This article investigates the 2008 reform of the EU’s environmental state aid guidelines, with an eye to determining the degree of external pressure and lobbyism towards environmental state aid policies. What is found is a strikingly low level of external pressure on the policy-field, not least on the part of the private sector. In fact, EU environmental state aid policy is largely the making of a few Commission officials, without much external ‘interference’. The article discusses possible reasons for this, and asks whether state aid policy-making might be marked less by clear and established interests and utility maximising, and more by actors constrained by complexity and bounded rationality.