel imports, and attract foreign investors. For companies from Poland and the EU, this is a chance for EPC contracts, supplying turbines, panels, storage, and auction advisory.

Rising Physical and Raw Material Risks

In Poland, the Ministry of Climate and Environment announced^[42] that by the end of 2025, renewable energy sources accounted for 50.04% of installed capacity^[32] in the national system, and the share of renewables in annual electricity production exceeded 30% for the first time. Solar and onshore wind dominate, and investment scale attracts financing from foreign banks. Norddeutsche Landesbank (NORD/LB) granted a loan of 32.5 million euros^[45] for a portfolio of 32 photovoltaic farms totaling about 59 MWp, developed by Sun Investment Group. Projects are expected to produce about 59 GWh^[43] annually, meeting the demand of about 17,000 households, partly supported by 15-year contracts for difference and partly market models and corporate PPAs. Meanwhile, the Ranger Road Fire burned around 145,000 acres^[30] and forced evacuations, illustrating growing physical climate risks insurers and investors must take seriously. On a global supply chain level, urban mining is gaining importance: according to the service recycling of rare earth metals is becoming a pillar of raw material security^[40], while a report by the European Court of Auditors reveals^[48] that for 7 of 26 key strategic materials in the EU recycling rates are as low as 1–5%, and 10 materials have no recycling at all.

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