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Revision of the Cost-Optimal Methodology framework for calculating minimum energy performance requirements for buildings

Energy

By 30 June 2025, the Commission shall revise the comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for new buildings and existing buildings undergoing major renovation, and for individual building elements (as established in Directive 2024/1275/EU (EPBD), Article 6(1)). To this end, the Commission will adopt a delegated act in accordance with Annex VII to the EPBD.

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Public consultation

ID: 14395

Lobbying Activity

28 responses

EDF Urges Tech Neutrality in Building Energy Methodology

ELECTRICITE DE FRANCE, 7 May 2025

EDF wants the rules to include low-carbon energy and district heating to ensure technological neutrality. They propose limiting emission forecasts to five years to prevent reliance on fossil gas boilers. Finally, they suggest hourly modeling for better tracking of renewable energy use.
These changes would promote EDF's nuclear-based electricity and favor heat pumps over gas.
Gas companies and biomethane suppliers lose as the rules discourage new gas infrastructure.

Bioenergy Europe urges financial perspective for building energy standards

Bioenergy Europe, 7 May 2025

The organization advocates for a financial perspective rather than a macroeconomic one when establishing national benchmarks. They also demand that the methodology recognize on-site biomass combustion as renewable energy produced on-site to ensure legislative consistency.
Bioenergy remains competitive by excluding health and environmental costs from the performance calculations.
Public health groups lose if air pollution costs are omitted from national energy benchmarks.

Liquid Gas Europe opposes pollutant costs in building energy rules

Liquid Gas Europe, 7 May 2025

Liquid Gas Europe opposes pollutant costs, proposing a minimum emission threshold for exemptions. They want the framework to recognize BioLPG and update emissions databases.
This avoids financial penalties that would make liquid gases less competitive than electricity.
Electric appliance manufacturers lose the competitive advantage of zero tailpipe emission ratings.

Insulation industry urges EU to prioritize building fabric improvements

European Insulation Manufacturers Association, 7 May 2025

The association wants 'emission performance' anchored to annual savings to prevent electrification bias. They also propose a 50-year calculation period to capture long-term insulation benefits.
Proposed changes would shift focus from short-term equipment to long-term insulation products.
The renewable energy sector may lose subsidies if grid electricity is not considered carbon-free.

FEANTSA urges EU to include health in renovation calculations

Fédération Européenne d'Associations Nationales Travaillant avec les Sans-Abri, 7 May 2025

FEANTSA calls for systematically incorporating social benefits into the methodology for calculating energy performance requirements. They argue health impacts from improved housing can significantly offset renovation costs.
Including health benefits justifies more public investment into housing for the low-income groups FEANTSA supports.
National treasuries would face higher immediate costs for fully subsidizing energy renovations for low-income citizens.

Solar Heat Europe urges equal valuation for renewable heating

Solar Heat Europe/ESTIF, 7 May 2025

The organization seeks a level playing field between heat and electricity in building energy calculations. They advocate that on-site renewable energy should be deducted from primary energy demand regardless of the energy type.
This would increase market opportunities for European solar thermal technology manufacturers.
Foreign technology suppliers lose as the proposal prioritizes European-made renewable energy solutions.

Glass for Europe backs realistic lifespans for energy calculations

Glass for Europe, 7 May 2025

Member States should consider insulation and solar gains when assessing glazing. The role of operable windows in maintaining healthy indoor environments must be recognized. The regulation should explicitly link cost calculations to future global warming assessments.
Broader performance metrics and longer calculation periods would boost demand for high-performance glass.

Consultation response

European Building Automation and Controls Association, 7 May 2025

Please find attached the contribution from the European Building Automation and Controls Association (eu.bac).

EPRA urges harmonised energy standards to drive green investment

European Public Real Estate Association, 7 May 2025

Promote consistent transposition of performance requirements and definitions across Member States. Reflect actual market diversity and use lower discount rates for valuations. Align national frameworks with recognised tools and voluntary disclosure frameworks.
Harmonised rules would lower compliance costs and increase investment certainty.
Diverse asset classes lose out as policy incentives favor specific typologies.

UIPI urges national flexibility in building energy performance methodology

Union Internationale de la Propriété Immobilière - International Union of Property Owners, 7 May 2025

UIPI requests that Member States retain the choice to calculate energy requirements from a purely financial perspective. They argue countries should use local data for energy and technology prices to reflect specific market conditions.
This flexibility helps property owners avoid higher costs associated with macroeconomic environmental calculations.
Environmental and health sectors lose if broad social benefits are excluded from performance calculations.

LightingEurope demands adequate consideration for lighting in building methodology

LightingEurope, 7 May 2025

LightingEurope reemphasizes the necessity of adequate consideration for lighting in this methodology. They urge the Commission to reference standards that include lighting elements.
This would foster a regulatory environment that promotes growth for European lighting manufacturers.
Environmental groups lose as energy targets are weakened by the methodology's limited scope.

Consultation response

European Ventilation Industry Association, 7 May 2025

Please find attached the contribution from the European Ventilation Industry Association (EVIA)

Consultation response

Climate Alliance of European cities with indigenous rainforest peoples, 7 May 2025

Please find attached the contribution from Climate Alliance.

Consultation response

Deutsche Unternehmensinitiative Energieeffizienz e.V., 7 May 2025

DENEFF welcomes the proposed delegated regulation and the Commissions intention to align the cost-optimality framework with the EU Climate Law and the recast of the EPBD. We offer the following remarks to strengthen consumer protection, investment certainty and climate delivery while keeping the…

Consultation response

Public Housing Sweden, 7 May 2025

Please find attached the contribution from the Public Housing Sweden Association.

Eurovent calls for including indoor air quality in cost-optimal calculations

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 7 May 2025

Eurovent argues that the cost-optimality framework must account for positive effects on indoor environmental quality. They request clear guidance for monetising health-related benefits like improved productivity and quality of life.
Broader assessments would demonstrate that Eurovent's high-efficiency climate systems are more cost-effective.

Consultation response

Buildings Performance Institute Europe, BPIE ASBL, 23 Apr 2025

BPIE's feedback is attached in the enclosed PDF.

Consultation response

Swedish Property Federation, 2 May 2025

Se enclosed file

Consultation response

Cool Heating Coalition, 5 May 2025

The Cool Heating Coalition welcomes the revised methodology to calculate minimum energy performance requirements, but would like to highlight a few concerns and key points to be taken into consideration. Please find the full contribution in attachment.

Consultation response

Österreichischer Biomasse-Verband, 7 May 2025

Please find attached the contribution from the Austrian Biomass Association.

Consultation response

Swedish Association of Local Authorities and Regions, 5 May 2025

The Swedish Association of Local Authorities and Regions (SALAR) finds the proposed regulation problematic, regarding a lack of technology neutrality and a disregard of the effects of the energy system at large. This concerns how to regard solar energy and how to apply emission factors to…

Consultation response

GCP Europe, 7 May 2025

Please see the attached document for the Swedish Installation Federation's feedback on the draft delegated act.

Consultation response

Suomen Kiinteistöliitto, 7 May 2025

Please find attached the contribution from the Finnish Real Estate Federation.

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 6 May 2025

HKI, the Industry Association of House, Heating and Kitchen Technology represents manufacturers of domestic heating and cooking appliances across Europe. The debate on including external costs, such as fine particulate matter (PM2.5) and nitrogen oxides (NOx) emissions, in the energy performance…

Consultation response

Fachverband Gebäude Klima e.V., 7 May 2025

Please find attached the contribution from Fachverband Gebäude Klima e.V..

Czech District Heating Group Demands Fair Energy Performance Metrics

Association for District Heating of the Czech Republic, 7 May 2025

ADH CR requests allowing national metrics like non-renewable primary energy. They also demand treating nearby renewable energy the same as on-site production. This ensures technological neutrality between district heating and local heat pumps.
This ensures district heating remains a viable, cost-effective option compared to on-site alternatives.
Providers of on-site technologies lose the competitive advantage granted by biased energy accounting rules.

Eurofuel Urges Inclusion of Renewable Liquid Fuels in Building Methodology

The European Liquid Heating Fuels Association, 6 May 2025

The organization calls for the explicit inclusion of renewable liquid fuels in building assessments. They demand mandatory lifecycle emissions calculations and realistic heating solutions for off-grid homes.
This would preserve the market for liquid fuel products in existing heating systems.

Consultation response

UNICLIMA, 6 May 2025

Add « and ventilation » at the end of definition « conditioned space » in the delegated regulation draft, article 2 (24). Indeed, ventilation also has an impact on temperature and humidity. Energy recovery ventilation allows to pre-heat or pre-cool passively the air which is introduced in the…