446 submissions from 348 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 472 submissions on this file. Shown here: the 446 from organizations. Not shown: 22 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 4 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
CommitteeITRERapporteurCiarán Cuffe (Greens/EFA)
Public consultation closed: Establishment of a portfolio framework to increase lending towards energy performance renovations , 45 responses · 18 Nov 2025
Published in the Official Journal · 8 May 2024
Signed · 24 Apr 2024
Approval of the EP's first reading position by the Council (adoption of the legislative act) · 12 Apr 2024
Discussions within the Council or its preparatory bodies · 11 Apr 2024
Who showed up
286 submissions from industry — companies and their trade associations — against 101 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 2.8 industry submissions for every one from civil society.
Industry 286Civil society 101Public authorities, academia, other 58
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 1 submission here repeats one text word for word and is folded into it.
What the room declares
194 of 348
in the EU Register
1,033
full-time lobbying staff
€93.3M+
declared costs a year
619
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 1 Apr 2022 — it ran from 15 Dec 2021.
Inception Impact Assessment Revision of the Energy Performance of Buildings Directive 2010/31/EU OBSERVATIONS CONFINDUSTRIA 22 MARZO 2021 • Noting the increase in the EU's ambition for 2030 and 2050 in terms of reducing emissions of climate-changing gases and energy consumed, a revision of this Directive is considered essential to have greater involvement of the construction sector, to which a significant share of…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Brussels, 22 March 2021 “Inception impact assessment – Revision of the Energy Performance of Buildings Directive 2010/31/EU” This is the reply of the European Heating Industry to the roadmap consultation launched by the European Commission on the review of the Energy Performance of Buildings Directive 2010/31/EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Schneider Electric welcomes the opportunity to share its feedback on the EPBD inception impact assessment. Buildings are the bedrock of Europe's decarbonization. We cannot solve climate change without transforming our buildings. This requires massive efforts from the private and public sectors, and support from the regulatory framework. First, the EPBD 2018 implementation must be strongly enforced.
Knauf Energy Solutions (KES) is a European one-stop-shop for residential building renovation powered by state-of-the-art digital technology. Our experience in delivering commercial-scale retrofits for social housing underlines that the EPBD revision needs to focus on two key areas. 1.
The revision of the EPBD is an important opportunity to increase the ambition for decarbonising the building stock with efficient and renewable heating and cooling solutions such as heat pumps in buildings. EHPA proposes the following measures: 1) Efficient and renewable heating system required in new buildings and major renovations EHPA recommends setting mandatory minimum energy performance standards at such an…
CEI-Bois We are a responsible Industry Woodworking Industry’s feedback to the review of the Energy Performance of Buildings Directive 22 March 2021 CEI-Bois welcomes the “Renovation wave” initiative as part of the EU Green Deal, and the consequent revision of the Energy Performance of Buildings Directive.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EDISON’S CONTRIBUTION TO THE REVIEW OF THE ENERGY PERFORMANCE OF BUILDINGS DIRECTIVE 2010/31/EU Edison welcomes the opportunity to share some preliminary considerations on the review of the Energy Performance of Buildings Directive 2010/31/EU, to assess the important contribution to the European objectives it is pursuing.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EPBD is the only EU legislation to address private charging and by failing to make this a focal point of the roadmap and the IA, the EU would be missing an essential piece of the European Green Deal and the Climate Target plan. The recent surge in electric vehicles (EV) sales (10.5% EV sales in 2020) highlights the need to ensure charging infrastructure keeps pace with the rapid growth of the EV market.
The European Union has committed to a net-zero economy by 2050. To get there, we urgently need to increase ambition levels and actions across all climate levers at EU level. This includes vastly increasing the energy efficiency of the building stock: Around 75% of the EU’s building stock is currently energy inefficient, and almost 85-95% of today’s buildings will still be in use in 2050 .
Liquid Gas Europe feedback to the roadmap on the revision of the Energy Performance of Buildings Directive Liquid Gas Europe is a European association composed of national Liquefied Petroleum Gas (LPG) associations, the main European LPG suppliers, distributors and equipment manufacturers.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ANIMA Federation is the organization representing the mechanical and engineering industries in Italy Regarding the Inception Impact Assessments for a potential revision of the Energy Performances of Buildings Directive, our opinion is that the issues of energy efficiency and renovation of buildings are fully among the most relevant to achieve the objectives of decarbonisation of the public and private building stock…
Association for District Heating of the Czech Republic (ADH CR) welcomes the opportunity to comment on Inception Impact Assessment to Revision of the Energy Performance of Buildings Directive 2010/31/EU (IIA). In light of such revision the following points should be addressed: ● Mandatory Minimum Energy Performance Standards (MEPS): Mandatory MEPS could be beneficial to further speed up building decarbonisation…
The energy transition can only succeed if all sectors contribute their fair share to the overall EU objective of achieving "net zero" by 2050. The building sector currently accounts for approximately 39% of CO2 emissions in the EU; therefore, it is also essential to set an ambitious course for climate neutrality here.
The Caisse des Dépôts Group (CDC), as the French climate public long-term investor strongly involved in the renovation of buildings while being the first social landlord in France, supports the revision of the Energy Performance of Buildings Directive.
Revision of the Energy Performance of Buildings Directive (EPBD) Ventilation systems in buildings to deliver on energy efficiency and Indoor Air Quality (IAQ) Introduction The European Ventilation Industry Association (EVIA) shares the European Commission’s ambition laid out in the European Green Deal and the Renovation Wave to make buildings more energy-efficient and less carbon-intensive over their entire…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Housing Europe contribution to the consultation on the Policy Roadmap for the revision of the Energy Performance of Buildings Directive (EPBD) Draft version March 2021 1. The ambition of the Social, Cooperative and Public Housing Providers: The leaders of the 27 member states of the European Union (EU) agreed on Friday 11 December to reduce their greenhouse gas emissions by “at least 55%” by 2030, by compared to the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Enel warmly welcomes the Commission Inception Impact Assessment to review the Directive 2010/31/EU and amending Directive 2018/844/EU on Energy Performance of Buildings, 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.
Better and more EE buildings are crucial for achieving the EU's energy and environmental goals, improve the quality of citizens' life, while bringing additional benefits to economy and society. The main legislative framework aimed to boost EPB includes the EPBD and EED; together, these two DIRs promote policies helping to: achieve a highly EE and decarbonised building stock by 2050; create a stable environment for…
The review of the EPBD provides an opportunity for further energy reduction and CO2 emissions and a return on investment. We support increasing the objectives of the EPBD and option 3, combined with the reinforcement of the current EPBD and support measures. A clear rehabilitation target should be set in line with the Renovation Wave (25 million buildings rehabilitated by 2030).
Filed in Spanish · English published by the European Commission
The Confédération Nacional de Asociaciones de Empresas de Fontanería, Gas, Calefaction, Climatisation, Fire Protection, Electricity and Afines (CONAIF) considers that decarbonisation of the buildings sector is vital to meet the EU’s climate and energy targets for 2030 and 2050, as buildings are responsible for 40 % of total energy consumption and 36 % of greenhouse gas consumption in the EU.
Filed in Spanish · English published by the European Commission
Stadtwerke München supports the renewal of the Energy Performance of Buildings Directive in order to achieve the objectives of the Green Deal in the long term. However, the following points should be taken into account in the revision: Integration of buildings and mobility sector With regard to the construction requirements for new buildings, the Commission’s idea of bringing the buildings and mobility sectors…
Filed in German · English published by the European Commission
Snam welcomes the opportunity to provide feedback on EC initiative on the revision of the EPBD. Higher climate ambitions require a swift implementation of the Renovation Wave initiative: increased building renovation rates and depth play a key role for a cost-effective transition to a net zero economy.
The scale and speed of transformation required to deliver on the EU’s 2030 and 2050 climate and energy targets requires not only clear and certain regulatory frameworks, but also adequate financing and enabling measures to foster deep renovation in both the public and the private sector.
The revision of the Energy Performance of Buildings Directive is a great opportunity to lay the foundations for deep, digital and future-ready renovations of the EU’s buildings stock. The potential is obvious as buildings now contribute to about 40% of EU energy consumption and 36% to greenhouse gas emissions.
Contribution of the Northern Netherlands to the Commission Inception Impact Assessment for the Energy Performance of Buildings Directive 2010/31/EU (EPBD) The Northern Netherlands, consisting of the Dutch provinces of Drenthe, Fryslân and Groningen, and the cities of Leeuwarden, Groningen, Assen, Emmen, welcome the opportunity to provide input for the review of the Energy Performance of Buildings Directive.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The building sector is already today recognized as the one with the greatest potential to decarbonize europe. As the requirements for new buildings are already today in many cases much higher the key is to improve the renovation and replacement of inefficient technology in the existing buildings.
The Bundesverband Pro passivhau eV is mainly active in Germany and brings together planners, service providers and industry. The Association and its members are in exchange with many European representatives of the construction sector, who have become a growing community with high expertise in the field of the highest energy efficiency in buildings through the support of the internationally valid passive house…
Filed in German · English published by the European Commission
Göteborg Energ’s response to the consultation of the Inception Impact Assessment for the revision of the Energy Performance in Buildings Directive 2010/31/EU (EPBD) 10-2021-0369 • Göteborg Energi AB supports ambitious climate and energy targets in line with 2050 climate neutrality for the EU.
The Coalition for Energy Savings welcomes the possibility to provide feedback and recommends that the following three considerations guide the upcoming EPBD revision: First, the EPBD revision must truly boost energy savings in the building sector to contribute to the achievement of a higher 2030 energy efficiency target; a stronger EPBD is also a prerequisite to meet a higher 2030 GHG emissions reduction target, the…
In the attached note, the FFB provides some comments on the different actions envisaged by the European Commission in its preliminary impact assessment. In conclusion, the FFB considers that only a strong incentive policy is capable of ensuring a harmonious development of the energy renovation market for buildings.
Filed in French · English published by the European Commission
The Andalusian Energy Agency (Agencia Andaluza de la Energía) is a 100% public body fully integrated in the Andalusian Regional Government and was created by regional law 4/2003 of 23 September. The Andalusian Energy Agency plays a major role as the entity responsible for the monitoring and implementation of the energy policies of the Andalusian Regional Government.
EFIEES represents energy service companies and their national associations in 12 EU Member States. They account for 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.
We strongly support the attached position of ECFD, eurofuel, FuelsEurope, and UPEI on the EC Roadmap regarding Energy Performance of Buildings Directive. It shows a realistic and efficient approach towards decarbonizing the liquid fuelled part of the heating sector. Therefore, we kindly ask to consider our common position as an efficient help to reach our common climate targets.
EDF fully supports the EPBD revision as part of the Fit for 55 Package. This is an opportunity to ensure that the EPBD is fully aligned with Green Deal climate objectives and coherent with other strategies or legislations. To that end, the option 3 of the roadmap is fully appropriate.
The Platform for Electromobility warmly welcomes the EC’s willingness to revise the Directive on the energy performance of buildings (2010/31/EU, EPBD). In light of the EC’s roadmap, the Platform does not only take a stand for the option 3 but points out that electromobility needs to be addressed as one of the key elements of the EPBD revision if the EU wishes to deliver the objectives set in the Smart and…
In response to the EPBD revision Inception Roadmap, COGEN Europe supports option 3 of the inception impact assessment, fostering higher ambition for energy efficiency and system integration in the building sector. In our view, the EPBD should be revised and designed in such a way to promote those solutions that enable significant energy savings and stabilise the energy system in a long-term perspective.
Consultazione Commissione Europea Revisione della direttiva sulla prestazione energetica degli edifici 2010/31/Ue (c.d. EPBD) OSSERVAZIONI ANIGAS 22 marzo 2021 1 Osservazioni generali ANIGAS accoglie con favore la revisione della direttiva sulla prestazione energetica degli edifici, considerandola un'importante opportunità per ampliare ulteriormente i benefici dell'efficienza energetica, ritenendo il principio…
Filed in Italian · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
A significant increase of the renovation rate plays a central role in Europe’s effort to tackle climate change. Consequently, we are strongly in favour of the Renovation Wave’s agenda and welcome the EPBD revision, which must be a core contributor to achieving the aim of carbon neutrality in the building sector.
ROADMAP - REVISION OF THE ENERGY PERFORMANCE OF BUILDINGS DIRECTIVE Finnish Real Estate Federation (FREF) thanks You for the opportunity to give a feedback. We acknowledge the intention of the European Commission to decarbonise our building stock and the objective to have more and deeper renovation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ISSOL is a Belgium manufacturer of solar glass and project developer of active glazing solutions. In collaboration with the world’s most famous contemporary designers we develop beautiful positive energy solutions for buildings that generate their own electricity using the free energy of the sun.
The European Federation of Allergy and Airways Diseases Patients’ Associations (EFA) represents the 200 million people living with allergy, asthma and chronic obstructive pulmonary disease (COPD) in Europe. We fully acknowledge that renovations can drive the transition towards green buildings but also healthy living environments, reducing disease risk factors and allowing vulnerable groups of the population.
On 22 February 2021, the European Commission published its inception impact assessment for the Revision of the Energy Performance Directive. Given the challenges of decarbonising the EU building stock identified in the Renovation Wave communication, we agree that the existing legislation is not sufficient to achieve the goal of minimising the carbon footprint of the built environment.
The EU has committed to a net-zero economy by 2050, and to reach at least -55% GHG reductions by 2030. To get there, this decade must be witness of an unprecedented wave of renovations resulting in buildings emissions reduction by 60% by 2030. Reducing energy demand and increasing energy efficiency in the buildings sector is a prerequisite for achieving the EU ’s energy and climate objectives.
We support the third option for the revision and call on the Commission to consider the following: Minimum energy performance requirements (MEPRs) must be accompanied by appropriate financial incentives and support to both owners and occupants. Introducing MEPRs requires mobilising funding, finance and technical support targeting cities, as well as supportive measures for building owners and occupants.
GD4S welcome the EC decision to revise the EPBD. Massive and fast deployment of CO2 efficient solutions are indeed required in the building sector, the largest energy consumer and CO2 emitter in Europe, to meet the 2030’s CO2 objectives. These solutions must adapt to the high variety of local conditions across Europe.
EPEE Feedback on the revision of the Energy Performance of Buildings Directive (EPBD) March 2021 Executive summary ▪ Whilst recognising the need to revise the EPBD to align the directive with the new 2030 and 2050 energy and climate targets, implementation of existing EPBD provisions is key for achieving Europe’s short-medium term renovation objectives.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ANCE PROPOSALS FOR THE REVISION OF THE EPBD (energy Performance of Buildings Directive 2010/31/EU) in order to double the rate of renovation of existing buildings In Italy, the tax deductions in force, primarily Superbonus 110 %, are a strategic tool for the development and implementation of a concrete programme for upgrading the building stock, in line with the sustainability and land use reduction objectives set…
Filed in Italian · English published by the European Commission
The https://www.renewableheatingandcoolingalliance.org states: • EPBD must focus on displacing fossil emissions from heating and cooling with renewable solutions combined with improving energy savings. There are no substantive technical barriers to enabling this change, just a lack of regulatory design and policy coherency.
World Green Building Council Feedback to Energy Performance of Buildings Directive (EPBD) Review Introduction WorldGBC Europe represents Green Building Councils (GBCs) in over 20 countries and works with eight Regional Partners and over 4,500 diverse members across the construction and real estate sector. Our vision is for a sustainable built environment at the heart of Europe’s future.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
UFE fully supports the EC’s willingness to revise the Energy Performance of Buildings Directive (2010/31/EU, EPBD) as part of the Fit for 55 Package endorsing the new EU climate ambitions. Following the Renovation Wave Strategy, the EPBD is a key file when it comes to the EU building stock’s decarbonisation and renovation.
Reaction of Swedish Construction Federation to Inception Impact Assessment – EPBD Revision We understand the need to revise the EPBD to ensure alignment with the Climate Law and to enable the implementation of the goals for deep renovations in the Renovation Wave. Therefore, we will engage positively with this process and we believe that Option 3 is the most reasonable for achieving the objectives.
The Renewable Heating & Cooling Alliance welcomes the opportunity to provide feedback to the Inception Impact Assessment of upcoming revisions to the Energy Performance of Buildings Directive. Objective: EPBD must focus on displacing fossil emissions from heating and cooling with renewable solutions combined with improving energy savings.
Gas Networks Ireland (GNI) welcomes the opportunity to provide feedback on the Revision of the Energy Performance of Buildings Directive (EPBD) 2010/31/EU Inception Impact Assessment (IIA). GNI agrees that “efficient use of energy is key to achieve the European Green Deal objectives” and that “cost-effective delivery of the EU’s current and future climate ambition” must be a key consideration in the energy…
REScoop.eu - the European Federation of Citizen Energy Communities - welcomes the opportunity to respond to the EBPD Revision Roadmap and Inception Impact Assessment on behalf of over 1500 energy communities and 1 million citizens in Europe.
EGEC welcomes the opportunity to provide feedback to the Inception Impact Assessment of upcoming revisions to the Energy Performance of Buildings Directive. 1. Significance: It is impossible to meet the EU’s 2030 and 2050 climate neutrality targets without ensuring all heating and cooling equipment and appliances are renewable by 2025.
The overall objective is to achieve the EU’s climate and energy targets for 2030 and 2050 by revising the existing Energy Performance of Buildings Directive, with a shift from fossil fuels to renewable energy sources. To this end, the annual energy renovation rate of buildings will be at least doubled by 2030 and deep renovations will be encouraged. The existing legislation is not sufficient for that purpose.
Filed in German · English published by the European Commission
smartEn welcomes the launch of a consultation phase with stakeholders in view of the revision of the Energy Performance of Buildings Directive (EPBD). Considering the roadmap and scenarios proposed by the Commission in its Inception Impact Assessment, smartEn supports Option 3 to amend the EPBD in a coherent way with both the Renovation Wave and the Energy System Integration Strategies.
SGI Europe welcomed in general the European Commission’s initiative for “A Renovation Wave for Europe”. Buildings in Europe consume around 40% of energy, therefore, to achieve the ambitious climate neutrality target and to successfully decarbonise the economy, as set in the EU Green Deal, the building and housing sector has to play a greater role.
The review of the Energy Performance of Buildings Directive (EPBD) provides a much needed opportunity which will result in higher energy savings, reduced CO2 emissions and deliver a high societal return on investment through the multiple ancillary benefits of investing in the building and construction sector.
Bioenergy Europe supports the highest level of ambition in the decarbonisation of building sector in order to achieve carbon neutrality by 2050. Consistently with this position, we have supported the increased use of renewable energy in the public consultations following the presentation of the European Green Deal as the main pathway to decarbonise domestic heating and cooling.
The Norwegian Green Building Council and Norwegian Property Federation hereby wish to provide input to the EU Commission initiative to a revision of the Energy Performance of Buildings Directive. The aim of the revision is to focus on and implement provisions that are central to boosting building renovation.
In the context of the Green Deal, the European Commission has announced that the EU would soon be raising its carbon emission reduction target for 2030 from 40% to at least 55% in view of achieving climate neutrality in 2050.
The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative to revise the Energy Performance of Buildings Directive (EPBD). It is a necessary step towards contributing to achieving the goals of the European Green Deal. Investment in buildings can provide a boost to businesses. In the light of the COVID-19 pandemic, this will be a necessary driver for the economy and central to the EU’s green recovery.
AUTODESK welcomes the opportunity to provide input regarding the revision of the Energy Performance Building Directive (EPBD) and shares the Commission’s view that decarbonization of the building sector is vital to deliver on the EU’s climate objectives.
REHVA welcomes the Renovation Wave Strategy and supports policy option 3, revising the EPBD to foster deep energy renovation that delivers healthy and energy efficient buildings. However, more attention shall be paid to improved indoor environment quality (IEQ) in energy renovation.
The EPBD is the only EU legislation to address private charging and by failing to make this a focal point of the roadmap and the IA, the EU would be missing an essential piece of the European Green Deal and the Climate Target plan. The recent surge in electric vehicles (EV) sales (10.5% EV sales in 2020) highlights the need to ensure charging infrastructure keeps pace with the rapid growth of the EV market.
Detailed knowledge about Europe’s and the EU associated countries’ building stock features and performances, including local (at least country / NUTS0) varieties, has a potential positive disruptive effect on the ability to design effective policies targeting buildings in view of the 2050 strategy and the European Green Deal.
The main points that EuroACE wishes to raise in response to the inception Impact Assessment Roadmap (IIAR) of the Energy Performance of Buildings Directive (EPBD), are: -EuroACE, welcomes the work of the Commission in revising the EPBD as part of the ‘Fit for 55 Package’.
The revision of the EPBD is part of the “Fit for 55 package” included in the Commission Work Programme 2021. This revision will focus on provisions that are central to delivering a Renovation Wave and that contribute to emission reduction. The Danish Chamber of Commerce fully supports the EU Green Deal, Climate Target Plan 2030, and Fit for 55 package and their complementary policies.
EuropeOn, the EU association of electrical contractors, welcomes the upcoming revision of the Energy Performance of Buildings Directive. Buildings will be at the center of climate action and digitalisation in the coming years, as they are needed to support local deployment of renewables, to provide flexibility to power systems and enable the smart electrification of transport.
The energy performance of buildings is a critical issue to tackle in order to reach a climate neutral economy. With 40% of the total EU energy consumption used to heat or cool buildings, improved standard and targets are essential aspects of the task. Following the Renovation Wave Strategy, Eurelectric fully supports the revision of the Energy Performance of Building Directive (EPBD).
European Aluminium supports the key objective of the EPBD revision to be the phased introduction of mandatory Minimum Energy Performance Standards to trigger energy renovation when key building transformations occur, while financially supporting the renovation works via incentives for private owners.
8 March 2021 Subject: The company response to the Energy Efficiency - Revision of the Energy Performance of Buildings Directive. The company welcomes the opportunity to provide feedback on the revision of the EU Energy Performance of Buildings Directive (EPBD).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The housing industry needs a climate policy that can be carried out by sustainable housing companies and foster their ability to invest in their stock. The intention of the following recommendations is to ensure that housing companies as portfolio managers are enabled to achieve increasing greenhouse gas reduction and that the successes are detectable in practice: - Mandatory Minimum Standards must be economically…
CEMBUREAU, the association of the European cement industry, welcomes the opportunity to provide feedback on the Commission’s inception impact assessment on the revision of the Energy Performance of Buildings Directive. CEMBUREAU’s 2050 Carbon Neutrality Roadmap, which was published in May 2020, sets out the cement industry’s ambition to reach net zero emissions along the cement and concrete value chain by 2050.
Housing Agency of Catalonia (AHC) From ACPORDI (Area of Stock Control, Building Planning and R&D&I of Housing) point of view Option 3 is the one to be adopted. In this sense in our opinion public sector must lead and facilitate the greening building process according to the Renovation Wave strategy and through NEXT-Generation EU funds.
The Inception Impact Assessment for the revision of the EPBD proposes 3 different pathways. - Renovate Europe strongly supports Option 3 ‘Amend the EPBD’ as this will be crucial to achieving the Renovation Wave objectives, with a clear focus on 1) Introduction of MEPS 2) Updating of the EPC framework and 3) Definition of deep renovation standard.
SLSP welcomes the last developments in EU Green policy that bring their attention also to the EU legislation on the energy efficiency (EE) of buildings (EPBD) and its national implementation. The proposal for technical screening criteria for buildings for EU taxonomy refers to the numeric indicators based on the national calculation methodology and as displayed on the Energy Performance Certificate (EPC).
As noted in the IIA, upgrading EV charging requirements under the revised EPBD is essential to deliver on the EU’s climate & mobility ambitions. ChargeUp Europe recommends to Align the EPBD revision with other legislative revisions to deliver a European EV charging masterplan: The revision of the EPBD should closely link with the revision of the Alternative Fuels Infrastructure Directive, which itself should be…
Nelfo, representing the electrical contractors in Norway, welcomes the opportunity to comment on the planned revision of the Energy Performance of Buildings Directive (EPBD). Nelfo believes the revision is needed in order to implement proposed actions in the Renovation wave and to achieve the overall ambitions in EU climate and energy policy.
Revision of the Energy Performance of Buildings Directive 2010/31/EU DI welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on the Revision of the Energy Performance of Buildings Directive (EPBD).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The TIC Council welcomes the European Commission’s intention to amend the Energy Performance of Buildings Directive (EPBD) so that it can contribute to the Renovation Wave and foster deep energy renovations of buildings.
Solar Heat Europe strongly supports the idea that buildings decarbonisation will be key for the achievement of Europe’s 2030 and 2050 climate and energy objectives. In this content, the revision of the EPBD is necessary to ensure an effective renovation strategy and a smooth implementation of the Fit for 55 Package.
Principles With the presentation of the Renovation Wave in October 2020 and the present impact assessment on the revision of the Energy Performance of Buildings Directive (EPBD), the Desh welcomes the increased focus on renovation, modernisation, refurbishment and re-use of existing buildings towards the 2050 climate neutrality objective.
Filed in German · English published by the European Commission
Decarbonisation of the building stock must be based on a deep reduction of energy consumption as it is the very first step in achieving the renovation wave that is part of the European Commission’ Green Deal agenda.
The Ministry of Housing, Local Government and Heritage Legal observations Tab A - Draft Obs on Inception Impact Assessment – EPBD 1. Part B of the document, entitled Objectives and Policy options, states that: “The revision of the EPBD would aim to strengthen the legal framework on energy performance of buildings” and it will do so “by exploring synergies and impacts of existing EU legislation related to energy and…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
KONE Corporation welcomes the initiative of the European Commission to revise the Energy Performance of Buildings Directive (EPBD). 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 greenhouse gas emissions by 2030.
BASF welcomes the initiative and the opportunity to provide feedback. A refurbished and improved building stock in the EU will help pave the way for a decarbonized and clean energy system, as the building sector is one of the largest energy consumers in Europe, responsible for more than one-third of the EU’s emissions.
Position paper on the EPBD roadmap Through this position paper, Aedes would like to give her comments on the inception impact assessment of the Energy Performance of Buildings Directive (EPBD). Aedes is the Dutch association for social housing providers. Together, Aedes members manage 2.4 million dwellings, constituting 32 percent of the total housing stock.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
With cooling needs expected to increase in the years to come, the refrigeration, air conditioning and heat pump (RACHP) sector has an important role to play in delivering on the Renovation Wave targets for 2030. In this context, AREA members, as the architects of RACHP systems, responsible for their design, installation, maintenance and repair, welcome the revision of the Energy Performance of Buildings Directive.
ELA, the European Lift Association, represents the lifts, escalators and moving walks associations active in the European Economic Area or in any country member of the Council of Europe, whether they are national associations or sector specific associations. ELA also represents their (components) manufacturers. The lift industry represents 6.400.000 lifts and employs approx. 160.000 persons in Europe.
IBERDROLA calls for and ambitious revision of the EPBD based on electrification Energy efficiency (EE) and direct electrification go hand in hand and offer the best possible benefits to achieve cost-effective decarbonisation. Any measure that boost electrification will automatically boost EE as well.
Support for Option 3: Amend the EPBD DENEFF — The German Business Initiative for Energy Efficiency — is the voice of Germany’s energy efficiency industry, which accounts for about 600,000 employees. Double the renovation rate of buildings is key for Europe to reach its higher climate targets, to Kickstart a green recovery from the current economic crisis and to provide modern, healthy and comfortable places to live…
Filed in German · English published by the European Commission
GCP Europe members welcome the proposal for a revision of the Energy Performance of Buildings Directive (EPBD) to foster deep renovations and deliver on the Renovation Wave targets for 2030. In this context, our members that include European installers and building professionals for building technologies, plumbing, ventilation, air conditioning, refrigeration and heat pump equipment, will play a vital role in…
In December 2020, the EU agreed to reduce greenhouse gas emissions by 55 % in 2030. As buildings use 40 % of energy and produce 36 % of greenhouse gasses in Europe, an earlier targeted review of the Energy Performance of Buildings Directive (EPBD) is needed to achieve those objectives.
Reducing GHG emissions and achieving carbon neutrality means reducing consumption across sectors. The renovation wave expected at European level rightly targets the building as a major contributor. In this context, the revision of the EPBD can be structuring, provided that it does not err in terms of objectives.
Filed in French · English published by the European Commission
DEAR Sir/Madam, to be in line with the Paris Agreement’s goal, the EU should reduce greenhouse gas emissions by 65 % by 2030. These calls for higher binding energy targets (at least 45 % for energy efficiency and 50 % for renewable energy) and to at least triple the current annual rate of energy renovations, increasing their depth and moving towards a fully renewable energy supply.
Filed in German · English published by the European Commission
To be in line with the goal of the Paris Agreement, the EU should reduce greenhouse gas emissions by 65 % by 2030. This requires higher binding energy targets (at least 45 % for energy efficiency and 50 % for renewables) and at least triple the current annual energy renovation rate, significantly increasing its depth and moving towards a fully renewables-based energy supply.
Filed in Portuguese · English published by the European Commission
With its large portfolio of industries, the ZVEI hosts many technologies that contribute to making our buildings smarter, safer, increasingly energy efficient and more pleasant for their occupants. Thus, to bundle knowledge and competence we have created the ZVEI-Platform for buildings. The commissions aim to boost building renovation is a policy that the ZVEI and its platform for buildings support.
The VELUX Group welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on the Revision of the Energy Performance of Buildings Directive (EPBD). We agree with the Commission’s assessment that existing legislation will not suffice and that a revision of the EPBD is necessary to deliver on the Renovation Wave and European Green Deal objectives. We therefore fully support Option 3.
ESMIG members welcome the proposal for a revision of the Energy Performance of Buildings Directive (EPBD) to contribute to the achievement of the EU’s energy and climate objectives for 2030, and the climate neutrality objective for 2050.
GIH Bundesverband e.V. Die bundesweite Interessenvertretung für Energieberater The GIH Federal Association was founded in 2001. As an umbrella association of 13 member associations, the GIH represents appr. 2,500 qualified energy consultants nationwide in Germany. Our members are craftsmen, technicians, engineers, architects, and scientists.
eu.bac welcomes the 2021 revision of the Energy Performance of Buildings Directive, which has become necessary in light of the increased ambition agreed in the Renovation Wave. To meet EU climate targets and fully decarbonise the building stock by 2050, stronger measures must be put in place at the European level.
The Shift Project would like to thank the Commission for the opportunity to provide a feedback on the inception impact assessment for the revision of the Energy Performance of Buildings Directive. The Shift Project is a French-based think tank advocating the shift to a carbon-free economy. Lowering the energy demand and Co2 emissions of the EU building stock is central to reach carbon neutrality.
Bellona welcomes the decision of the Commission to revise the EPBD in light of the new targets for 2030, aiming at doubling the building renovation rate by 2030. Buildings are responsible for over a third of the energy-related GHG emissions in the EU, thus the revision of the EPBD is necessary to reduce emissions by 55% by 2030.
For the public domain: 1. Real-time monitoring of energy consumption data for each building (Real-time monitoring energy consumption); 2. Availability of energy consumption information in real time locally; 3. Availability of electrical production information in real time locally; 4. Installation of centralized technical management systems for buildings (BMS); 5.
ENERGY EFFICIENCY – REVISION OF THE ENERGY PERFORMANCE OF BUILDINGS DIRECTIVE Documento presented by: Federación Coordinadora de Telecomunicaciones, FECOTEL Dirección: Avda. de Aznalcázar 33. 41110, Bollullos de la Mitación - Sevilla Phone: [phone removed] e-mail: [email removed] 22 de marzo de 2021 INTRODUCCIÓN Fecotel es una organización empresarial española representativa del sector de empresas instaladoras…
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ABOUT SOLAR AS BUILD SOLUTION FOR DESCENTRALIZED ENERGY As a transmittal for the revision, we are in the #sustainablepublicaffairs with Mr. Willem Vriesendorp who send a letter to the Commission, Frans Timmermans about the relevance of retrofitting buildings in the EU, and the necessity to include Solar Build Materials (named BIPV), as the mainstream to reduce the building impact on carbon footprint.
ECODES fully supports the revision of this directive, as outlined in option 3, to deliver on the Renovation Wave and drastically reduce Europe’s carbon emissions. Renovations can provide extensive co-benefits for tackling climate change, alleviating energy poverty and creating green, local jobs if enabled by a strong financial and legislative framework.
The Central Association of German Construction Industries (ZDB) welcomes in principle the EU’s efforts to achieve the objective of climate neutrality by 2050. Given the existing greenhouse gas emissions in the building stock, this area can contribute to the achievement of the target through renovations.
Filed in German · English published by the European Commission
The European Association for External Thermal Composite Systems (EAE) strongly supports the European Commission’s Green Deal to make Europe the first net-carbon neutral continent by 2050. As the Commission pointed out in the inception impact assessment on the revision of the Energy Performance of Buildings Directive (EPBD) 2010/31/EU, the construction sector must play a significant role as it stands for 40% of…
SMEunited welcomes the initiative to revise the Energy Performance of Buildings Directive (EPBD) and believes that the third option presented by the Inception Impact Assessment can guarantee the achievement of the desired objectives; SMEs represent more than 90% of the businesses in the EU building sector.
To be in line with the Paris Agreement’s goal, the EU should reduce greenhouse gas emissions by 65% by 2030. This requires higher binding energy targets (at least 45% for energy efficiency and 50% for renewable energy) and to at least triple the current annual rate of energy renovations, increasing significantly their depth and moving towards a fully renewables-based energy supply.
POSITION PAPER Ref. Ares(2021)2019117 - 22/03/2021 22 MARCH 2021 EHP RESPONSE TO THE IIA ROADMAP ON THE EPBD Euroheat & Power, the association representing the district heating and cooling (DHC) sector in Europe and internationally, supports the European Commission’s intention to revise the Energy Performance of Buildings Directive (EPBD).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurogas welcomes the opportunity to provide input on the inception impact assessment for the Energy Performance of Buildings Directive. Within the broader context of the Renovation Wave, heating and cooling is central to our daily lives and comfort and pivotal for achieving the climate neutrality target. Given the size of the challenge, all options should be considered.
The EU Chapter of the World Green Infrastructure Network (WGIN) is the European section of a collaborative network that brings together national and regional industry associations and researchers to promote the incorporation of urban green infrastructure practice and planning, globally.
As buildings are expected to play a critical role in the decarbonisation efforts, it is important not only to ensure that EPBD is fully consistent with the entire legislative framework which is going to be addressed by the “Fit for 55 Package”, notably the EED, RED, ETD, ESR and a possibly extended EU ETS.
I Sverige står bygg- och fastighetssektorn för 33% av den totala energianvändningen och för 21% av växthusgasutsläppen. Ungefär hälften av dessa utsläpp kommer från själva byggverksamheten. Att minska utsläppen av växthusgaser och energianvändningen från bygg- och fastighetssektorn är därmed även ett viktigt mål i en svensk kontext.
In order to contribute to this objective, the Spanish Confederation of Metal Employers’ Organisations (Confemetal), which brings together various stakeholders involved in the renovation of buildings among its member organisations, considers, from a joint and comprehensive perspective, proposals for action on the renovation of facilities in both the residential and industrial fields, as well as as an enabler in many…
Filed in Spanish · English published by the European Commission
As an association active in the liquid heating fuels industry, we would like first to remind the many benefits they bring: easy to store and easy to transport, they have a high energy density, which means they are very efficient, and an excellent supply infrastructure. They are necessary for 20 million households in Europe, often in off-grid areas with limited options for heating.
> > Challenges: Gisad welcomes the European Commission’s initiative to improve the Directive on the overall efficiency of buildings. From the perspective of an overall digital strategy, the digital regulation of technical building systems is at the forefront.
Filed in German · English published by the European Commission
To: European Commission DG ENER Unit B3 ECIA Feedback on the Inception Impact Assessment on the revision of the Energy Performance of Buildings Directive 2010/31/EU Energy performance matters both for citizens and the environment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sir/Madam, with reference to a public consultations held by the European Commission on the proposal for an Inception Impact Assessment - Revision of the Energy Performance of Buildings Directive 2010/31/EU, attached please find comments of Polish Association of Professional Heat and Power Plants (Polskie Towarzystwo Elektrociepłowni Zawodowych).
FEEDBACK 22.3.2021 Vesa Peltola European Commission DG ENER Unit B3 (PLAN/2020/8667) Revision of the Energy Performance of Buildings Directive 2010/31/EU Feedback to the EPBD roadmap - AFLRA Introductory remarks Local and regional governments (LRGs) play a significant role in delivering goals on sustainable development, climate and energy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Electricity Futura warmly welcomes the consultation on the preliminary impact assessment on the revision of the European Directive on the energy performance of buildings. The Energy Efficiency First principle is one of the main pillars on which the European Union’s fight against climate change must be based and the aim of decarbonising the building sector will be crucial once buildings are responsible for 40 % of…
Filed in Italian · English published by the European Commission
The Walloon Region would like to submit its opinion on the draft amendment to the Energy Performance of Buildings Directive, due to be adopted at the end of 2021. In the impact assessment published under reference ARES (2021) 1397833, the following points call for comments from the Walloon Region.
Filed in French · English published by the European Commission
Finnish Energy (FE) believes that the revision of the EPBD should be coherently implemented within the “Fit for 55 Package”. A cost-efficient and technology neutral climate framework based on the EU ETS will prioritise climate action and bring transitions costs down. EU ETS is certain and efficient way to ensure emission reductions and would also minimise the costs for citizens.
Xella International GmbH welcomes the European Commission’s initiative to revise the Energy Performance of Buildings Directive and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. Xella Group is one of the leading, internationally operating solution provider of building materials and related industries.
Mandatory minimum standards for buildings A mandatory minimum standard for existing buildings should only be defined as energy demand per m² for the most inefficient buildings and alternatively as CO2 emissions per m². The renovation of buildings above the minimum standard should be encouraged and not prescribed by means of subsidies.
Filed in German · English published by the European Commission
Considering that almost 100 Million persons with disabilities live in the EU plus the even greater number of older persons, which will increase in the coming years, accessibility must be a priority. Making buildings accessible from the beginning or as part of a bigger renovation project is less costly and should be routine procedure.
Liquid fuels, such as heating oil, provide numerous benefits to consumers and to the wider energy system: they are easy to store and transport, have a high energy density, which means they are very efficient, and an excellent supply infrastructure. Thanks to the lower capital investment and running costs, heating oil systems are part of the solution against energy poverty.
UPEI supports measures to help decarbonise the heating sector, including the EPBD which contributes to higher-performance and comfortable buildings and reduced energy bills for citizens, as well as facilitates the acceptance of the energy transition.
Finnish Commerce Federation welcomes the opportunity to contribute to the development of energy and climate policies at the EU level. Investors already prefer sustainable businesses and, like companies, are committed to ESG and carbon neutrality. Time, know-how and money is invested to actions which strongly pursue carbon neutrality.
The European Copper Institute, representing the copper industry, welcomes the opportunity to provide input on the review of the Energy Performance of Buildings Directive. The copper industry is committed to support the decarbonisation of the building sector to achieve the objectives of the Climate Target Plan 2030 and the Renovation Wave communication.
The European Panel Federation (EPF) welcomes the Inception Impact Assessment on the revision of the Energy Performance of Buildings Directive 2010/31/EU as part of the “Fit for 55” package included in the Commission Work Programme 2021.
Belimo with its headquarters in Switzerland is the global market leader in the development, production, and sales of field devices for controlling heating, ventilation and air conditioning systems. Sensors, control valves and damper actuators make up the company’s core business. Founded in 1975, the company employs approximately 1,900 people in over 80 countries.
Dear Madam, Sirs, We suggest the following: 1. Require the use of the Commission’s Level(s) framework to assess and benchmark the sustainability performance of buildings. Reason: The framework has been embraced by the industry and is the result of a long testing procedure of the users. Currently, there isn’t a more fact-based, tried and workable assessment for sustainable building indicators. 2.
FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Revision of the Energy Performance of Buildings Directive (EPBD) 2010/31/EU” and the possibility to comment it. 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.
Knauf Insulation supports Option 3 – revision of the EPBD as a pre-condition to meet the objectives of EU Renovation Wave in combination with reinforced non-regulatory instruments such as technical assistance and project finance (Option 2). To that end, we propose the revision of the EPBD to include the following improvements: 1.
Fire Safe Europe (FSEU) is a unique alliance of fire experts, firefighters, associations, and international companies. FSEU’s mission is to improve fire safety in buildings for people and society. We believe that the EPBD Revision offers a once in a decade opportunity to capitalise on renovation investments by simultaneously improving energy-efficiency and fire-safety.
Kingspan supports the EU’s 2050 decarbonisation objective, and the crucial role the buildings sector has for us to get there, as highlighted in the Assessment. As identified by research, notably RAP in its 2020 study (Filling the policy gap: Minimum energy performance standards for European buildings.
EEB welcomes the Energy Performance of Buildings Directive (EPBD) revision to help achieve 2050 EU environmental objectives. EEB considers that an extensive revision of the EPBD should be done ensuring a better cohesion with the national Long Term Renovations Strategies and the Renovation Wave. Failing to do so will be a missed opportunity that could make it challenging to achieve the environmental targets.
Feedback to EPBD Inception Impact Assessment BPIE welcomes the opportunity to give feedback on the EPBD Inception Impact Assessment (IIA) in view of the revision planned in Q4 2021. The Commission has decided to open the EPBD for revision earlier than its planned review (by 1st January 2026 according to Article 19) to align legislation with the ambition of the Renovation Wave Strategy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
RECO (https://rekoforskning.se/) recognizes that improving the energy efficiency of the building stock is of vital importance to ensure climate goals, such as reaching a carbon neutral society in the EU by 2050. However, increasing the rate of energy efficiency measurements of existing buildings can conflict with other sustainability goals, for example goals that aim to preserve the built cultural heritage.
Build Europe Feedback on Energy efficiency – Revision of the Energy Performance of Buildings Directive Deadline: 22 March 2021 Build Europe and its members consider that the EPBD has been successful in achieving its goals of increasing the energy performance of new buildings.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ROCKWOOL fully supports an early revision of the EPBD (option 3) to become an effective tool to deliver on the Renovation Wave and to align ambition with the “fit for 55% package”, delivering 25 mio deeply renovated dwellings by 2030.
The Groupement du Mur Manteau (Groupement du Mur Manteau) is a professional organisation bringing together industrialists developing outdoor thermal insulation systems (ITE) wishing to accompany the ecological transition and to contribute to a drastic reduction in gas emissions caused by the sector.
Filed in French · English published by the European Commission
European Association for Wastewater Heat Recovery representing inventors, manufacturers and distributors of wastewater heat recovery solutions is committed to support the decarbonisation of the building sector and supports amendment of the EPBD to translate the actions proposed in the Renovation Wave and the increased ambition towards building decarbonisation into legislation and wishes to bring the following…
Cerame-Unie welcomes the initiative of the European Commission to revise the EPBD according to the new ambitions of the EU Green Deal, the Climate Target Plan 2030 and the Renovation Wave Strategy and hereby contributes with the perspective of the European ceramic industry for the ongoing impact assessment (attachment).
To comply with the Paris Agreement, the EU should reduce greenhouse gas emissions by 65% by 2030. This requires higher binding energy targets (at least 45% for energy efficiency and 50% for renewable energy) and to at least triple the current annual rate of energy renovations, increasing significantly their depth and moving towards a fully renewables-based energy supply.
EFBWW welcomes the revision of EPBD as an opportunity to improve some aspects of the existing regulatory framework. Because the potential for cost-effective energy savings is so high, the buildings sector has become a priority area for the EU to meet its ambitious climate and energy targets for 2020 and 2050. Today, buildings account for 40% of the energy consumed and for about 40% of CO2 emissions.
Hello The renovation wave launched by the committee is more than necessary in order to drastically reduce the carbon impact of the building, in this sense the revision of the EPBD is more than necessary; However, if we forget the purpose of the building, which is a place of life where we must feel safe, in particular health, and live comfortably, we will inevitably lead to unhealthy, uncomfortable, and even…
Filed in French · English published by the European Commission
AGFW, the German association for DHC (district heating and cooling) and CHP (Combined Heat and Power), welcomes the possibility to voice its opinion on the revision of the Energy Performance of Buildings Directive (EPBD).
There are currently a huge number of buildings in the EU that use more energy and emit more CO2 than any other sector of the EU economy. Without addressing the EU’s biggest CO2 emitters, buildings, the 2030 climate goal will be unachievable. Today only 1% of existing buildings undergo energy efficient renovation every year.
· · filed 19 Mar 2021 · same text as 1 other organization · source
Doubling the renovation rate of buildings is key for Europe to reach its higher climate targets, to kickstart a green recovery from the current economic crisis and to provide modern, healthy and comfortable places to live and work for all Europeans. We therefore strongly endorse the Renovation Wave agenda and welcome the EPBD revision.
More than 40% of the historical building heritage in Europe is privately-owned. The European Historic Houses (EHH) and the European Landowner’s Organisation (ELO), which speak for millions of family-owned heritage houses all over Europe represent some of the potentially most endangered and fragile houses which could be impacted by the recently launched Commission’s Renovation Wave initiative.
PlasticsEurope comments on the Inception Impact Assessment “Revision of the Energy Performance of Buildings Directive 2010/31/EU” 22 March 2021 PlasticsEurope welcomes and supports the European Commission’s statements that “The decarbonisation of the buildings sector is vital to deliver on the EU’s 2030 and 2050 climate and energy objectives, given that buildings are responsible for 40% of total energy consumption…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
More than 40% of the historical building heritage in Europe is privately-owned. The European Historic Houses (EHH) and the European Landowner’s Organisation (ELO), which speak for millions of family-owned heritage houses all over Europe represent some of the potentially most endangered and fragile houses which could be impacted by the recently launched Commission’s Renovation Wave initiative.
OUR MAIN MESSAGES IN SUMMARY 1)CEMR supports ambitious climate and energy targets in line with 2050 climate neutrality for the EU Member States (MS) and in non-EU countries where EU legislation applies. We emphasise the need to involve LRGs in both planning and implementation.
STARTING POINTS As yet, there is no evidence of success in terms of the 20-20-20 targets under the existing EPBD. FIEC understands the need to revise the EPBD to ensure alignment with the Climate Law. However, there is evidence, in the report "Lessons on the proportionality of the implementation of the EPBD directive 2010", undertaken by the Economic institute for construction and housing, of an increased burden for…
From BDI's point of view, it would be appropriate to maintain the existing requirements for new buildings until 2023 and only then provide for a review of the specifications. It is important that requirements for new buildings should only be developed further in accordance with the current state of technology and with an affordable time frame.
The Regulatory Assistance Project welcomes the opportunity to provide feedback on the EPBD Roadmap. Significantly strengthening the EPBD and broader energy efficiency and decarbonisation policies, is key to significantly raise the rate and depth of renovation this decade. We support ambitious implementation of option 3.
Preferring option 3 with a revision towards more energy efficiency in buildings. The sustainability over whole lifecycle of products shall be considered as well (e.g. with environment product declarations). In terms of circularity, environmentally friendly materials shall be preferred instead of chemically produced products with unclear possibilities for reuse or recycling (cascade usage).
The revision of the EPBD proposes to take into account the following aspects: 1. The climate zones of some colder regions, in which there are also significant exploitable reserves of natural gas, so as to continue to allow the transitional energy source to use natural gas, given that local renewable sources at building level cannot support the need for heating during the cold season, and the infrastructure for…
Filed in Romanian · English published by the European Commission
Friends of the Earth Europe fully supports the revision of this directive, as outlined in option 3, to deliver on the Renovation Wave and drastically reduce Europe’s carbon emissions. Renovations can provide extensive co-benefits for tackling climate change, alleviating energy poverty and creating green, local jobs if enabled by a strong financial and legislative framework. This revision comes at a pivotal time.
Doubling the renovation rate of buildings is key for Europe to reach its higher climate targets, to kickstart a green recovery from the current economic crisis and to provide modern, healthy and comfortable places to live and work for all Europeans. We therefore strongly endorse the Renovation Wave agenda and welcome the EPBD revision. The EPBD must be the core contributor to achieving the Renovation Wave’s aims.
Eurovent strongly supports policy option 3 to inscribe the ambition of the Renovation Wave initiative into legislation. The review should also focus on mainstreaming indoor environmental quality (IEQ) considerations into the Directive, for which a dedicated stakeholder workshop on IEQ should be convened.
As key stakeholders in the housing and real estate sectors, we fully acknowledge the importance of decarbonising the building stock and energy system. Property owners, be they owner-occupier households or individual/professional landlords, have a crucial role to play to contribute towards achieving the 2050 climate goals, and thus we, as an association, are committed to improve the energy efficiency of our stock and…
1- La nécessité d’évoluer vers une rénovation profonde : Les marchés ont atteint ces dernières années, grâce à l'impulsion de l’UE, des stades de maturité non négligeables en matière de rénovation énergétique des bâtiments.
Having assessed the document Inception Impact Assessment (Ref. Ares (2021) 1397833), Andimat (National Association of Aislantes Manufacturers) considers it necessary to bring forward the revision of the EPBD for this year 2021 and supports Option 3 Amend the EPBD to translate the actions proposed in the Renovation Wave and the incriminated ambition towards building decarbonisation into legislation.
Filed in Spanish · English published by the European Commission
Homelessness in the EU has increased by 70% in the last decade. It stands at around 700,000 people (level expected to increase as countries lift moratoriums on evictions put in place during covid). Eurostat reports that over the period 2007-2019 rents have increased by 21.0%. This increase has been decisive is fueling homelessness & housing exclusion.
Health Care Without Harm (HCWH) Europe welcomes the opportunity to feed into this IIA. Our changing climate is already having a significant impact on our health through, for example, extreme weather events, changes in communicable diseases, and respiratory illnesses exacerbated by poor air quality. According to The Lancet, climate change is the “largest public health threat of the 21st Century”.
· · filed 18 Mar 2021 · same text as 1 other organization · source
Doubling the renovation rate of buildings is key for Europe to reach its higher climate targets, to kickstart a green recovery from the current economic crisis and to provide modern, healthy and comfortable places to live and work for all Europeans. We therefore strongly endorse the Renovation Wave agenda and welcome the EPBD revision.
EuroWindoor welcomes the opportunity to comment on the Inception Impact Assessment on the Revision of the EPBD in the attached document. We believe that the upcoming revision is an opportunity to secure the introduction or the update of a coherent set of measures that will enable the green transition and benefit all Europeans.
EDA Attikis S.A, the natural gas DSO operator in the region of Attica (Greece) welcomes the Commission’s initiative to enhance the Energy Performance of Buildings Directive In this perspective we suggest a “Natural gas heating system/Appliance Recycling Program”.
GBCe believes that this revision is necessary and stands for the Option 3 Amend the EPBD to translate the actions proposed in the Renovation Wave. Also: • The 2030 Climate target plan acknowledges that in other to achieve a 55% reduction of GHG buildings and power generation can make the largest and most cost-efficient emissions reductions, in the order of 60% and more compared to 2015.
The Right to Energy Coalition unites a diverse range of stakeholders to tackle energy poverty across Europe. We fully support the revision of this directive, as outlined in option 3, to deliver on the Renovation Wave and drastically reduce Europe’s carbon emissions.
ANEC clearly favours ‘policy option 3’; the amended EPBD is to address in particular the following 7 key aspects among the measures considered: - The update of the framework for Energy Performance Certificates is fundamental.
BEUC welcomes the European Commission’s plan to improve energy efficiency of the EU’s building stock through the revision of the Energy Performance of Buildings Directive. Making buildings more efficient will be a quadruple win for consumers: it will contribute to fight climate change via lower energy consumption and greenhouse gas emissions; to lower energy bills; healthier and more comfortable indoor and outdoor…
The Federal Chamber of Architects (BundesArchitektenkammer — BAK) is of the opinion that the issue of renovation, conversion and further use of existing buildings should be given greater priority over the issue of new buildings, as there is considerable potential for energy savings, efficiency gains and the use of renewable energy sources that still needs to be mobilised for climate protection.
Filed in German · English published by the European Commission
Naturgy welcomes the opportunity to provide feedback on the inception impact assessment for the Energy Performance of Buildings Directive, within the context of the Renovation Wave. Conventional and new Gaseous solutions should be part of the solutions for decarbonising and increasing efficiency in the EU building sector, which represents 40% of total energy consumption.
Confcommercio – Imprese per l’Italia Comments to the Commission Initiative “Energy efficiency – Revision of the Energy Performance of Buildings Directive” In relation to the revision of the directive on energy performance of buildings, Confcommercio Imprese per l'Italia agrees with the Commission in affirming that the European climate objectives also rightly apply to the redevelopment of the building stock.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Energy Performance of Buildings Directive (EPBD) is the backbone of the European Union policy for energy efficiency in buildings. Glass for Europe, the trade association of Europe’s flat glass sector, believes that the EPBD should be amended (option 3) to translate into legislation the Renovation Wave and tackle the inefficiencies which have been overlooked during the 2018’s review.
STATEMENT OF REASONS 1. The optimal cost-effective solution for converting the built stock into NZEB in line with the requirements of the EPBD already in 2012, as subsequently revised 2018, is the use of insulation in all new and existing buildings. 2. At EU level, in 2050, 75-90 % of buildings will remain in use and will only be rehabilitated once more by 2050.
Filed in Spanish · English published by the European Commission
The Public Waste Agency of Flanders (OVAM) underlines the importance of amending the EPBD (option 3). We agree that the EPBD should include the actions proposed in the Renovation Wave and the ambition towards building decarbonisation.
The Intergovernmental Grouping Bauernhaus eV (IGB) very much welcomes the fact that, for the first time, the document on the renovation wave makes conservation so clear as a decisive factor in climate protection. However, we find it worrying that explicit protection of built cultural heritage is not addressed. The IGB fears negative effects on the appearance of building monuments.
Filed in German · English published by the European Commission
The European Autoclaved Aerated Concrete Association (EAACA) welcomes the European Commission’s initiative to enhance the Energy Performance of Buildings Directive and would like to thank the Commission for the opportunity to provide its views on the associated roadmap. EAACA promotes the interests of producers of autoclaved aerated concrete (AAC) and their national associations across Europe.
The energy consumption of professional kitchens is one of the largest energy consumers in restaurants, hotels or even office buildings. Technically, there is potential for improvement. However, these are poorly implemented as the industry and developments are misunderstood. A proactive cooperation with policymaker would be better than an intervention against the industry.
The improvement of energy performance of buildings is of major importance. With 40% of total energy consumption stemming from the buildings, this is without a doubt one of the key goals. However, so far, the EU addresses building efficiency only in relation to the building size, but not in relation to the occupants.
When making amendments to the policies, the local governments should be stimulated to search for solutions that are long-term and that stimulate the creation of partnerships in the country that could lead to the systematic renovation of buildings.
We recognize the importance of this initiative, which is opportunity for scaling up current renovation rates and bringing benefits for citizens and businesses, from consuming less energy to healthier homes, and saving money. However, the initiative should keep in mind that the principle of technological neutrality when selecting a type of heat source should be preserved.
Buildings are a central element of the daily life of Europeans by providing a space to live, learn and work. Indeed, research suggests that Europeans spend over 90% of their time indoors, so our health and well-being strongly depends on how these buildings are built, maintained and renovated.
REMARKS OF BAUINDUSTRIE ON THE EPBD ROADMAP Preliminaries - In 2050, the goal of ZERO emissions applies to all sectors. In view of the long-term nature of investments in the building sector, this must therefore be the target line for every building, which must be considered today in every measure.
Feedback from AICVF AICVF is the French association for HVAC professionals and is member of the European REHVA association. AICVF is supporting the REHVA position in the revision of the EPBD. Please find hereafter our feedback and proposals for possible solutions on the intended initiative.
Hello, Firstly, it would be interesting to know the different European building stock (by country): — volumes — Types: Industrial, institutional, housing, historical (heritage) — ‘quality’: Physical and thermal condition This would make it possible to have a better view of the renovation emergencies, both from the point of view of the Member States and of the populations concerned.
Filed in French · English published by the European Commission
We think the main problem with the Energy Performance of Buildings Directive has been the neglect of the importance of the water-energy nexus in buildings. However, the problem must be approached differently in relation to other components of housing (climatization, household appliances, etc.), as water consumption in buildings has implications not only for energy consumption in the building (production of sanitary…
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