OpenLobby.EU
Explore

Danfoss A/S

Danfoss is a global leader focused on energy-efficient solutions that save energy and costs, and reduce carbon emissions.

Lobbying Activity

Response to Standardisation Strategy

9 Jul 2021

Please see attached file with comments
Read full response

Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

5 Apr 2021

Thank you for the opportunity to comment. Danfoss is a leading provider of energy efficiency solutions across a wide variety of sectors. As such, efficiency is part of our DNA and the core of our product know how. To reach EU Climate targets we must do two things: 1) cut energy consumption, and 2) cover the remaining demand efficiently with renewable energies. Energy efficiency is thus key on the primary as well as on the secondary side and we very much support the Commission’s Energy Efficiency First principle. At the same time the EU needs to recover from the covid-19 crisis, and kickstarting Green Recovery is and must be the focus of the European Commission today. To answer these challenges from climate change and covid-19, unprecedented investments in our energy systems are needed. Both on the supply side and the demand side. To trigger these investments it is important to remove all obstacles hindering them, and in the area of energy efficiency, one of those obstacles can be the State Aid regulation. Therefore Danfoss fully supports the planned revision of the GBER. Our key points from practical experience are as follows. 1. State-Aid and Energy Efficiency First are two conflicting principles As the building sector is by definition of mainly local impact, which in turn means that the ability to distort competition is very low. At the same time, the buildings sector is very hard to decarbonize without funding. GBER should include all efficiency measures for buildings As the building sector is key for decarbonization as well as for the green recovery, national funding schemes on renovating building stock should in general not be classified as state aid. This would mean funding applications will not need all the declarations and information usually needed (de-minimis declarations, cost splitting on additional cost for the efficiency investment etc.). 2. State Aid intensity for energy efficiency measures need to be the same, as applying for Renewable Energies (Art 38 GBER; EEAG, Annex 1) The funding intensity of energy efficiency measures is usually limited to 30%. For renewable energies, this has been increased to up to 100% because they are considered key to decarbonizing our economies. As energy efficiency is equally key and needed on the primary and on the secondary side, it would be consistent to increase funding intensity for efficiency to the same levels as for RES. 3. Make ESCOs eligible for funding and remove prohibitive framework (Art 38 GBER; Art 39 No4 GBRE) Energy services are an important tool to implement energy efficiency in markets. In some areas they are also a key tool to solving the issue of split incentives. To solve both, equal access to government funding is needed for ESCOs and they need to be treated as their customer would be treated if no ESCO would be used. The Commission should give clear guidance to Member States on ESCOs, and the EED revision should ensure Member State regulations do not create disadvantages for ESCOs, including State Aid schemes discriminating against ESCOs. 4. The framework for eligible cost is way too complex, simplification is needed (Art 38 GBER) For building efficiency measures as well as for industry measures, full project cost should be eligible cost – from here it would be up to the Member States to define a funding quota (in the past funding schemes remained unused as the framework was too complex.)
Read full response

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

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 . With only 1% of European buildings undergoing energy renovations each year, the scale of the challenge is clear. The Renovation Wave strategy acknowledges this problem and the need to increase the rate and the depth of renovations setting the objective of at least doubling the annual energy renovation rate by 2030. As Danfoss, we therefore welcome the work of the Commission in revising the Energy Performance of Buildings Directive (EPBD) as part of the ‘Fit for 55 Package’. It is a much-needed opportunity to increase energy savings, optimize energy consumption and reduce GHG emissions from the building sector across new builds and, not least, existing building stock. At the same time, the building sector and renovation have been identified as the most suitable lever to support a swift, economic recovery from the COVID-19 pandemic by creating sustainable growth, local jobs and delivering multiple benefits to citizens. Buildings account for 40% of energy use in the EU, and heating and cooling is responsible for around 50-80% of that energy consumption. Three quarters of heating and cooling in buildings is still supplied from fossil fuels. That means that increasing the ambition for decarbonizing the building stock with efficient and renewable heating and cooling solutions such as heat pumps, district energy and building automation and controls that optimize the performance of the systems in buildings will have to sit right at the heart of the recast. Furthermore, while we welcome the increased ambition and planned revision of the EPBD, it is equally crucial that the existing EPBD is properly implemented. Even though the deadline for transposition was 10th of March 2020, many Member States have still not fully implemented this legislation. This results in uncertainty for investors and professionals. As an example, all non-residential buildings, existing and new, with an effective rated output > 290kW, will have to be equipped with certain BACS capabilities by 2025. Some Member States did not implement this measure at all, while others implemented it but without providing any “clearly identified, framed and justified” parameters for defining feasibility nor specifying how to identify whether a BACS can implement the capabilities required by the Directive . According to the Waide Study on the “Impact of the Revision of the EPBD on energy savings from the use of building automation and controls”, if implemented properly, only the BACS measures approved in the revised EPBD (in articles 8, 14 and 15) would lead to savings corresponding to 14% of the total building energy consumption, with 64 Mt CO2 annual savings and €36 billion energy bill savings triggered. We therefore urge the Commission to ensure full implementation of the Directive in the Member States, as well as strengthening the existing BACS measures, in the next EPBD revision. We enclose detailed feedback.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Danfoss is pleased to contribute to the consultation on the delegated act of the Taxonomy regulation. Please refer to the document attached to see our position.
Read full response

Response to Empowering the consumer for the green transition

22 Jul 2020

We appreciate the aim to strengthen the role of consumers in the green transition. We encourage policy makers to be aware that there are major differences between the consumer market and the professional (industry) market. When applying new rules, be careful not to impose requirements to the professional market that are not suitable for this sector. For both sectors, clear rules provide for a level playing field. It is important to ensure fair competition, also towards products coming from outside the EU. No rules should be set without ensuring appropriate market surveillance. When establishing requirements for more information, companies should be able to deliver this in digital format, as this is the most effective and efficient way to provide and maintain information – and for the consumers or users to find it. Avoid imposing new labels, as some products are already met with many label requirements, but make sure that any labels or other green claims are substantiated and verified. Option 2 includes the possibility to set specific requirements for information on durability. Whereas this may make sense for consumer products, that are typically consumed under comparable conditions, this is often not the case for industrial products, where there is often a big variance in operating conditions (operating hours, environmental conditions etc.). Rather than requesting mandatory information on durability, regulation should specify requirements to format and content if the manufacturer choose to provide information on durability.
Read full response

Response to Methodology for assessing the potential for efficient heating and cooling

10 Jan 2019

Danfoss welcomes the initiative of the Commission to revise the rules of the national assessments on efficient heating and cooling under Article 14 EED (2012/27/EU). Revising the rules and methodology in Annex VIII is crucial to align the reports with technology and policy developments as well as lessons learnt in the first reporting period. Conducted properly, the national assessments can be a valuable instrument to leverage the potential of efficient heating and cooling solutions, especially efficient district heating and cooling (DHC). We believe the published draft of the Commission will lead to a better quality of the second cycle of comprehensive assessment reports that are due by 31 December 2020. Nevertheless, Danfoss calls upon the Commission to consider the following points to improve the quality of the reports further: • Waste heat: The assessment of the waste heat potential should not be limited to waste heat from industry; it should include waste heat from the tertiary sector (covering e.g. supermarkets and data centers), in line with the definition of “waste heat and cold” in the new Renewable Energy Directive (EU) 2018/2001). We suggest to include a new point 2 (b): vi ‘tertiary sector, according to Art. 2 (9) RED II, other than specified under point 2 (b)(iii);’. The same is the case respectively for part III point 7 (a). To facilitate reporting, certain thresholds for the installations that produce waste heat could be introduced. • Refurbishment of existing heating and cooling networks: There is a big potential to upgrade existing DHC networks, to improve their energy efficiency and suitability for the introduction of low temperature heat sources and sector coupling. The market is still below its potential. Thus, we support the notion of DHC improvements in part II point 5 and the inclusion of the potential to reduce heat losses in part III point 7 (f). However, we call for the explicit mentioning of the list considered in the Governance Regulation (EU) 2018/1999, including under point (b) ‘strategies for the expansion of efficient district heating and cooling and cogeneration; consideration of options to increase the efficiency of district heating and cooling systems, upgrading of existing district heating and cooling grids’. • Separation of heating and cooling: Heating and cooling demands and the technologies used to cover these demands are of a very different nature. To ensure that cooling is taken into account in the national assessments in a meaningful way, we suggest listing cooling (technologies) under a separate point (inserted as point 2 (a bis)). • Differentiation of supply options: The current differentiation of options under point 2 (a) lacks clarity and leaves room for interpretation. The differentiation is not exclusive and allows for various competing ways of reporting. This could lead to double counting. We suggest a new list that a) reflects the difference between onsite and district energy solutions and b) ensures that all viable options can be reported in a clear and distinguished way. • Consideration of power-to-heat potentials: Utilising renewable electricity in District Heating and Cooling is one option that will contribute to the decarbonisation of heating and cooling. Accordingly, we suggest to add this highly relevant area with a focus on the utilisation of renewable electricity used in heat pumps or boilers in district energy systems. We call for an inclusion of the respective point in point 2 (a). The same is relevant for part III point 7.
Read full response

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

5 Jul 2018 · CLEAN MOBILITY PACKAGE

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

5 Jul 2018 · clean mobility package

Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

The Water Framework Directive (WFD) is the main instrument of EU water policy, its objective being to protect and enhance freshwater resources. This objective is seriously threatened by shrinking resources, pollution and rising pressure on freshwater, resulting for example from increasing abstractions and effects of climate change (such as rising temperature and droughts). Moreover, the high energy intensity of the water sector presents a growing challenge that EU water policy does not address. At the same time, technological progress and innovation offer new opportunities for more sustainable water management. Therefore, we welcome the planned fitness check of the WFD and ask the Commission to take the below challenges (and solutions) into account: Shrinking resources and leakage: Abstractions for drinking water are a serious pressure on freshwater resources and contribute to their deterioration. The reduction of freshwater quantity has a negative effect on the quality (leading for example to higher concentration of pollutants). This is as well a threat for the provision of sufficient supply of good quality water for e.g. drinking water. A logic measure to reduce abstractions is to reduce leakage in water distribution systems. Water losses in public supply are estimated at a staggering 24% in the EU, amounting to 13bcm (IEA WEO 2016). High energy intensity: The energy consumption of the EU water sector (including extraction, distribution and treatment) is equivalent to ca. 3.5% of EU electricity consumption. In municipalities, water and wastewater facilities can account for 30-50% of the total electricity bill. The increasing complexity of pollutants and stronger requirements for the treatment of drinking and waste water might further increase the energy need of the sector. Still, the role of energy in the water sector has been widely neglected in EU water policies. We recommend that the fitness check investigates the following aspects: • Is the Directive fit to solve the growing challenges for freshwater resources and water services, such as shrinking resources and dependence on high amounts of energy? What is the potential to extend the scope of the Directive and complement its measures and tools? • How well has the Directive promoted the reduction of leakage in drinking water distribution systems? The Fitness Check of EU Freshwater Policy from 2012 stated that the WFD shows a gap when it comes to measures that target drivers of decreasing freshwater quantity. • What is the potential to link the monitoring of surface water and groundwater status (quality and quantity) in the WFD to the monitoring of the quality of discharged waste water (UWWTD) and potential new requirements in the DWD on the monitoring of leakage rates? A systematic and integrated monitoring approach could give a full picture of the water cycle and allow to detect the sources of pressures and potential solutions. • Is the WFD coherent with EU climate, environment and energy policies and objectives? The water sector can make an important contribution to targets for energy efficiency, CO2 reduction and renewable energy, as well as resource efficiency and the circular economy, while making the sector more sustainable. • Economic aspects: o Besides requiring water pricing policies that lead to a more efficient use of water by end-users, does the WFD promote incentives for water service providers, such as drinking water companies, to use water more efficiently? o Measures to reduce leakage in distribution systems are a cost-effective way to improve quantity and thus quality of water resources – have they been taken into account by Member States? Is there a need for the Commission to provide more guidance to Member States on cost-effective measures to reduce water use? To read the full feedback, see the attached file.
Read full response

Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)

9 Nov 2017

Danfoss welcomes the Commission’s understanding of the problems related to the UWWTD, i.e. that there are new challenges (and opportunities) that the current version does not address; namely depletion of resources, technological progress, and the development of a European circular economy. Nonetheless, we believe that there is an additional challenge that should be underlined: the dependence of waste water treatment on large amounts of energy. Waste water collection and treatment is a highly energy intensive process. Today, the energy consumption of the EU water sector (including extraction, distribution and treatment) is equivalent to ca. 3.5% of EU electricity consumption. In municipalities, water and wastewater facilities can account for 30-50% of the total electricity bill. The increasing complexity of pollutants and stronger requirements for treated waste water might further increase the energy need of the sector. As might the increasing demand for waste water treatment resulting from decreasing resources of fresh water. Still, the role of energy in the water sector has been widely neglected in EU legislation. It is realistic to cut the net energy consumption of the whole water segment (both water supply and wastewater handling) by at least 50% (by a combination of energy efficiency measures and energy recovery). Larger water facilities (which usually treat more than 50% of the total load in a country) can be made energy neutral and smaller facilities can cut energy use by 30-50%. We are convinced that the scope of the current Directive is too narrow to meet the above challenges and should therefore be extended to include objectives and measures to achieve energy neutrality, limiting both the greenhouse effect and contributing to the circular economy. We support that the evaluation will investigate the following aspects: • (under effectiveness) How well the Directive promotes wastewater treatment plans to be neutral from GHG emissions and become net energy producers; considering that there is a significant potential to reduce energy consumption of the water sector and produce biogas from sludge. • (under relevance) To what extent the Directive is relevant to achieve a circular economy in the EU and in the light of the Sustainable Development Goals in 2030. Noting that goal 6 is about ensuring sustainable management of water; and that EU water legislation does so far not take into account the potential to improve energy efficiency in the water sector. • (under coherence) The coherence with related legislation; the evaluation should as well include coherence with the EU’s overall climate and energy targets and the circular economy. In addition, we think it is of utmost importance that the evaluation does the following: • Evaluate the state of the market by collecting data on energy efficiency in the EU water and waste water sector. So far, waste water facilities do not have to monitor and report their energy performance; therefore, there is a lack of information and data. • In hand in hand with the first point goes the need for transparency for consumers and the public: especially considering that it is taxpayers’ money that is spent ineffectively when energy is wasted in the water sector. • Investigate the possibility to ensure compliance with the help of continuous monitoring of the water quality by the waste water facility (possible with smart process control), as an alternative to the collection of samples by responsible authorities or bodies. More information in the attached file.
Read full response

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

8 Sept 2017 · water framework Directive + the Energy Performance of Buildings Directive

Meeting with Dominique Ristori (Director-General Energy)

5 Sept 2017 · Clean Energy for All Europeans package

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

8 Feb 2017 · EU policy framework on water

Meeting with Dominique Ristori (Director-General Energy) and European Alliance to Save Energy

9 Dec 2016 · energy efficiency and ecodesign

Meeting with Kilian Gross (Digital Economy)

8 Sept 2016 · energy union

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

12 Feb 2016 · energy efficiency initiatives and follow-up to the heating and cooling strategy

Meeting with Dominique Ristori (Director-General Energy) and European Alliance to Save Energy

30 Nov 2015 · Energy Efficiency