Fastighetsägarna

Fastighetsägarna welcomes the European Commissions ambition to establish a Circular Economy Act as part of the Clean Industrial Deal. The property and construction sector supports this transition but stresses that circularity must be built on value creation, prevention and market functionality, not on new administrative layers or overlapping quota systems.

Ensuring carbon neutrality and fostering the energy transition is a key societal challenge. Property owners, be they owner-occupiers or individual/professional landlords, are not only key stakeholders in the housing and real estate sectors, they also are consumers, as well as potentially producers of renewable energies helping households and businesses to reduce their energy costs and their environmental footprint.

General comments The property owners consider that properly designed and incentive-based policies to improve the energy efficiency of the building stock are an essential prerequisite for the continued contribution of the real estate industry to set energy and climate targets.

Filed in Swedish · English published by the European Commission

Swedish Property Federation on the proposal for a directive on Energy efficiency (EED) (recast) November 2021 KEY MESSAGES Energy efficiency has been identified as a key area of action in order to reach full decarbonisation by 2050 and all sectors, including our sector, the building sector, will need to contribute.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Summary of our key comments (also see attached file) We have no objections to the proposed amendments where no specific comments are provided below. For activity 7.1, we highlight the lack of robust reference data for life-cycle GWP calculations and request clarification of the purpose and scope of on demand disclosure.

Fastighetsägarna welcomes the Commissions initiative to develop an Electrification Action Plan. As property owners, we represent a key sector that both consumes and enables electrification through buildings. We fully share the objective of increasing cost-effective, system-friendly and competitive electrification. Against this background, we would like to highlight the following points: 1.

Fastighetsägarna welcomes the Commissions initiative to develop a Heating and Cooling Strategy. We would like to highlight the following points: 1. Stronger consumer protection in district heating monopolies ensures affordability and competitiveness. District heating is a natural monopoly in most Member States. Consumers cannot change supplier, which requires stronger protection than currently in place.