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annul pursuant to Article 263 TFEU the Commission Decision (EU) 2025/1479 of 22 May 2025 (the ‘Contested Decision’) (1); and or

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annul pursuant to Article 263 TFEU the Contested Decision insofar as it lists EMPN and MEEG as obligated entities subject to the contribution obligations as set out in Annex 1; and/or

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annul pursuant to Article 263 TFEU the Contested Decision insofar as it lists EMPN as an obligated entity subject to the contribution obligations as set out in Annex 1; and/or

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annul pursuant to Article 263 TFEU the Contested Decision insofar as it lists MEEG as an obligated entity subject to the contribution obligations as set out in Annex 1; and/or

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declare Article 23 of Regulation (EU) 2024/1735 of 13 June 2024 (the Net Zero Industry Act or NZIA) (2) and/or the Delegated Regulation (EU) 2025/1477 of 21 May 2025 (the Threshold Act) (3) inapplicable, in whole or in part, pursuant to Article 277 TFEU;

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order the Commission to pay EMPN and MEEG’s costs pursuant to Article 134 of the Rules of Procedure of the General Court, including the costs relating to any intervening parties.

1.

First plea in law, alleging that Article 23 NZIA was adopted in violation of the principles of conferral and subsidiarity, and in any event lacks a valid legal basis under Article 114 TFEU.

2.

Second plea in law, alleging that Article 23 NZIA is inconsistent with the EU Charter of Fundamental Rights (the Charter) and general principles of EU law, in particular the principle of proportionality of Article 5(4) TEU, and the Contested Decision is unlawful insofar as it is adopted pursuant to Article 23 NZIA.

3.

Third plea in law, alleging that the Contested Decision is unlawful because it is inconsistent with the Charter and general principles of EU law.

4.

Fourth plea in law, alleging that the Threshold Act is unlawful because it is inconsistent with the Charter and general principles of EU law.