Energy Efficiency Directive

Solar Heat Europe welcomes the European Commission’s proposal for the recast of the Energy Efficiency Directive (EED) and supports the European Commission goal to align it with the Union's climate objectives. Energy efficiency offers multiple benefits such as greenhouse gas emission reductions, lower dependency on energy imports, job creation, alleviating energy poverty and improved health.

The German National Committee for Monument Protection (DNK) – a network of actors and stakeholders in monument preservation and archaeology in Germany – welcomes the proposal for the recast and amendment of the Energy Efficiency Directive (EED) as important contributions to the objective of reducing greenhouse gas emissions in the EU by at least 55% by 2030 compared to 1990 levels and limiting the temperature…

FarmTech Society (FTS) supports the revision of the Energy Efficiency Directive (EED) aligned with the goals of the Green Deal and in response to current climate and energy emergencies. FarmTech Society (FTS) is an international non-profit industry association for the Controlled Environment Agriculture (CEA) sector, which is a practice in intensification of yields while upholding ecological principles.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the „Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on energy efficiency (recast)“. Please find detailed comments in the Attachment.

To make the transition towards a more energy efficient economy successful, we propose the following adjustments to the Fit for 55 package and the proposal for a Recast of the Energy Efficiency Directive. 1. The Fit for 55 package should not contain conflicting or overlapping obligations, such as the requirements for reducing energy consumption versus the reduction of emissions.

From ECODES (Foundation for Ecology and Development), we would like to thank the European Commission for the opportunity to participate in the evaluation and review process of the Energy Efficiency Directive, seeking to achieve an ambitious document in order to achieve at least the goals set out in the Paris Agreement. Please find attached the document containing comments to try to achieve these objectives.

Filed in Spanish · English published by the European Commission

Veolia welcomes the European Commission’s proposal to revise the Energy Efficiency Directive (EED). Together with other proposed initiatives within the Fit-for-55 Package, the new EED can contribute to achieve the greenhouse gas emissions reduction target of 55% by 2030, while consolidating the EU’s role as a global leader in energy efficiency and the overall energy transition.

OVHcloud is delighted to provide further comments to the Proposal of the European Commission for a Recast of the Energy Efficiency Directive (EED). The EED is a critical piece of legislation to materialize the goals of the European Green Deal.

Dear Commission, Please find Energy Norway's feedback on the revised EED proposal attached. Energy Norway is an association that represents the whole electricity chain in Norway. In other words, our members include companies producing, transporting and trading electricity. Our members produce 130-140 TWh annually, which is around 95 percent of all power production in Norway.

Energy efficiency improvement is a key lever of the European transition towards a neutral economy. However, measures should be coherent and guided by cost-efficiency so to do not jeopardize energy supply and consumers bills.

Hydrogen has seen an unprecedented development from an innovative niche technology to a systemic element in the EU’s efforts to transition to a climate neutral society in 2050. In the future energy system, renewable energy producers will be faced with an important choice: how to deliver renewable energy most cost-effectively and whether to deliver it as electricity or as hydrogen.

UFE, the association representing the French Electricity Industry, welcomes the European Commission’s proposal to revise the Directive on energy efficiency (EED). But given the climate emergency, we believe that some improvements are still needed. Please find enclosed UFE's reaction and recommendations on the proposal of revision of the EED.

ENTSO-E welcomes the EC proposal for a revision of the Energy Efficiency Directive (EED), as part of the ‘Fit for 55’ package and the opportunity to provide feedback on the proposal. ENTSO-E indeed considers energy efficiency as a key driver to reach the EU climate objectives, including carbon neutrality by 2050.

IFIEC Europe, representing energy intensive industries (EIIs), welcomes the opportunity to provide feedback on the proposal related to the revision of the Energy Efficiency Directive (EED). IFIEC is concerned by the potential impact of the revision of the EED on industry competitiveness. 1.

The European Heating Industry, EHI, welcomes the Commission’s proposal on the Energy Efficiency Directive. The EED recast, with its proposed higher and binding EU energy efficiency target, offers an opportunity to scale up efforts in energy efficiency, including in heating. In this sense, we argue that the EED should include a 6% yearly target for the replacement of old and inefficient heating equipment.

We would like to thank the European Commission for the opportunity to provide comments on the Energy Efficiency Directive proposal ('recast EED'). In summary, we generally find that the recast EED is strengthening the existing framework to achieve the new EU climate ambition of cutting carbon emissions by at least 55% by 2030 and the ultimate climate neutrality objective by 2050.

UNIDEN, representing the French industrial energy consumers, welcomes the revision of the Energy Efficiency Directive (EED) in order to align the text with the 2030 55% GHG reduction objective of the European Union. The clear recognition of the significant efforts achieved by the industry over the last decade is most welcome.

Bioenergy Association of Finland supports the aims of the EU Green Deal and the objective of reducing net greenhouse gas emissions by 55 % by 2030. It is quite clear that achieving this objective also requires a significant improvement in energy efficiency around Europe.

The EU ETS Directive would require mandatory energy audits to ETS installations based on the current Article 8(4) of Directive 2012/27/EU. Not implementing the recommendations proposed by the auditors could lead to a “penalty” i.e., the reduction of 25% of free allocation quotas.

Statkraft AS refers to the European Commission’s consultation on the Energy Efficiency Directive (EED) (2018/2002). We believe that energy efficiency is a crucial part of the solution. For the revision of the directive we emphasise the following points: • Energy efficiency targets and measures must not hinder the increased use of clean electricity which is important to substitute fossil fuel use and decarbonize our…

Gas Infrastructure Europe (GIE), representing almost 70 European companies operating storage facilities, transmission pipelines and LNG terminals, welcomes the European Commission’s initiative to revise the EU Energy Efficiency Directive and adapt it to the EU’s target of reducing greenhouse gas emissions by 55% by 2030, compared to 1990.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The success of the energy transition requires a cost-effective decarbonisation pathway. To achieve this, the Energy Efficiency Directive must enable the identification and delivery of energy efficiency across the entire energy value chain. Eurogas is firmly committed to ensuring an energy transition that is both cost-effective and just.

The EC recently published its “fit for 55” package, including a review of the energy efficiency directive (EED). Essenscia supports the climate transition and considers the reduction of greenhouse gases, while remaining competitive in a global context, key. The sector finds energy efficiency crucial element in the transition and the revision of the EED could help industry in its efforts to reduce GHG emissions.

E3G welcomes the update of the Energy Efficiency Directive (EED) to align it with the Climate Law and the need to limit global warming to 1.5˚C. While E3G is generally supportive of the direction of the proposal, the directive needs to be improved to meet European climate targets and ambition. The draft recast contains useful provisions that need to be safeguarded, and others that need strengthening.

Schneider Electric, recognised by Corporate Knights as the most sustainable company in the world, welcome the ambition of the Directive with the increase of both the energy efficiency target and the annual energy savings target. However, addressing the structural shortcomings of the current Directive is a paramount to bolster energy efficiency actions.

EPEE, representing the refrigeration, air-conditioning and heat pump sector in Europe, is delighted to provide feedback to the European Commission's proposal for a revised Energy Efficiency Directive (EED). Please find our input in the enclosed position paper.

Reganosa, as Transmission System Operator, is committed to play an active role in the energy transition process framed within the European Green Deal, the National Energy and Climate Plan 2021-2030 (NECP) and the EU Energy System Integration and Hydrogen strategies.

RTE would like to draw the attention of the European Commission to the issue of network losses addressed in Article 25 of the proposal. Electricity losses in energy systems are inevitable, mainly due to the laws of physics (technical losses).

Build Europe is glad to inform the work of the European Commission to promote energy efficiency across the EU and support its ambition – expressed in the Energy Efficiency Directive - to achieve greenhouse gas reductions of 55% in a responsible way by 2030. Developers and housebuilders are ready to make efforts to improve the energy efficiency of new buildings.

Comments on the recast of the EED from the Agency for Palaces and Culture in Denmark are attached. It is of great importance that the EU member states have the possibility to exempt the protected buildings from comprehensive energy adaptations if the adaptations decrease the cultural, environmental, or architectural values of the buildings.

VGMS welcomes the Commission’s proposals for the Energy Efficiency Directive (EED). The objective of achieving net-zero greenhouse gas emissions is important. Equally importantly, it is also possible for companies to go there.

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Aruba is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), Aruba supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

- Need to include cultural considerations. Consumer choice and human behaviour are important elements of realising energy efficiency goals. Because culture is embedded in dominant consumption patterns, culture-based strategies can give insights and solutions that make an essential contribution to reducing the consumption of energy. - Need to promote energy efficiency in the historic built environment.

GENERAL COMMENTS: • PGNiG highlights that some Member States due to national circumstances (e.g. Poland) still rely heavily on coal. PGNiG is actively involved in transformation of district heating by replacing coal plants with natural gas-fired high efficiency cogeneration units.

Article 4 It is reasonable to raise the ambition and requirements for end-use and primary energy at European level. We also find it useful that a cap on energy consumption in the Union becomes clearer. We are reluctant to link the intensity target to Gross Domestic Product. Each Member State should identify appropriate indicators for different sectors.

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CISPE is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), CISPE supports the revised EED and has attached its feedback, jointly developed with the members of the Pact. Please consult the attached document for a full overview of our contribution.

Public procurement — Fair competition! The draft recast of the Energy Efficiency Directive, presented as part of the Fit-for-55 package, provides for extensive changes in the area of public procurement in Article 7.

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Strengthening of the Energy Efficiency Directive DUH is calling for the adoption of a binding energy efficiency target of at least 45 % in the year 2030 (compared to the EU Reference Scenario 2007 or of at least 20 % in 2030 compared to the EU reference scenario 2020). This will help to achieve the 1.5°C target of the Paris Agreement, improve the energy security of the EU, create jobs, and reduce pollution.

The Coalition for Energy Savings is thankful for the opportunity to provide feedback on the Energy Efficiency Directive (EED) recast proposal. We believe that the EED recast is a core element of the Fit for 55 package as energy savings are the prerequisite to reach Europe’s 2030 energy and climate targets in an affordable way.

AFLRA acknowledges the need for increased energy efficiency and energy savings as necessary components to reach EU climate targets for 2030 and carbon neutrality 2050. AFLRA supports ambitious climate and energy policy and action involving local and regional authorities (LRAs) as forerunners, when accompanied by appropriate frameworks, measures and financial resources.

Synergy thanks for the possibility of submitting a consultation response to the European Commission’s “Fit for 55” Climate Package and specifically the Energy Efficiency Directive of 14 July 2021. The European Commission’s proposal for a new Energy Efficiency Directive will oblige Member States to significantly increase their efforts, which is positive.

Filed in Danish · English published by the European Commission

GAZ-SYSTEM welcomes the opportunity to express its views in the public consultation on the proposal for a directive on energy efficiency (hereafter EED). Energy efficiency is a key tool to achieve emission reduction targets and use more effective technologies.

Social, cooperative and public housing providers are strong supporters of the Renovation Wave and the decarbonization of social, cooperative and public housing is under way, as proven by the improved energy efficiency and reduction of C02 emitted by m2 . The proposed article 6 of the revised EED would include housing provided by public entities in the scope of the obligation to renovate 3% of the total floor area.

Elia Group welcomes the review of the Energy Efficiency Directive (“EED”) to support the climate and decarbonisation ambitions of the EU. Acting in the interest of society, and in line with its tasks of developing a secure, reliable and efficient transmission system with due regard to the environment, Elia Group supports a further step towards greater sustainability and optimization of existing energy resources and…

Summary of CurrENT's submission. See full submission attached: -- Europe needs dramatically increased power system capability and flexibility in the coming decades to accommodate renewables. This must be provided for by increased interconnection, innovative grid infrastructure and far better utilisation of existing, planned and future electricity grids, e.g. by deploying new grid enhancing technology.

Enedis, France’s main electric DSO, believes energy efficiency first (EE1st) principle must be combined with a GHG emission reduction priority. It shall also adopt a holistic vision aiming at wide environmental, economic and societal benefits. Enedis already works towards more energy-saving practices.

EuropeOn is the voice of electrical contractors, the 1.8 million professionals implementing the energy transition by installing and maintaining electric technologies such as building automation and control systems and advising consumers on the most efficient clean energy technologies.

EuroWindoor welcomes the adoption of the European Commission proposal to revise the Energy Efficiency Directive on 16 July 2021 and appreciates the opportunity to provide feedback to feed into the legislative debate. The EuroWindoor feedback is summarised as follows: In the upcoming negotiations, we call on the EU Institutions to: i.

Deutsche Telekom AG (DT) welcomes the opportunity to offer feedback to the European Commission’s (EC) proposal for a revised Energy Efficiency Directive (EED). With the attached document, we aim to contribute our experiences and insights to the further development of the provisions of the proposal that specifically relate to the energy efficiency of data centres.

The EU sugar industry has reduced its CO2 emissions by 51 % compared to 1990. The industry is on track to meet the objectives of the Fit for 55 package for 2030. And we recognise the importance of transitioning to climate neutrality by 2050. In the sugar manufacturing sector, the heat and electricity required to produce beet sugar is generally provided by high efficiency Combined Heat and Power (CHP) systems.

The EU Primary Food Processors Association (PFP) welcomes the Commission’s EED revision proposal as well as the ambitious GHG emission reduction targets set by the EU Climate law. Our sectors are committed to further reducing emissions into the future. The following requests are essential to ensure that the revised EED supports the decarbonisation of PFP sectors. 1. EXEMPT CAMPAIGN PLANTS FROM OBLIGATIONS UNDER ART.

Simplex Software & Internet Services Ltd is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), Simplex Software & Internet Services Ltd supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

ICLEI Europe recognises that energy efficiency is a key area for urgent action in the EU, to reach 2030 greenhouse gas emission reduction targets and achieve a climate-neutral Europe by 2050. Whilst supporting the proposed revisions to the EED overall, ICLEI counsels that amendments to the text are made to highlight the central role subnational governments play in delivering on-the-ground energy efficiency gains…

The passive house Institute is an independent research institution which has been working on highly energy-efficient construction and renovation for more than 25 years. We welcome the proposal for a recast of the EU Parliament and Council Directive on the EU Energy Efficiency Directive (EED).

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Europe’s airlines are fully committed to decarbonize air transport and are accelerating their efforts to make Europe the world’s first carbon-neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, and through mitigation.

Italgas welcomes the adoption of the Fit455 package, both in spirit and in substance and the decision to modify the EED by including the “Energy Efficiency First” Principle. We think though that the current proposal can be amended by incorporating a broader view of efficiency and considering a more comprehensive approach, in which: - efficiency gains at one point of the energy system does not result in greater…

Air Liquide very much welcomes the European Commission’s proposals to make the EU's climate, energy, land use, transport and taxation policies fit for reducing net greenhouse gas emissions by at least 55% by 2030, compared to 1990 levels. We firmly believe that all available emission reduction technologies need to be supported in order to reach the EU Green Deal targets.

Increased energy efficiency in relation to the purpose and benefits of its use is an important part of the work to reduce climate impact, a more efficient energy system, and increase the competitiveness of industry. The Energy Efficiency Directive should be designed to facilitate such development.

The Energy Efficiency Directive (EED) is a key pillar for EU’s efforts to accelerate decarbonisation, support industrial competitiveness, address rising energy costs and deliver a more sustainable society on the path to net-zero emissions by 2050.

Dear Sir/Madam, APQuímica, the Portuguese Petrochemical and Refination Association, presents in the attached document its comments and contributions as part of the “Fit for 55” legislative package, and in particular with regard to the proposed revision of the Energy Efficiency Directive (EED).

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The Swedish Association of Local Authorities and Regions (SALAR) supports increasing energy efficiency as a necessary component to reach EU climate targets for 2030 and carbon neutrality 2050. We recall the necessity to respect the subsidiarity principle and avoid burdensome and inflexible legislation.

EurEau welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach. Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy.

EDF welcomes the revision of the EED, which is an opportunity to ensure that it is fully aligned with Green Deal objectives and coherent with the EU ETS, the RED, the EPBD, the ETD, the Energy System Integration Strategy, and the Renovation Wave strategy. Nevertheless, these legislative works have to be done with a focus on affordability, taking into account the most cost effective way to reach the climate targets.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation.

Finnish Energy welcomes the opportunity to comment on the Fit for 55 climate package. We strongly support the EU’s climate targets for 2030 and 2050, and we are also committed to Finland’s carbon neutrality target for 2035. The energy and climate policy initiatives published by the Commission in July set the Europe to the right path towards climate neutrality. Please find our comments here attached.

The YESO Technical and Business Partnership, ATEDY, welcomes the “Goal 55” package for Europe to reduce its GHG emissions by at least 55 % by 2030 and strongly believes that low carbon and light construction solutions, such as plaster-based products, are key to achieving the ecological transition.

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Fluxys welcomes the opportunity provided by the Commission through this feedback period for stakeholders to provide views on the Commission’s adaption regarding Energy Efficiency Directive (EED) back in the summer of 2021 with the aim of feeding into the legislative debate at the European Parliament and Council.

The European Copper Institute (ECI) supports the EU’s climate ambitions for 2030 and 2050 and welcomes the proposed recast of the Energy Efficiency Directive (EED). Copper is a key material for energy efficiency in all sectors and contributes significantly to the clean energy transition as a sustainable raw material that is essential to decarbonise the economy.

— For the IFR, reducing greenhouse gas emissions should be the first and main objective of climate policy. Improving energy efficiency is one of the ways to contribute to this. Therefore, the VBO calls for the energy efficiency target to be formulated as a genuine indicative target.

Filed in Dutch · English published by the European Commission

VELUX A/S welcomes the opportunity to provide feedback on the proposed revision of the Energy Efficiency Directive (EED). To become climate neutral by 2050 and meet the 2030 CO2 reduction target, we need an ambitious EED revision with a binding energy efficiency target of at least 40%, at both EU and Member State level and a clear commitment to and implementation of the Energy Efficiency First (EE1) Principle.

Turboden S.p.A. welcomes the initiative of the European Commission on the Energy Efficiency Directive Recast. We strongly support the policy recommendations aiming at the promotion of energy efficiency and the efficient use of the sources. By the next decade, the EU must halve its greenhouse gas emissions and slash its fossil fuel dependency.

Cepi represents the European pulp and paper industry and gathers, through its 18 member countries, some 895 pulp, paper and board mills across Europe directly, employing more than 180,000 people. Our sector is investing at a rate of more than €5 billion per annum, increasing our production volumes while simultaneously reducing our carbon footprint.

E.ON welcomes the revision of the Energy Efficiency Directive as a key pillar to reach our 2030 goals. Mobilizing private investments to accelerate the energy transition is essential. In this regard, the predominantly market-oriented approach in this directive seems suitable. In E.ON’s opinion, the efficiency targets are in line with the overall 55% GHG emissions reduction target by 2030.

The European Energy Research Alliance (EERA) welcomes the European Commission’s proposal to review the EU Energy Efficiency Directive (EED). While generally in agreement with the approach followed, EERA wishes nevertheless to bring to the EU decision makers’ attention a set of elements for further consideration. The first main point relates to the missing out on the concept of energy sufficiency.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030, for which energy efficiency policies and continuous energy efficiency improvements in operations are key.

EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of private energy service companies (ESCOs) and their national associations in 12 EU Member States (MS). Our members represent over 130.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of…

The Confederation of Industry of the Czech Republic (SP CR) considers energy efficiency to be an important part of the gradual decarbonisation of the EU. Companies have invested considerable funds in energy efficiency and plan to invest additional funds. However SP CR is afraid that setting too ambitious energy efficiency targets will lead to cost inefficiency.

FNADE the French association for waste management and environmental services companies welcomes the Proposal of the European Commission to Review the Directive 2012/27/EU on energy efficiency aligning the energy efficiency targets with the 2030 EU climate ambitions. Please see document attached for FNADE's comments.

On 16 July, the European Commission opened a public consultation on its review of the Energy Efficiency Directive (EED). TransnetBW considers energy efficiency as a key driver to reach the EU’s energy and climate policy objectives for 2030 and beyond. The European power systems will play a decisive role in supporting and enabling the achievement of these ambitions.

EU energy efficiency directive (EED) – evaluation and review (Commission Adoption until 19 November 2021) The members of the electric Handdryer Association (eHA) strongly support the EU’s goal to reduce EU greenhouse gas emissions by at least 55% by 2030, among other things by achieving higher energy efficiency.

DEKRA welcomes the revision of the Energy Efficiency Directive (EED) and the aim to implement energy saving targets in the public sector, such as through the mandatory annual renovation of 3% of public buildings.

Bioenergy Europe welcomes the European Commission’s proposal for the recast of the Energy Efficiency Directive (EED). The draft shows a renewed interest towards heat decarbonisation, listing concrete measures to further promote the uptake of renewable heat solutions such as sustainable biomass.

Dear Commission, We would like to fully support the comments and justification expressed by Eurofer in its position document (attached). As such we fully support the following: • The Energy Efficiency Directive (EED) should remain focused on its primary objective of promoting energy efficiency and refrain from double regulation with other legislation.

Feedback to the evaluation and review of the EU energy efficiency directive (EED) Proposal for a Directive - COM(2021) 558 dated July 14, 2021 We welcome the European Commission’s initiative reflected in the latest revision of the EU energy efficiency directive (EED) recast to strengthen the regulatory framework to lift barriers hampering the wider application of excessive waste heat recovery from data centres.

As a basic principle, we support the notion of energy, and on a more overall basis, ressource, efficiency. Nevertheless, any such notion needs to be well integrated into the legal framework of the EU based on transparent, holistic and reliable planning taking international competitiveness fully into account and aiming at utmost planning certainty.

CEWEP Ireland supports the definition of ‘efficient district heating and cooling system’ in the revised Articles 23 and 24 of the EED recast. The stricter planning requirements and the obligation to follow up on comprehensive assessments on heating and cooling, including the promotion at local and regional levels, will be important for Member States such as Ireland where there is currently low levels of district…

The revision of this Directive comes at a crucial time. Over 50 million Europeans currently live in unhealthy, leaky homes; forced to choose between heating their homes and having food on the table. Moreover the social cost of inefficient housing is severely understated, with indecent housing linked to over 100,000 premature deaths and a public health burden of over €194 billion a year across the EU.

High energy prices affect the competitiveness of European energy-intensive industries (EIIs), and in particular the steel industry vis-a-vis competitors in third countries. A coherent EU energy policy framework should aim at ensuring affordable energy prices, so to boost industrial competitiveness and avoid losing further market shares at a global level.

Enel welcomes the EU Energy Efficiency Directive’s “Fit for 55” recast proposal. The proposed increase of the EU target to reduce energy consumption by at least 9% by 2030 compared to the projections of the 2020 Reference Scenario baseline seems appropriate to reach the 55% GHG emissions reduction target by 2030.

Please find enclosed the submission document drawn up by the Andalusian Energy Agency. Technical and Energy Planning Directorate C/[name removed], 6. Isle de la Cartuja, 41092 Seville, [email removed] Tfno: 954 78 63 35, Fax: [phone removed] https://www.agenciaandaluzadelaenergia.es/es

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The European flat glass sector takes it as its role to produce the materials essential for renovating Europe’s buildings, for supporting the clean mobility transition and for increasing the share of renewable solar energy in Europe.

EU Energy Efficiency Directive – evaluation and review The Finnish Technology Industry welcomes the opportunity to comment on the subject matter. Summary of the main messages of our opinion: •Technology is in favour of tightening the energy efficiency target at EU level as it generates markets and demand for energy-efficient solutions.

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AEAS welcomes the Proposal for a Directive on energy efficiency (recast) (EED) and supports the role of circular economy and the life cycle approach. Water operators are moving towards energy neutrality, combining high energy efficiency and generation of renewable energy.

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital plays a key role in enabling the green transition and achieving the ambitious climate goals. Studies show that carbon emissions of traditional sectors e.g., construction, manufacturing, energy, transport, or agriculture can be cut by a fifth by 2030 through digitalisation.

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Energy Efficiency Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.

Synergrid is the Belgian association representing all Belgian TSOs and DSOs (electricity and gas). In our response we are focussing mainly on article 25 about energy transformation, transmission and distribution in the recast EED. Synergrid can comfortably state that energy efficiency runs already for many years through the ‘veins’ of its member companies.

ECGA, the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology acknowledges the publication of the…

EiiF welcomes the EED recast and supports in particular the following amendments: • The energy efficiency first principle (cf. Page 3) • A binding and increased energy savings target (cf. Page 34) • Energy management obligation for energy-intensive companies (with an annual energy consumption higher than 100TJ) (cf.

PLINOVODI d.o.o. as a transmission system operator in Slovenia supports stronger promotion of energy efficiency in all areas of the energy system and in all relevant sectors, where activity affects energy demand, as well as energy efficiency first principle as its key role.

We would like to thank you for the opportunity to comment. EED III We reject the provision on mandatory implementation of energy audit results. How can these be translated into deductions in the Emissions Trading System? What are the measures for ETS installations? Penalties must be predictable and objectives achievable.

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With the European Green Deal, the European Commission presented an ambitious growth and transformation strategy in December 2019, which is intended to bring about climate neutrality for Europe by 2050. In response to this landmark decision, the European Parliament and the European Council have committed to realigning the European climate targets for 2030.

CEMR acknowledges the need for increased energy efficiency and energy savings as necessary components to reach EU climate targets for 2030 and carbon neutrality 2050. We support ambitious climate and energy policy and action involving local and regional authorities (LRAs) as forerunners, when accompanied by appropriate frameworks, measures and financial resources.

The EED builds on the European Green Deal, in which the Commission set out “a new growth strategy that aims to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use.

The European Infrared Heating Alliance (EIHA), representing the infrared heating manufacturers in Europe, welcomes the opportunity to share its feedback on the proposed revision of the Energy Efficiency Directive (EED). Achieving the 55 % emissions reduction targets by 2030 and climate neutrality by 2050 will require ambitious policies to bring change in the European energy system.

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (Escos), FEDENE’s members employed 60.000 professionals developing sustainable services.

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Eurelectric, the European electricity industry association, welcomes the chance of expressing its views on the Commission’s proposal for a more ambitious Energy Efficiency Directive. Our full feedback is attached.

The TIC Council, as the voice of international independent third-party testing, inspection, certification and verification organisations, welcomes the Commission’s proposal for a more ambitious Energy Efficiency Directive.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

At REPSOL we consider the revision of the EED to be timely, as emissions reduction is linked with Energy Efficiency (EE). In any case, we would like to contribute with the following suggestions: a) Benefits of technological neutrality are not fully exploited Annex V provides the direct use of fossil fuels will no longer be counted for meeting EE obligations.

GD4S welcomes the EC decision to revise the EED, and its inclusion of the Energy Efficiency First Principle. A broader view of efficiency, such as Life Cycle Analysis (LCA) and system benefits, is required to ensure that carbon emission are not just displaced but avoided. - An LCA to assess the overall CO2 and cost-efficiency, including in manufacturing and recycling.

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

Gas Networks Ireland (GNI), welcomes the opportunity to provide feedback on the forthcoming evaluation of the EU Energy Efficiency Directive (EED). GNI agrees with the view that energy efficiency is to be treated as an energy source in its own right. Gas grids can play a key role in the energy transition and in terms of energy efficiency.

The FGW is committed to ensuring that the efficient use of energy is of the utmost importance with the increasing share of renewable energy sources. However, energy efficiency should not only be seen as an absolute savings target, but should also take into account, for example, the increased need for flexibility due to an increasing share of renewable energy.

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The European Commission published the revised text of the Energy Efficiency Directive (EED) on 14 July 2021 within the Fit for 55 package. MVM Group (a 100% state-owned integrated energy company) has analysed the text.

The VKU is grateful for the opportunity to comment on the draft revision of the Energy Efficiency Directive. With the revision of the EED, the future framework of EU energy efficiency policy will: tension until 2030 and partly beyond. What can be inferred from this national implementation options are high for VKU member companies economic relevance.

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Dear Sir/Madam, The Association of State Heritage Care (VDL) expressly welcomes the European Commission’s initiative on climate protection. This is because the protection of monuments takes account of climate change concerns: Preservation of monuments follows the principles of sustainability and resource conservation through the protection of substance, the prevention of building rubble and the minimisation of land…

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Dear Colleagues, The German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Proposal for a Directive of the European Parliament and the Council on energy efficiency (COM(2021) 558 final). Attached please find our position paper.

The revision of this Directive comes at a crucial time. Over 50 million Europeans currently live in unhealthy, leaky homes; forced to choose between heating their homes and having food on the table. Moreover the social cost of inefficient housing is severely understated, with indecent housing linked to over 100,000 premature deaths and a public health burden of over €194 billion a year across the EU.

As part of the European Green Deal, the EU has adopted the European Climate Law, which includes a binding commitment for the Union to become climate-neutral by 2050. It has set a highly ambitious interim goal on the road towards achieving climate neutrality by targeting a reduction of at least 55% in CO2 emissions by 2030.

The European Data Centre Association (EUDCA) is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), EUDCA supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

Helen Ltd. is the second largest energy company in Finland with the 1.8 million consumers. Helen Ltd.’s district heating network is the fifth largest in the world and we are reaching the carbon-neutrality by 2030 based mainly by the non-combustion technologies. Already today but in much larger scale in the future Helen Ltd.

The BDEW supports the objectives of the Energy Efficiency Directive (EED) and considers the issues addressed therein to be relevant to achieving these objectives. Since the introduction of Directive 2012/27/EU (EED) in 2012, both the energy and climate policies of the European Union and its Member States have evolved considerably. This must also be reflected in an adaptation of the EED rules.

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Energy efficiency is a critical lever for decarbonizing the EU economy. The revision of the Directive is needed to adapt it to the new headline emission reduction target. Measures to promote energy efficiency should be coherent, proportionate and essentially market-driven, while avoiding policy overlaps. Otherwise it may have unintended consequences and risking undermining cost-effective decarbonisation.

With the Energy Efficiency Directive proposal, the Commission has timidly started to embrace a system efficiency perspective resulting from the activation of demand-side flexibility, although it is not fully compliant with its own Energy System Integration Strategy.

In its statement on the renovation wave initiated by the European Commission, ICOMOS Germany, to-gether with other organizations and associations, has already pointed out that the European cultural her-itage must not be completely disregarded in the efforts for effective climate protection.

In July 2021, the European Commission launched its recast proposal for a revised Energy Efficiency Directive (EED) within the “Fit for 55” package, which aims to reach at least 55% net greenhouse gas emissions reduction by 2030 in line with the European Green Deal. The recast proposal is being now debated within the Council and the European Parliament.

PGE Polska Grupa Energetyczna S.A. (hereinafter: “PGE S.A.”) welcomes the recast of the Directive 2012/27/EU of the European Parliament and of the Council on energy efficiency (hereinafter: “EED”) as an opportunity for a reasonable adaptation of the current regulations to the Union’s climate neutrality objective by 2050.

Keppel Data Centres (KDCR Ireland) is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), Keppel Data Centres supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

Generally The VCI supports the objective of net-zero greenhouse gas emissions. The need to move away from fossil fuels in the electricity sector to a large extent and to compensate for it through the development of renewable energies is a challenge. This can be better addressed by increasing energy efficiency.

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Equinix is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), Equinix supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

KevlinX is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), KevlinX supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

3DS OUTSCALE is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), 3DS OUTSCALE supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.

E.DSO welcomes the revision of the EU’s approach to energy efficiency (EE) and the FF55 package as a tool to equip the EU’s economy for climate neutrality. However, we acknowledge that the role of DSOs is not sufficiently recognized in the EED or the FF55 despite their central role in the energy transition.

The European Commission adopted on 14 July 2021 a major step towards reducing Europe’s greenhouse gas emissions. The “Fit for 55” Package aims to introduce the necessary policy and legislation for Europe to cut its greenhouse gas emissions by at least 55% by 2030.

Considering the deployment of several policy instruments to reduce greenhouse gas emissions in the road transport sector and the limited role of road transport in the Energy Efficiency Directive, the FIA EB believes that if road transport gets included in the ETS, the price signal would create an incentive for energy savings in road transport anyway, and therefore it is not necessary to keep road transport in the…

Finnish Forest Industries Federation Register ID number: 39671713910-36 Ahti Fagerblom, Manager, Climate and Energy Policy [email removed] Finnish Forest Industries’ response to the consultation on the Energy Efficiency Directive (EED) Finnish Forest Industry Federation Industry (FFIF) silver that the FF55 package including EED will provide regulatory stability which promotes the industry’s investments in climate…

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Improving energy efficiency is a key part of achieving the EU's climate objectives for 2030 and 2050, which is why EdEn supports the European Commission's proposal to recast the Energy Efficiency Directive (EED).

The industry constantly takes new initiatives to improve energy efficiency. Due to the high energy costs, it is a matter of course to continuously question the energy efficiency of the systems and technologies. But it is becoming more and more challenging to take new measures.

The Federal Association of Energy-Efficient Buildings envelope (BuVEG) welcomes the proposal for the recast of a Directive of the European Parliament and of the Council on energy efficiency. The building sector plays a crucial role in achieving climate objectives, as it accounts for more than 30 per cent of greenhouse gas emissions in Europe.

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● The proposed target under Article 8 to be applied as of 2024 is perceived as a hardly achievable limit in terms of the capacity of the Czech economy and households. As regards the newly proposed commitment - almost doubled annual cumulative final energy savings for the Member States (i.e. 1.5 pp per year) - we oppose its binding nature and „one-size-fits-all“ approach to Member States.

Eurofuel welcomes the Commission’s proposal and we consider energy efficiency as the most cost-effective tool to address climate change and reduce emissions from the building sector for all types of households. The “Energy Efficiency First” principle should be acknowledged throughout the text to enable the contribution of the wide range of existing heating solutions.

Dear Dame or Mr, the Verbraucherzentrale Bundesverband e.V. (vzbv; Www.vzbv.de) represents consumer interests in politics, business and administration and brings consumer rights to court. The vzbv is the umbrella organisation of the 16 consumer centres of the Länder and 27 other consumer policy associations and is a founding member of BEUC, the European Consumers’ Association.

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On 14 July, the European Commission took an important step towards reducing greenhouse gas emissions in Europe. The “Fit for 55” package aims to introduce the necessary policy and legislation for Europe to reduce its greenhouse gas emissions by at least 55 % by 2030.

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UPRIGAZ supports the Commission’s ambition in the Fit for 55 package to adapt EU legislation to reduce greenhouse gas emissions by at least 55 % by 2030, compared to 1990 levels, with a view to achieving EU carbon neutrality in 2050.

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The Polish Electricity Association (PKEE) believes that improvements in energy efficiency are necessary to achieve more ambitious EU climate targets. However, the recast of Directive (EU) 2012/27/EU on energy efficiency (EED) must acknowledge different starting points of individual Member States, especially regarding district heating and high-efficiency cogeneration.

• Article 5 As regards energy efficiency objectives in the public sector, Sweden’s general benefit is that more incentives must be given for profitable energy efficiency improvements and voluntary initiatives to improve energy efficiency and reduce climate emissions. Since 2018 Sweden’s public benefit has been running the so-called climate initiative, which covers a larger share of utilities.

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HSE Group, as a strong advocate of an inclusive and just energy transition, supporting better commitments for the Member States concerning the protection of vulnerable consumers as well as prioritisation of energy efficiency measures with end users and vulnerable groups to reduce energy use.

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EuroACE – Energy Efficient Buildings welcomes the opportunity to share its feedback on the proposed revision of the Energy Efficiency Directive as set out below. We call the co-legislators to consider: 1) Strengthening the collective effort of Member States towards the achievement of the binding EU Energy Efficiency target: - We welcome the proposal for a binding EU Energy Efficiency target but call for it to be…

In order to achieve the EU’s new climate change target of reducing greenhouse gases (GHG) to at least 55 % below 1990 levels by 2030, energy consumption must also be reduced through efficiency measures. We welcome the ‘energy efficiency first’ principle enshrined in the Directive, since a reduction in greenhouse gases cannot be achieved by switching to renewable energy sources alone, but only in combination with…

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The International Association of Oil & Gas Producers’ (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognise that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes.

The Danish Chamber of Commerce’s consultation response regarding the revision and update of the Energy Efficiency Directive (EED). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Energy Efficiency Directive (EED).

Overall - Industry has achieved significant reductions in energy consumption due to efficiency improvements. Switching to low-carbon technologies such as process electrification or hydrogen will however significantly increase the industrial final energy demand.

Efficient use of energy is key to achieve the European Green Deal and as a key, means to decarbonise the energy system by 2050. No, by 2030. ‘The initiative will contribute to the decarbonisation objectives together with other European Green Deal Initiatives with other European Green Deal Initiatives, the EU Strategy for Energy System Integration and Digitalisation Strategy, Zero Pollution Action Plan, Circular…

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The Confederation of Norwegian Enterprise (NHO) welcomes the opportunity to comment and to provide inputs to the EU energy efficiency directive (EED) evaluation or revision. NHO supports the EU ambition of net-zero greenhouse gas emissions (climate neutrality) by 2050 to reach the objectives of the Paris Agreement.

BIBM, the Federation of the European Precast Concrete Industry, shares the European Commission's view that energy use needs to be reduced in order to minimise the associated environmental impacts while maximising benefits for society (Option 3). ‘Energy efficiency first’ principle must be at the core of Europe’s energy policy and the relevant measures should be applied across the entire energy value chain.

Saint-Gobain welcomes the intention to revise the Energy Efficiency Directive: the full potential of energy efficiency across all the sectors of the economy, and in particular in the building sector, needs to be untapped to achieve a reduction of at least 55% of GHG emissions by 2030.

Feedback from Raúl Velasco-Fernández, H2020 MAGIC project (https://magic-nexus.eu/). Efficiency video: https://youtu.be/nZjq6sqJCqo See more details of this recomendations in the document attached. 1. EED should break silo-governance and introduce a nexus perspective where not only energy performance is crucial to a more sustainable economy, but also its balance with other strategic resources as water, materials…

Solving the Market Failure at the Heart of Energy Efficiency Renovation To deliver a step change in the deep energy efficiency renovation of buildings, innovative policy measures will be needed. The revision of the Energy Efficiency Directive (EED) offers an opportunity to put some of these needed policy innovations into place.

Habitat for Humanity Hungary believes that energy-efficient dwellings and appliances not only have a positive economic and environmental effect but are also vital to fight energy poverty (EP). To ensure a just transition and to effectively tackle EP, ambitious energy efficiency (EE) targets have to be reached by measures carried out in the residential sector involving low-income households (LIHs).

Danfoss welcomes the evaluation launched by the European Commission on the Energy Efficiency Directive. With the presentation of the European Green Deal and the new climate objectives for 2030 and 2050, we agree with the Commission that the Directive must be revised, and it is also clear to us the ambition must be revised upwards so that it is fully aligned with the EU’s commitments.

Thank you for this opportunity to briefly comment on this combined evaluation roadmap/inception impact assessment. DI would like to emphasize the key role of energy efficiency in building a carbon neutral EU economy. The current state of affairs indicates, that implementation must be improved in many Member States.

ENGIE's point of view : The impact assessment accompanying the Commission’s communication on stepping up Europe’s 2030 climate ambition showed that the increased ambition for GHG reductions by 2030 would also require higher Energy Efficiency ambition.

THIS IS A SUMMARY OF EHPA'S MAIN REQUEST. THE DETAILED POSITION HAS BEEN ATTACHED TO THIS SUMMARY. The revision of the EED is an important opportunity to further expand the energy efficiency benefits of heat pumps, as well as to support their large-scale deployment in accordance with the EU Energy System Integration Strategy.

ENGIE’s view : The impact assessment accompanying the Commission’s communication on stepping up Europe’s 2030 climate ambition showed that the increased ambition for GHG reductions by 2030 would also require higher Energy Efficiency ambition.

Finnish Forest Industries’ viewpoints on public consultation on EU energy efficiency directive (EED) Wood-based products and sustainable forest management will play an important role when achieving 2030 climate targets and climate neutrality for 2050. Our industry is up to the challenge.

The EU’s 2030 climate target requires an adaptation of the Energy Efficiency Directive (EED) with regard to the transport sector. This applies to the previous 2030 target of 40 % greenhouse gas reduction and, a fortiori, to a possible higher target of 55 %. DVF recommendation of measures related to the Energy Efficiency Directive (EED): • enshrine a target of at least 40 % energy efficiency for the EU in 2030.

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AirClim’s response to the Energy Efficiency Directive (EED) roadmap The action taken in the next 10 years will determine if it will be possible to reach the 1.5°C objective. The EU's commitment to put energy efficiency first needs to be strengthened to enable this.

RE: USIPA response to the inception impact assessment of the Energy Efficiency Directive This submission is on behalf of the US Industrial Pellet Association (USIPA), a trade association bringing together over 30 members based in the southeastern US, representing all aspects of the wood energy export industry and supply chain, including wood pellet producers, large landowners, traders and brokers, equipment…

To be on a pathway consistent with achieving climate-neutrality by 2050, SolarPower Europe supports the European Union to review upwards its 2030 greenhouse gas emissions target to at least 55%. However, the EU is not on track to meet its energy efficiency targets, with energy consumption increasing three years in a row.

General The Flemish Region is satisfied with an evaluation of the effectiveness of the EED Directive. In order to achieve the ambitious energy and climate objectives, all regulatory and incentive initiatives need to be fully cooperative and form a coherent whole. Regular evaluation and timely advice, where appropriate, can contribute to this.

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Introduction Energy efficiency is one of the most cost-effective ways to decarbonise the energy system in both short and long term. A successful energy efficiency policy should aim at supporting multiple targets such as strengthening the competitiveness of industrial value chains and helping to reach climate goals, among others.

Decarbonising the economy and reaching carbon neutrality by 2050 require reducing resources demand - through energy efficiency, circular economy, or lifestyle/behaviour changes as well as technology options to decarbonise the energy supply – like fuel-switching, renewable energy sources.

Veolia welcomes the European Commission initiative to revise the Energy Efficiency Directive, as announced in the EU Green Deal Communication. Efficient use of energy is key to achieve the Green Deal objectives. The revision seems necessary as preliminary estimates show that even if the 2020 target might be achieved due to COVID19 effect, there are very little chances the 2030 targets will be achieved.

The Directive 2012/27/EU on energy efficiency (EED) revised in 2018 is a key element to achieve the European Green Deal objectives, with the Renewable Energy Directive (RED) and the European Emissions Trading System (EU ETS).

COGEN Europe, the welcomes the opportunity to comment on the European Commission’s consultation on the evaluation and revision of the Energy Efficiency Directive (EED). Energy efficiency (EE) has uncontested benefits for energy consumers, cities, the economy and in tackling climate change. Yet, despite efforts to promote energy savings, EU lags behind on its 2020 EE targets.

We welcome the opportunity to contribute to the roadmap consultation of the Energy Efficiency Directive. E.ON fully supports the increase of the 2030 target to reduce greenhouse gas emission by 55%. It sets an appropriate pace to achieve net-neutrality until 2050. Mainstreaming energy efficiency is pivotal to making such a steep cut possible.

Any proposal to revise the current Energy Efficiency Directive (EED) should be based on solid evidence and relevant measures for sectors that are struggling to identify energy efficiency gains. The ferro-alloys and silicon sector support an exhaustive assessment (fitness check) of the current framework to overcome non-regulatory barriers, market failures and weaknesses that may arise in the aftermath of COVID-19…

Contribution from three associations of Eure and Loir (France) 1. Findings on energy efficiency practices Although desired by the general public, energy efficiency is a poorly accessible concept. the measures resulting from the application of the Directive by the state (French) are not very practical and too far from the real life of citizens (example of environmental taxes: They have created rebellions, including…

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Enel strongly welcomes the Commission combined Evaluation Roadmap and Inception Impact Assessment for the review of Directive 2012/27/EU and amending Directive 2018/2002 on Energy Efficiency, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy transition.

Please refer to the document attached. About EHI, the Association of the European Heating Industry: EHI represents 90% of the European market for heat and hot water generation, heating controls and heat emitters, 75% of the hydronic heat pump market, 80% of the biomass central heating market (pellets, wood) and 70% of the solar thermal market.

Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers. With the support of its working groups of industry experts, Liquid Gas Europe is actively involved in concrete initiatives and programmes to ensure the sustainable, safe and efficient development of LPG and bioLPG in Europe.

The GEN-I Group welcomes the European Commission's initiative, via the European Green Deal, to increase the EU's climate ambition for 2030 and thereby accelerate also the deployment of renewable energy, in particular as it affects the potential for active consumer empowerment through renewables self-consumption.

PU Europe, representing the European polyurethane insulation industry welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment on the evaluation and the review of the Energy Efficiency Directive.

eu.bac fully supports a revision of the EED, in combination with additional non-regulatory policy measures. New economic and financial measures should be put in place, supporting the transition to energy efficient, smart buildings.

CEWEP Ireland response to the EC Roadmap on the Review of the Directive 2012/27/EU on Energy Efficiency CEWEP Ireland welcomes the early revision of the Energy Efficiency Directive (EED) as an excellent opportunity to further improve certain elements of the existing regulatory framework to ensure that the EU achieves carbon neutrality by 2050.

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich/WKÖ) supports the goal of European climate policy to achieve greenhouse gas neutrality by 2050. The economy can make a significant contribution, but it needs a fair, plannable, and competitive legal framework in order to continue to implement investments in Europe.

FNADE Feedback – Energy efficiency FNADE, the french association for waste management and environmental services, welcomes the European initiative for the Review of the Directive 2012/27/EU on energy efficiency.

We welcome the European Commission (EC)’s proposal on the combined evaluation roadmap/inception impact assessment for the revision of the EU Energy Efficiency Directive (EED). Energy efficiency (EE) is a key means to limit climate change, ensure energy security while improving air quality and creating jobs.

About Swedenergy Swedenergy is a Swedish association for about 400 companies producing, distributing, selling and storing energy. Our aim is from knowledge, a holistic approach on the energy system and in collaboration with our surrounding environment develop the energy sector – to the benefit for all.

Solar Heat Europe welcomes the commitment announced by the European Commission to increase the 2030 target for greenhouse gas emissions reduction to at least -55%. In this context, we also support the goal of realigning key directives as the RED II and the Energy Efficiency Directive to this higher ambition.

Friends of the Earth Europe (FoEE) is the largest environmental network in Europe, uniting 32 member organisations, activist groups and supporters on social and environmental justice issues. We consider the Energy Efficiency Directive (EED) as an essential strategy to mitigate the worst impacts of climate change, end fossil fuel dominance and help Europe’s energy poor.

As key stakeholders in the housing and real estate sectors, we value the possibility of having our members’ propositions and concerns reflected in the upcoming revision of the Energy Efficiency Directive (EED). In our view the priority should be to focus on a thorough implementation of current legislation, accompanied by specific and impactful non-regulatory measures, such as well-designed financing programmes.

The revision of the Energy Efficiency Directive is an important step to cement the road to climate neutrality including recent related works such as the Energy System Integration, the renovation wave and the Hydrogen strategy. At GD4S, we are convinced that gas solutions and renewable gases, can bring key contributions to achieve a fast, safe and sustainable energy transition and meet the increased 2030 targets.

Bankwatch supports the revision of the Energy Efficiency Directive (EED) and welcomes the opportunity to react to its roadmap. As regards to the options put forward by the European Commission, Bankwatch also supports a stronger implementation of “energy efficiency first” principle, especially in the planning of the EU funds and their spending.

Under the European Green Deal, the European Commission has committed to stronger action on climate change. The current proposal to increase the 2030 target for greenhouse gas emissions (GHG) reduction to at least 55% requires dramatic stepping-up of efforts to improve energy efficiency levels.

The Directive 2012/27/EU on energy efficiency (EED) is a key tool to reduce energy consumption, and accompanied by an ambitious electrification, and the deployment of renewable energy sources, it will help meet the EU’s climate and energy objectives.

EdEn strongly believes, as the Commission does, that the energy efficiency legislation can play a key part in addressing both of the challenges the EU is currently facing: • Climate change - Energy efficiency requirements can lead to significant reductions in fossil fuels consumption and thus contribute to GHG-emission reductions; • Economic crisis - Energy efficiency requirements also contribute to fostering…

Cefic supports Europe’s ambition to become climate neutral by 2050 requiring breakthrough technologies and enabling frameworks for the very large investments required. The Green Deal recognises that Energy Intensive Industries (EIIs) are indispensable for Europe’s transition. The chemical industry provides all other sectors including efficiency solutions to multiple value chains such as the construction sector.

The European Insulation Manufacturers Association (Eurima) welcomes the Commission’s intention to revise the Energy Efficiency Directive in support of the EU’s higher 2030 climate target. Below we list our key priorities for this revision.

A response of Confederation of Finnish Industries to a roadmap consultation on the Energy Efficiency Directive Confederation of Finnish Industries EK represents the entire private sector and has 24 member associations and 16,000 member companies. We speak for employers of all sizes, from public limited companies to SMEs.

Edison welcomes the opportunity to share some preliminary considerations on the review of the Directive 2012/27/EU on energy efficiency (EED), to assess the important contribution to the European objectives it is pursuing. Edison continues with conviction in strengthening a solid growth path in the industrial energy efficiency, construction and energy and environmental services sectors.

Please find the attached paper for our full feedback. Danish Energy Welcomes the Commission's initiative to evaluate the Energy Efficiency Directive (EED) in order to align it with the EU's new and more ambitious climate targets.

FEDENE’s feedback to EED Review Roadmap September 2020 FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services.

The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of EU energy efficiency directive (EED) and wants to draw attention to the following key points: • EUDCA welcomes the review of the EED in the light of a higher EU climate ambition under the European Green Deal; • EUDCA supports a higher 2030 target for energy…

Enedis understands the Commission’s willingness to evaluate EU energy efficiency directive to align it with new climate objectives. Energy efficiency is one of the best lever to reduce GHG emissions and to reach ambitious European climate targets. However, it is also necessary to emphasise the risk of over-regulation.

EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Energy Efficiency Directive (EED). The Alliance brings together businesses, think thanks and Members of the European Parliament to ensure that the voice of energy efficiency is heard across the business and political community.

EUTurbines, the European Association of Gas and Steam Turbines Manufacturers, welcomes this opportunity to provide feedback. The energy efficiency first principle requires giving priority to both demand and supply side energy efficiency measures when available. While demand side efficiency has been under the spotlights for years, supply side efficiency has not been always given the attention it deserves.

Gas Infrastructure Europe represents the European gas transmission operators, gas storage facilities and LNG terminals. Our response is based on responding to the aim: “This initiative aims to address the current low decarbonisation and renovation rates across the EU as well as provide a framework for renovation to play a key role in supporting a green and digital recovery.” Please see our complete views in the file…

Bioenergy Europe welcomes the opportunity to contribute to the public consultation on the revision of the Energy Efficiency Directive. Bioenergy Europe believes that to reach the 2050 decarbonisation targets, 2030 climate and energy objectives must be revised. The penetration of renewables in the heating sector must be prioritised by 2030 to decarbonise Europe’s building stock.

The Confederation of Swedish Enterprise supports efficient use of energy and increased energy efficiency across the EU. Cost efficient energy efficiency improvements can led to positive socio-economic effects and The Confederation of Swedish Enterprise emphasizes the importance of these improvements being realized.

The European copper industry is committed to maintaining a prominent role in the field of energy efficiency. It has an exemplary track record in energy efficiency investments and pioneered strategies on carbon reductions in the downstream industrial, residential, service and transport sectors of Europe.

The German Renewable Energy Federation (BEE) welcomes the COM proposal to reduce GHG emissions by at least 55 percent by 2030. In order to be able to achieve an ambitious greenhouse gas reduction target of at least 55 percent by 2030 compared to 1990, an equally ambitious increase in the targets for the share of renewable energies in gross final energy consumption and energy efficiency are necessary.

Snam welcomes the opportunity to provide feedback to the EC initiative on the review of the EED, acknowledging energy efficiency as key for a cost-effective transition to a net zero economy (“Energy Efficiency First” principle). The revision should proceed consistently with the Energy Sector Integration and Renovation Wave initiatives.

Please, find attached FEAD’s full feedback to the EC Roadmap on the Revision of EED. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to review the 2012/27/EU Energy Efficiency Directive (EED).

General comments Elettricità Futura welcomes the European Commission initiative evaluating the possible revision of the Energy Efficiency Directive. The revision of the Directive is an important opportunity to further expand the energy efficiency benefits, as the “Energy Efficiency First” principle constitutes one of the main pillars of the EU’s fight against climate change and a successful and sustainable energy…

In the light of the impact assessment that the European Commission will organise in preparation for a possible revision of the Energy Efficiency Directive 2012/27/EU (EED), the Belgian Association of Belgian Enterprises (FEB) would like to emphasise the following issues: — The IFR calls for the energy efficiency target to be an indicative target in a possible revised Directive.

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Housing Europe's feedback can be found in attachment. "Conclusion The review of the Energy efficiency directive is the opportunity to rethink our policy approach. The best way to deliver the results we need is to support the people who are delivering them.

CEWEP welcomes the European Commission’s Inception impact assessment on the evaluation and review of the Energy Efficiency Directive (2012/27/EU) - EED and in particular the measures to promote security of supply, resource-efficiency, circular economy, competitiveness and reducing pollution.

The European Engine Power Plants Association (EUGINE) welcomes this opportunity to provide a feedback on the inception impact assessment regarding the review of the energy efficiency directive. The energy efficiency first principle requires giving priority to both demand and supply sides energy efficiency measures when available.

In FORATOM’s opinion, the evaluation and review of the Energy Efficiency Directive should take a closer look at how the Primary Energy Factors (PEF) were (re)assessed in 2016 and what the impact would be of changing the PEF for nuclear technologies.

The OSGP Alliance, a global non-profit association dedicated to promoting the adoption of the Open Smart Grid Protocol (OSGP) and infrastructure for smart grid applications towards a future proof modern smart grid, would like to affirm its support of the objectives associated with the Energy Efficiency Directive (EED) and of the Energy Performance of Buildings Directive (EPBD) as parts of the “Clean energy for all…

Essenscia supports the climate ambition and considers the reduction of greenhouse gases the main objective. Therefore it is important other targets, like the EED target, are supportive of this objective and should be made indicative. The chemical and life sciences sector has been working for decades on reducing its own energy consumption and associated greenhouse gas emissions.

The Federation of Norwegian Industries (Norsk Industri) is grateful for the opportunity to comment on the forthcoming revision of the Energy Efficiency Directive (EEDII). It should be noted that Norway is still in the process of transposing the recently agreed review of the Energy Efficiency Directive (Directive 2018/2002) into national legislation.

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Review of the Directive 2012/27/EU on energy efficiency”. This initiative is clearly in line with the objectives enshrined in the EU Green Deal and to be applied by, among others, the Renovation Wave. Additionally, it could help supporting the economic recovery from the still ongoing Covid-19 pandemic.

SYNERGI welcomes the prominent role that energy efficiency has so far enjoyed with the EU’s Green Deal and the Economic Recovery Plan. As mentioned in our feedback to the Renovation Wave initiative (reference F524095), there are several good reasons the EU must continue to prioritise energy efficiency.

FuelsEurope supports the EU Green Deal’s ambition of climate neutrality by 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. Specifically, the refining industry’s Clean Fuels for All vision indicates how by 2050, liquid fuels for transport could be climate neutral, enabling the decarbonisation of aviation, maritime and road…

The important issues of energy efficiency and the development of renewable energies must, in principle, be considered separately. The ‘energy efficiency first’ principle must not overstretch the energy efficiency targets in order to achieve the climate objectives.

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BPIE welcomes the opportunity to give feedback on the EED roadmap and would like to comment specifically on the provisions of this directive that are related to the building sector. First, the current provision on the renovation of central government buildings (Article 5) is too limited in scope to increase the renovations of the public building segment.

Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this Inception Impact Assessment proposal. We believe that the EU should commit to more ambitious climate and energy targets to limit temperature increases to 1.5°C and safeguard the environment, safety, and prosperity of people in Europe and worldwide.

UPEI, the voice of Europe’s Independent Fuel Suppliers, welcome the opportunity the provide initial feedback to the roadmap on the Energy Efficiency Directive (EED). In this context, we would like to draw your attention to the following issues: 1. We agree that energy efficiency is the number one priority in the transition towards climate neutrality.

ESMIG members welcome the proposal for a revision of the Energy Efficiency Directive (EED) to achieve a higher level of greenhouse gas reduction by 2030 as well as the European Green Deal initiatives. Energy Efficiency First principle is indeed a key means to decarbonise the energy system. The EED revision represents also an opportunity to improve the enabling framework for energy management.

Deutsche Umwelthilfe (DUH) would like to stress that currently, the EED, like the other elements of the Clean Energy for All package, are inconsistent with the ambition of the Paris Agreement, as action in the next 10 years will be decisive in reaching the 1.5°C objective. We fully support the initiative to revise the EED and stresses that the ambition level needs to increase significantly.

Electricity has been decarbonising fast: 59% of the electricity mix was decarbonised in 2019, and this is expected to grow up to 81% in 2030. While further decarbonisation of the current power mix is expected in the coming years, deployment of direct electrification should be pursued faster, further and stronger.

The 2030 energy efficiency (EE) objective was set at 32.5% based on a GHG emissions reduction target of 80-95% by 2050. Consequently, in order to reach carbon neutrality by 2050, the 2030 EE objective should be increased accordingly. Iberdrola strongly supports the proposal to increase this value to 36%.

We appreciate the opportunity to provide feedback to the review roadmap on the Energy Efficiency Directive (EED). Europe Beyond Coal is an alliance of civil society organisations hosted by Climate Action Network Europe working to make Europe coal free by 2030 and hasten the just transition to renewable energy and energy efficiency.

EGEC welcomes the opportunity to contribute to the consultation process on the revision of the Energy Efficiency Directive. For the geothermal sector, the EU targets on climate, renewable energy and energy efficiency need to be revised upwards to be aligned with the 2050 decarbonisation objectives.

VELUX welcomes the timely work of the European Commission in evaluating the Energy Efficiency Directive (EED) to assess its effectiveness and the need for possible further amendments in order to support the EU’s progress towards climate neutrality by 2050.

The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s ambitions to reduce greenhouse gas emissions and the associated initiative to review the Energy Efficiency Directive. EAACA was founded in 1988 and has members from 18 countries, which operate more than 100 production sites and produce around 16 million cubic meter of autoclaved aerated concrete (AAC) annually.

Overall, Deutscher Naturschutzring (DNR) believes that the Energy Efficiency Directive (EED), like the rest of the elements of the Clean Energy for All package, is not consistent with the ambition of the Paris Agreement. Therefore, DNR fully supports the initiative to evaluate and revise the EED with the aim to increase its ambition.

The increased use of local/physical energy sources in buildings (especially heat pumps), as referred to in one of the actions of the Energy System Integration Strategy, is not the only way to increase the efficiency potential of buildings. In agglomerations in particular, there will also be a substantial need for central heating and cooling in future.

Filed in German · English published by the European Commission

The Coalition for Energy Savings thanks the Commission for the opportunity to react to the roadmap on the Energy Efficiency Directive (EED). The Coalition has been advocating for a strong energy efficiency legislative framework for over a decade. Our diversity in membership is a key asset in that effort.

Polish Electricity Association's comments on the review of the Directive 2012/27/EU on energy efficiency Polish Electricity Association (PKEE) believes that energy efficiency might play a role in achieving the European Green Deal objectives, yet it should not undermine the long-term perspective of EU economy electrification.

The EFBWW fully supports the goals laid down in the European Green Deal and welcomes the European ambitions to achieve climate neutrality by 2050. The EFBWW at its general assembly in 2019 adopted a resolution on “Creating a Social Europe of workers”. The Executive Committee adopted in May this year its position on the European Green Deal.

The Swedish Forest Industries Federation represents companies that use forests to provide the raw materials for their products and services. This includes producers of pulp, paper, cardboard, packaging and biofuel. Similarly, sawmills producing all sorts of boards, planks, roof trusses and other prefabricated construction elements are also included.

The Federal Chamber of Labour (BAK) is convinced that increasing energy efficiency is the key prerequisite for achieving climate and energy policy objectives. Energy efficiency also plays a supporting role in objectives such as combating energy poverty, improving industrial competitiveness and security of supply.

Filed in German · English published by the European Commission

The Federal Chamber of Labour (BAK) is convinced that increasing energy efficiency is the key prerequisite for achieving climate and energy policy objectives. Energy efficiency also plays a supporting role in objectives such as combating energy poverty, improving industrial competitiveness and security of supply.

Filed in German · English published by the European Commission

Overall, CAN Europe believes that the Energy Efficiency Directive (EED), like the rest of the elements of the Clean Energy for All package, is not consistent with the ambition of the Paris Agreement. Therefore, CAN Europe fully supports the initiative to evaluate and revise the EED with the aim to increase its ambition.

Habitat for Humanity International (HFHI) wants to highlight the case of Central and Eastern European (CEE) countries focusing on 7 key points 1. Owner occupied Multi Apartment Buildings (MAB) 2. Technical and social assistance to Homeowner Associations (HOAs)3. Role of municipalities 4. Involvement of commercial market 5. Socially targeted subsidies 6. Energy poverty in single family houses 7.

Finnish Energy, the association representing Finnish companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related service, thanks for the possibility to give feedback to the roadmap for the impact assessment on the review of EED.

As a member of the Right to Energy Coalition, the Energy Action Project calls on the EU to oblige Member States to directly address energy poverty through the Energy Efficiency Directive. Energy efficiency, particularly renovation of homes, is the most effective long-term strategy to alleviate energy poverty. 80 million Europeans currently live in unhealthy, leaky homes.

Representing the steel industry in Sweden, Jernkontoret is deeply engaged in the area of energy efficiency. Making the best use of energy is central for the industry as it is a natural way to increase cost efficiency, competitiveness and sustainability.

The Energy Efficiency Directive was, by 2018, subject to amendments. The resulting provisions would, according to the amended provisions, be implemented by 25 June 2020. Any further legislative changes will thus occur very close to the latest. The Union of Tenants is certainly in favour of the EU increasing its common climate ambition in terms of energy efficiency and reducing greenhouse gas emissions.

Filed in Swedish · English published by the European Commission

Considerations of the National Council of Industrial Periti and Graduated Industrial Graduates as regards the revision of the EU Energy Efficiency Directive 2012/27/EU. The revision of the EU Directive 2012/27/EU is an important opportunity for the sustainable development of the European Union, according to the CNPI, the arguments and the revision of the standard should go in the direction of option 3 with the…

Filed in Italian · English published by the European Commission

Regarding energy efficiency improvements in buildings, we would like to reiterate that: - individual metering and billing must remain voluntary in countries where rent includes heating costs. A mandatory requirement would be disproportionate in the context of our housing market, and move the incentive for energetic improvements from owners to tenants.

The German EMAS Advisory Board fully supports the statement of the Spanish Club EMAS. It argues that the initiative for the revision of the EED is a good way to achieve better energy efficiency performance in Europe, but calls for EMAS, the EU's eco-management and audit scheme, to be clearly and forcefully taken into account.

Cloud Infrastructure Service Providers in Europe (CISPE) appreciates the opportunity to offer comments on the roadmap consultation for the Energy Efficiency Directive roadmap. CISPE is a non-profit association that focuses on developing greater understanding and promoting the use of cloud infrastructure services in Europe. Members based in 14 EU Member States range from SMEs to large multinationals.

Total shares the Green Deal’s ambition of climate neutrality in the EU by 2050 and communicated in May 2020 on its Ambition for Net Zero across all its production and energy products used by its customers in Europe by 2050 or sooner (scope 1+2+3). Energy efficiency improvements are key for realising that ambition.

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on the review of the Directive 2012/27/EU on energy efficiency and the related more ambitious targets for the reduction of the EU’s greenhouse gas emissions by at least 50% to 55% by 2030.

The Directive does not sufficiently meet the democratic values of the EU and does not contribute sufficiently to a socially just energy transition. The climate is also not well served. Biomass is CO2 increasing. We have all done everything in our response as set out in the Annex. Please check that our document has been sent to us in your system. If this is not the case we would like to send it by email.

Filed in Dutch · English published by the European Commission

Eurovent supports the energy efficiency (EE) first principle. While outlining the future EE requirements the implementation of the National Energy and Climate Plans (NECPs) of the member must be assessed and enforcement of the NECPs be strengthened so that the EED may reach its targets. EE in the building sector can provide a major share of EE but health and cost aspects should be borne in mind.

The Shift Project would like to thank the Commission for the opportunity to provide feedback to the evaluation/review roadmap of the Energy Efficiency Directive (EED). The Shift Project would like to highlight several points in its feedback, the details of those are provided in the document attached: 1- Europe needs to improve its energy efficiency and, simultaneously, to promote energy sufficiency, for instance…

[Please see attached document for full response] EED needs to avoid capping energy usage and should focus on energy efficiency IFIEC contribution Under the European Green Deal, the Commission has committed to stronger action on climate change and in particular in the field of energy.

The electric Handdryer Association is an international, growing initiative of key hand dryer manufacturers from around the world, including European companies, most of which are family-owned and mid-size. We, the members of the electric Handdryer Association acknowledge that climate change is a global challenge.

Please find attached UNIDEN (French association of large energy consumers)' views on the review of the Energy Efficiency Directive. Key messages UNIDEN reminds that EED needs to avoid capping energy usage and should focus on energy efficiency • Avoid capping of energy consumption but focus on efficiency • Avoid conflicting regulations amongst the Green Deal • Stimulate energy sector integration • Keep out of the…

The change in the structure of Europe’s climate objectives must also be reflected in the energy efficiency target. This opportunity should also be used to make the target architecture consistent. In principle, the nature of the efficiency directive as a framework for achieving the objectives must be preserved and the development and implementation of specific measures must be left to the Member States.

Filed in German · English published by the European Commission

EPEE, representing the refrigeration, air-conditioning and heat pump industry in Europe, welcomes the Commission’s initiative to review the Energy Efficiency Directive (EED) and considers the EED Review key for promoting sustainable cooling as well as synergies between cooling and heating.

Our CEMR key messages are: 1. CEMR welcomes the priority given by the European Commission to saving energy and using energy efficiently. CEMR supports ambitious climate and energy targets in line with 2050 climate neutrality 2. CEMR supports measures and targets for renewable energy on a voluntary basis put forward by MS 3.

Euroheat & Power, the association representing the district heating and cooling sector in Europe and beyond, welcomes the European Commission initiative to assess the effectiveness of the Energy Efficiency Directive (EED) in delivering the energy and climate objectives announced in the EU Green Deal.

eco – Verband der Internetwirtschaft e.V. and the eco alliance to strengthen digital infrastructure in Germany welcome the evaluation of the Energy Efficiency Directive. However, the efficiency assessment of digital infrastructures should not ignore some important aspects.

Filed in German · English published by the European Commission

Turboden welcomes the European Commission initiative evaluating the possible revision of the Energy Efficiency Directive. The revision of the Directive is an important opportunity to further expand the energy efficiency benefits, as well as to support and create a common framework, also in accordance with the Energy System Integration Strategy.

Energy efficiency is one of the tools that can be used to achieve the EU’s goal of carbon neutrality and reduce our exposure to imported fossil fuels. However, it is not an end in itself which must be pursued for itself. Efficiency needs to be promoted only when it reduces greenhouse gas emissions and fossil fuel consumption (gas, coal, oil).

Filed in French · English published by the European Commission

Glass for Europe, the trade association of Europe’s flat glass sector, believes that an upwards revision of the 2030 Energy Efficiency target is necessary to align energy efficiency measures to the increased climate ambition.

The German Business Initiative for Energy Efficiency (DENEFF) would like to thank the European Commission for the opportunity to provide feedback to the evaluation/review roadmap on the Energy Efficiency Directive. DENEFF is closely following the development of the energy efficiency legislative framework and supporting implementation in Germany for ten years.

EUROMOT, the European Association of Internal Combustion Engine Manufacturers, welcomes the Commission's initiative to consult stakeholders on the review process of the Energy Efficiency Directive EED 2012/27. An efficient use of energy is crucial in order to fulfil the EU climate objectives.

The Club EMAS supports the initiative for the revision of the EED as a way to achieve better energy efficiency performance in Europe, but calls for EMAS, the EU's eco-management and audit scheme, to be clearly and forcefully taken into account.

EiiF strongly supports the initiative to revise the EED with the aim to achieve a higher level of greenhouse gas reduction by 2030 and to assure its most effective contribution to other European Green Deal initiatives.

The aim of the Cérémé association (Cercle d’Etudes Réalités Ecologiques et Mix Energétique) is to promote –in France and the European Union more broadly –a debate based on the ecological and economic consequences of the various types of energy. This discussion primarily considers the targets set out in the draft “energy efficiency” directive.

The VIK welcomes the opportunity to provide feedback on the inception impact assessment on the Review of the Directive 2012/27/EU on energy efficiency, and fully supports the efforts on climate protection and towards a low greenhouse gas economy. With the Green Deal, the EU Commission has set climate neutrality as a key priority.

The German Construction Industry Federation represents the interests of large companies, family companies and mid-sized companies at a national, European and global level. The federation members are mostly run as family companies, operating across regions, highly innovative and concentrated on technically complex projects.

Gas Networks Ireland (GNI) and its parent company Ervia, welcomes the opportunity to provide feedback on the forthcoming evaluation of the EU Energy Efficiency Directive (EED). GNI and Ervia agree with the view that “efficient use of energy is key to achieve the European Green Deal objectives”.

Right to Energy is a European-wide coalition which unites trade unions, anti-poverty organisations, social housing providers, energy cooperatives and environmental and health organisations to advocate on energy poverty and energy efficiency. Energy efficiency, particularly renovation of homes, is the most effective long-term approach to alleviate energy poverty.

Business Finland is the Finnish innovation funding, trade, investment, and travel promotion organization and is fully owned by the Finnish government. We fully recognize the strategic importance of the EED directive, support the decarbonisation of the energy sector and understand the importance of energy efficiency in achieving climate objectives.

Energy Technologies Europe (ETE) represents the suppliers of energy conversion technologies. ETE Members are located throughout Europe and are engineering cutting edge technologies contributing to a clean, secure, and affordable energy supply.

TIF shares Commission’s view that efficient use of energy is key to cost-effective delivery of the EU’s climate ambition and to achieve other European Green Deal objectives Voluntary energy efficiency agreements have been effective Current EED offers member states several options how to improve energy efficiency on a national level.

In summary, Energy Agencies of Sweden wants to emphasize the following: - The review and possible revision of the Energy Efficiency Directive (EED) must be based on sustainability and a holistic view, as proposed by the European Commission. - It is important to recognize the role of attitudes and behavioural changes in both non-regulatory and regulatory measures.

The emergence of the Green Deal and the inclusion of net neutrality by 2050 as the flagship objective of European policy entails the need to review a number of founding texts, including the Energy Efficiency Directive to set landings.

Filed in French · English published by the European Commission

Regulatory Assistance Project (RAP) welcomes the opportunity to give feedback on the EED roadmap. The Commission (EC) aims to ensure that energy efficiency (EE) sufficiently contributes to the achievement of a higher 2030 climate goal.

Public Housing Sweden´s view of the roadmap for review of the Directive 2012/27/EU on energy efficiency Public Housing Sweden is an industry and interest organization for Sweden's public and private housing companies. Public Housing Sweden shares the Commission's view that energy use needs to be reduced in order, among other things, to reduce CO2 emissions and make EU less dependent on imported energy.

EurEau is the European federation of water services and represents drinking water (DW) and waste water (WW) operators from 29 countries. We support the EU’s Green Deal, including its climate targets and Strategies. We call for full coherence between the EED, other energy legislation (RED), and sectoral legislation (Drinking Water Directive - DWD, Urban Waste Water Treatment Directive - UWWTD).

The Energy Efficiency Directive needs to avoid capping energy consumption and should focus on actual efficiency: • The EED must focus on actual efficiency keeping industry growth instead of capping energy consumption which would lead to a reduction of the manufacturing production. • The revised EED objectives should not come in conflict with the provisions of other related directives such as ETS or RED.

Climate change is a global challenge that demands urgent action and requires every actor in society to play his/her part in responding to the challenge. We, in the paper industry, are strongly convinced that, with the help of the new European Green Deal, we can reduce our impact on climate change while increasing production in Europe.

The main points of the EuroACE feedback on the EED Roadmap are: - The Commission recognises in its Roadmap the importance of energy efficiency and a lack of recent progress, but, unfortunately, it does not lead to a stronger and more forward-looking approach; - There is a big oversight, i.e.

Energy efficiency is the least presented for the purposes of achieving climate neutrality in 2050. This is clearly to be strengthened. Ideally, the energy needs would be offset by the overall improvement of energy efficiency. In other words, this would lead to stabilising energy consumption.

Filed in Polish · English published by the European Commission

Although domestic wind and solar energy will very likely make an important contribution to the further increase of installed EU renewable energy, it is also very likely it will not be sufficient to achieve the Paris agreement goals.

It is important to update the energy efficiency directive in order to match the new Green Deal goals. In this sense, we would like to remember that energy efficiency is just part of the solution and one of the ways to reduce energy consumption, thus reduce Greenhouse Gases (GHG) emissions.

1. Add methane emissions to the gasses covered by the ETS 2. Add Oil and Gas and related activities to the sectors covered 3. Issue free allowances to electrochemical, electrochemical and green hydrogen long-duration energy storage installations that can be resold 4.Reformulate the ETS Directive to provide that the Member States should use at least 50% of auctioning revenues in financial value for energy-related…

Ironically, the European Union, the European Investment Bank, and national governments in Southern and Eastern Europe focus on supporting and financing the implementation of nZEB without focusing on the enforcing and enabling human infrastructure (problem root cause) that should understand and define nZEB’s performance before carrying them out.

Any increase in the EU's climate goals requires a dramatic intensification of the work of expert bodies to implement the necessary significant technological leap in many technologies. Without a proper technological leap, an ambitious climate policy can disappoint politicians and societies. Advances in technology: 1. The use of biomass seems to be the cheapest way to achieve climate neutrality in Europe.