Deutsche Unternehmensinitiative Energieeffizienz e.V.
DENEFF
Die DENEFF ist das erste unabhängige, industrieübergreifende Netzwerk von Vorreiterunternehmen der Energieeffizienzbranche in Deutschland zur gemeinsamen politischen Interessensvertretung.
ID: 19736167705-91
Lobbying Activity
Response to Electrification Action Plan
8 Oct 2025
In times of the continuation of inefficient fossil-based energy consumption at high levels, high electricity prices, vast untapped energy saving potentials, and the uncertainty regarding OPEX switching from fossil to electricity a dedicated strategy is essential. While the Commission identifies key challenges, critical gaps persist: the vast efficiency potential across buildings and industry remains largely untapped. In Germany alone, 226 TWh/a of industrial process heat could save the industry up to 21 bn /a, further 153 TWh/a could be saved in decentralised heat supply. These potentials must be activated to ensure a secure, affordable and climate-neutral energy system. Otherwise, unchecked electrification risks overloading power grids, increasing costs and fuelling a subsidy spiral. Energy efficiency significantly reduces energy bills, mitigates investment needs in generation and infrastructure, and supports climate neutrality. Moreover, Europe is already a technology leader in green and power-based process heat technologies. Tapping these potentials would strengthen the domestic market (up to a 22-fold increase), secure up to one million new jobs, and create long-term value. Key Facts and Challenges: Industrial process heat accounts for two-thirds of final industrial energy use and three quarter of the industrys CO2 emissions. Electrification is in most cases the efficient decarbonisation path. 42 TWh/a could be saved through direct electrification, further 167 TWh/a through classical efficiency measures (e.g. process optimisation, control systems, insulation, waste heat reuse) in total 44% of the industrys final energy demand in Germany alone without cutting output. If they wont be implemented, Germanys electricity system must cover these 167 TWh/a additionally significantly increasing system expansion needs, costs, and energy prices. This illustrates electrification without efficiency is inefficient and unaffordable. Buildings: Efficiency measures reduce peak loads, cut consumption, and act as thermal storage. Without them, Germany alone would need an extra 98 GW of capacity and 153 TWh/a electricity, equal to ~200 new gas plants. Barriers persist: Massive delays in grid connections, unclear standards, low renovation rates (<1%), unfavourable gas-to-electricity price ratio, and lack of support for ESCOs, SMEs, and vulnerable households hamper progress. Our Recommendations: Energy Efficiency First operationalise and enforce Embed the principle into all planning and funding processes: prioritise efficiency when more cost-effective than supply-side investments. Enforce EED and EPBD, including MEPS and binding application of Article 3 EED. Establish an EU-wide governance system (scoreboards, reporting, infringement procedures) to ensure accountability. Make electrification efficient and affordable Reduce electricity prices (target ratio: electricity to gas <2:1), but only where coupled with strong efficiency policies to avoid a subsidy spiral. Link subsidies to effective energy-saving measures. Strengthen EU industry, unlock markets and tackle lacking grid access Define clear targets for energy efficiency and decarbonisation beyond 2030. Ramp up funding (incl. for SMEs), ease loan access, and introduce derisking mechanisms. Mandate national roadmaps for process heat decarbonisation. Boost R&D and lead markets for decarbonised commodities. Enable expansion of electricity grid connections for companies in a timely manner. Enable Energy Efficiency as a Service The electrification from fossil-based heating and process heat is a cornerstone of decarbonisation. Remove barriers for ESCOs and create fair, stable market conditions. Strengthen frameworks for district heating, mandate heat mapping at lower thresholds, and standardise technical interfaces. Promote social contracting models to reduce energy poverty and enable access to affordable clean heat for vulnerable households.
Read full responseResponse to Heating and cooling strategy
2 Oct 2025
Heating and cooling account for nearly half of Europes final energy demand and remain 70% fossil-based. Persistently high energy costs and import dependency (60% of total energy, 19% of gas from Russia) threaten households, industry, and Europes energy sovereignty. While the Commission identifies key challenges, critical gaps persist: the vast efficiency potential across buildings, industry, waste heat and district heating remains largely untapped. In Germany alone, 226 TWh/a of industrial process heat, 153 TWh/a in decentralised heat supply, and 300 TWh/a of waste heat could be saved or reused. EU-wide, over 2,800 TWh/a of industrial waste heat remains unused. These potentials must be activated to ensure a secure, affordable and climate-neutral energy system. Otherwise, unchecked electrification risks overloading power grids, increasing costs and fuelling a subsidy spiral. Energy efficiency significantly reduces energy bills, mitigates investment needs in generation and infrastructure, and supports climate neutrality. Moreover, Europe is already a technology leader in clean heating and cooling. Tapping these potentials would strengthen the domestic market (up to 22-fold increase), secure up to 1 million new jobs, and create long-term value. Key Facts and Challenges: Industrial process heat accounts for two-thirds of final industrial energy use; 44% of final energy demand in German industry could be saved cost-effectively without cutting output. Buildings: Efficiency measures reduce peak loads, cut consumption, and act as thermal storage. Without renovation of single family houses Germany would need an extra 98 GW of capacity and 153 TWh/a electricity, equal to ~200 new gas plants. In industrial production halls and heated warehouses 61116 TWh can be saved in Germany. District heating: Expansion from 13% to 20% EU demand could save 24 bcm of gas by 2030 equivalent to nearly half of Europes 2024 Russian gas imports. Cooling: Rising demand threatens summer peak stability. Efficient cooling technologies and building design can reduce electricity peaks und system costs. Waste heat: Germany uses only 5% of its potential; low-temperature urban waste heat is growing rapidly but lacks strategic integration. Barriers persist: Delays in grid connections, unclear standards, low renovation rates (<1%), and lack of support for ESCOs, SMEs, and vulnerable households hamper progress. Our Recommendations: Energy Efficiency First operationalise and enforce Embed the principle into all planning and funding processes: prioritise efficiency when more cost-effective than supply-side investments. Enforce EED and EPBD, including MEPS and binding application of Article 3 EED. Establish an EU-wide governance system (scoreboards, reporting, infringement procedures) to ensure accountability. Make electrification efficient and affordable Reduce electricity prices (target ratio: electricity to gas <2:1), but only where coupled with strong efficiency policies to avoid a subsidy spiral. Link subsidies to effective energy-saving measures. Strengthen EU industry and unlock markets Define clear targets for energy efficiency and decarbonisation beyond 2030. Ramp up funding (incl. for SMEs), ease loan access, and introduce derisking mechanisms. Mandate national roadmaps for process heat decarbonisation. Boost R&D and lead markets for decarbonised commodities. Mandate waste heat and cold recovery Make waste heat recovery mandatory for major emitters and integrate reuse into heat planning. Ensure DHC readiness in new urban/industrial developments. Modernise networks, enable low-temperature reuse, and align planning with industrial transformation. Enable Energy Efficiency as a Service Remove barriers for ESCOs and create fair, stable market conditions. Strengthen frameworks for district heating, mandate heat mapping at lower thresholds, and standardise technical interfaces. Promote social contracting to enable access to clean heat for low-income households.
Read full responseMeeting with Dan Jørgensen (Commissioner) and
16 May 2025 · Energy Efficiency policies Affordable Energy Action Plan
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 methodology administratively lean. 1. Efficiency-First as guiding rule. Energy efficiency is the most direct lever to cut bills for tenants and owners, shield house-holds from volatile energy prices and reduce the public-investment needs for generation, grids and storage. We therefore urge the Commission to place an explicit hierarchy in the regulation: minimize energy demand through ambitious end-use requirements and meet the residual demand with on-site and district level generation primarily. Making this sequence mandatory would give Member States a clear decision tree and operationalize the Energy Efficiency First principle embedded in EU energy legislation. 2. Appropriate discount rates to value long-term benefits. Building components often last fifty years or more, yet many Member States still apply macroeconomic discount rates of 3-5 % real. Such rates down-weight future energy savings. We support the mandatory sensitivity analysis but recommend setting a maximum real macro-rate of 2 % for the benchmark calculation. This ceiling reflects recent work by the Commissions own impact-assessment guidelines, growing academic consensus on social time preferences and the need to protect future generations from climate costs. Lower rates would also level the playing field between energy efficiency and capital-intensive supply-side assets that already enjoy long depreciation periods. 3. Unbiased energy-price assumptions. Since 2022, many Member States have introduced temporary tax reductions, price caps and direct transfers that artificially depress end-user prices. If these interventions are carried into the calculations, the true value of efficiency improvements is systematically underestimated. We recommend that Annex II clarify that Member States must use unsubsidized social opportunity costs of energy and, where available, the long-term cost of supply including upstream network, balancing and storage expenses. This correction will ensure that cost-optimality reflects real economic welfare instead of short-term crisis instruments. 4. Forward-looking primary-energy and CO factors. DENEFF welcomes the requirement to apply projected primary-energy and emission factors averaged over the calculation period. To guarantee comparability, the Commission should publish default pathways covering electricity, district heat and major fuels consistent with NECPs, REPowerEU and the 2040 climate target. Member States may deviate if they submit transparent, peer-reviewable data. Harmonised forward factors will prevent underestimation of the long-term benefit of electrification and deep renovation in power systems that decarbonize rapidly after 2030. 5. Transparency and enforcement The mandatory reporting template in Annex III is pivotal. We encourage the Commission to (a) host all national input data, assumptions and results on an open portal in machine-readable form; (b) publish a biennial scoreboard comparing minimum requirements with national cost-optimal levels; and (c) initiate infringement procedures promptly where Member States fail to adjust their standards within the 24-month deadline or leave margins wider than the 15 % allowed. Transparent data will enable investors, civil society and local authorities to monitor progress and accelerate market uptake of high-performance solutions.
Read full response2 May 2025
The German Business Association for Energy Efficiency (DENEFF) welcomes the Commissions draft implementing regulation and annexes establishing common templates for transferring national building performance data to the EU Building Stock Observatory (EUBSO). The regulation is an essential pillar for making the Energy Performance of Buildings Directive (EPBD) operational: only if comparable, machine readable and complete data are delivered can Europe track progress toward a highly efficient, decarbonized building stock by 2050. DENEFF supports the overall architecture of annual, anonymized country level reporting focused on energy, carbon and renovation indicators from Energy Performance Certificates (EPCs), real-performance data, and data from heating, ventilation and air conditioning inspections, Building Renovation Passports, and the Smart Readiness Indicator. We emphasize the need to avoid unnecessary administrative burdens. Therefore, we recommend focusing on existing data points that are crucial to enable investments and support implementation, governance and policy monitoring. However, the current drafts show several gaps that could limit future usefulness for policymakers, financiers and planners. 1. Unique Building Identifier (UBID): Templates only contain stock aggregates. A harmonized UBID is vital EU-wide to link cadastral, subsidy or metered datasets and avoid double counts. The regulation should require member states to register hashed UBIDs in national files; Brussels would still receive aggregates but national data quality would improve significantly. 2. Metered energy and load data: EPC data are static. Smart-meter readings and energy management data are key for grid planning and EU Taxonomy risk. Add mandatory-if-available fields for annual metered energy use (kWh/m²a) and peak demand (kW), starting with non-residential buildings with HVAC systems > 70 kW from 2030. 3. Finance-relevant indicators: DENEFF welcomes integration of renovation passport data (e.g. iSFP in Germany). Include estimated and discounted cost savings (aligned with revised cost-effectiveness method) and simple brown-discount or Taxonomy-alignment scores, flagged mandatory-if-available to let frontrunners lead. 4. Phased roadmap: Define two milestones: minimum dataset by 15 March 2027; extended dataset (including metered and financial data) by 2030. This start with what exists, then enrich approach offers fast IT clarity. 5. Sub-national granularity: National privacy rules limit insights for local actors. Allow optional anonymized NUTS-3 or LAU summaries once sample thresholds are reached to support spatial heat planning. 6. Using existing data sources: Publish guidance listing subsidy registries, building permits, 3D models and micro-census data; promote automated feeds via APIs so member states can avoid expensive new surveys. 7. Inspection alternatives (automation/ESCO): Art. 23(7) EPBD allows exceptions from inspection requirements (Art. 23 (1)) for buildings with certain automation/monitoring systems (Art. 13(10)(11)). Art. 23 (5) allows for exemptions if an ESCO contract guarantees performance. Article 6 should register these alternatives to track uptake and impact. Finally, DENEFF highlights the value of existing datasetssubsidy databases, building permits, micro-census and geospatial models. The Commission should issue guidance listing such sources and encourage automated interfaces to accelerate database maturity without introducing unnecessary new reporting obligations.
Read full responseMeeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)
29 Apr 2025 · Discussion on efficient processes and decarbonization strategies in the European industry.
Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)
6 Feb 2025 · Industrial competitiveness and affordable energy
Meeting with Thomas Geisel (Member of the European Parliament)
5 Feb 2025 · General exchange on productivity of Europe's industry
Meeting with Peter Liese (Member of the European Parliament)
29 Oct 2024 · Austausch
Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager)
15 Dec 2021 · Draft State aid Guidelines on Climate, environmental protection and Energy
Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Bureau Européen des Unions de Consommateurs and
2 Dec 2021 · EPBD - Energy poverty
Response to Commission Communication – "Renovation wave" initiative for the building sector
8 Jun 2020
DENEFF, the German Business Initiative for Energy Efficiency, is the strong voice of Germany's energy efficiency industry.
DENEFF fully supports the European Commission’s intention to develop a Renovation Wave.
We endorse the feedback submitted by our partner organisation, The European Alliance to Save Energy (EU-ASE). Please find the detailed EU-ASE statement attached. We envisage an EU-wide building Renovation Wave which revolves around the swift implementation of the Energy Efficiency First principle as the fastest and most cost-effective way to reduce emissions and stimulate sustainable economic recovery.
The attached set of recommendations outlines ideas for a Renovation Wave communication which should recognise the role of energy efficiency as a potent and critical catalyst to the massive scale-up of building renovations in a resource-constrained Union, especially during the
unprecedented crisis triggered by COVID-19:
1. Accelerate the implementation of the provisions that concern buildings in the Clean Energy Package by strengthening and facilitating monitoring, evaluation and exchange of good practices among the Member States accompanied by rigorous enforcement.
2. Apply the Energy Efficiency First principle
3. Boost the renovation of existing residential and commercial buildings and mobilize resources to eradicate energy poverty
4. Boost digitalization of buildings as a key driver of greater efficiency
5. Prioritize finance for energy efficiency in buldings in all EU funding programmes post 2020 and improve access to technical assistance
6. Lead by example ensuring that 100% of public (central, regional, and local) buildings are nearly-zero energy (nZEB) by 2030
7. Remove all existing barriers to the full functioning of energy performance contracting
8. Raise awareness about the multiple economic, social and environmental benefits of highly energy-efficient and smart buildings for citizens, cities and businesses
Read full responseMeeting with Günther Oettinger (Commissioner)
5 Sept 2019 · EU climate change policy