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Efficient Buildings Europe

Efficient Buildings Europe is the leading European industry association dedicated to advancing energy efficiency in European buildings.

Lobbying Activity

Efficient Buildings Europe urges alignment with energy performance rules

20 Nov 2025
Topic — Review of technical criteria for the EU green finance classification system.
Message — The group wants the building directive to be the central framework for taxonomy building criteria. The association also calls for simplifying the reporting burden for smaller building renovation projects.12
Why — This alignment would provide easier access to green financing and lower interest rates for homeowners.3
Impact — Private certification schemes could lose market share if the EU prioritizes national energy certificates.4
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Efficient Buildings Europe urges mandatory smart meters and digital retrofits

5 Nov 2025
Topic — A roadmap to leverage digital technologies and artificial intelligence in the energy sector.
Message — The association calls for implementing the Energy Performance of Buildings Directive to scale up smart automation. They suggest mandating digital tools in public procurement and requiring smart meters for energy and water.1234
Why — Member companies would benefit from mandatory requirements driving demand for their digital efficiency products.56
Impact — Building owners face higher upfront costs and a shortage of skilled workers for digital installations.78
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Meeting with Dan Jørgensen (Commissioner)

3 Nov 2025 · Housing and energy efficiency of buildings

Efficient Buildings Europe Calls for EU-Wide Data Standards in Carbon Rules

31 Oct 2025
Topic — EU framework for calculating global warming potential of new buildings under EPBD.
Message — The organization requests that the rules prioritize primary product data from verified declarations and EU-level generic data rather than national-level data. They want harmonized product-level data for HVAC manufacturers and explicit recognition of Ecodesign data sources.1234
Why — This would reduce administrative burden by avoiding different datasets for varying national standards.5
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Efficient Buildings Europe urges efficiency-led energy security reforms

13 Oct 2025
Topic — The European Commission is revising its energy security framework to improve resilience.
Message — The association proposes making gas suppliers responsible for implementing energy efficiency measures. They demand aligning energy security plans with national building renovation targets.12
Why — These reforms would create significant market demand for the association's energy-saving technologies.3
Impact — Gas suppliers face mandatory targets to reduce consumption, cutting into their core business.4
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Efficient Buildings Europe urges 2035 fossil fuel heating ban

9 Oct 2025
Topic — This consultation aims to accelerate the decarbonisation of European heating and cooling systems.
Message — They request a mandatory phase-out of fossil fuels in buildings by 2035. The group advocates for zero percent VAT on renovation works and smart meter installation.123
Why — Removing capital costs and financing gaps will allow the efficiency sector to scale.4
Impact — Fossil fuel appliance manufacturers will lose their market as sales are banned by 2035.5
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Efficient Buildings Europe Urges Energy Efficiency First for Electrification

9 Oct 2025
Topic — The consultation addresses barriers to switching EU energy demand from fossil fuels to electricity.
Message — Put the Energy Efficiency 1st principle at the core of the plan to make electrification affordable. Lower VAT for efficiency products to zero and mandate the installation of smart meters by 2030. Rebalance taxation to favor electrification while phasing out distorted fossil fuel subsidies.123
Why — The proposals would boost demand for building renovations and secure subsidies for efficiency manufacturers.4
Impact — Fossil fuel suppliers lose market advantage as their subsidies are removed to rebalance taxes.5
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Meeting with Margareta Djordjevic (Head of Unit Energy)

30 Sept 2025 · Presentation of the association and discussion on the EU energy efficiency policy

Meeting with Leila Chaibi (Member of the European Parliament, Shadow rapporteur)

25 Sept 2025 · HOUS related issues

Construction Industry Urges EU to Prioritize Energy Efficiency in Housing Strategy

18 Sept 2025
Topic — EU strategy to increase housing construction supply and close supply-demand gaps.
Message — The organization requests regulatory stability for energy efficiency directives, support for renovating vacant buildings, and removal of barriers to industrialized construction techniques. They advocate for mandatory Building Information Modelling in public procurement and stronger workforce skills mapping.1234
Why — This would provide market predictability for investments and reduce compliance uncertainty for the efficient buildings industry.56
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Meeting with Borja Giménez Larraz (Member of the European Parliament, Rapporteur)

15 Sept 2025 · HOUS Draft Report

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

10 Sept 2025 · Energy efficiency, housing

Response to European climate resilience and risk management law

4 Sept 2025

An efficient, comfortable, and healthy building stock is the first step towards climate resilience. Buildings offer protection from extreme events when adequately designed, constructed, renovated, and maintained. However, most of them are ill-adapted to a changing climate. Up to 1 in 5 households cannot afford the cost of summer cooling 75% of the EUs building stock is energy-inefficient and about 80-95% of the buildings will still be standing in 2050 Maintaining safe indoor temperatures and air quality is essential to protecting the health and well-being of Europeans. Energy efficiency products and equipment help deliver on these two key dimensions of indoor environmental quality and must be included. Well-insulated buildings paired with appropriate adaptation strategies (solar control glazing, complemented by solar shading, and sufficient natural or mechanical ventilation) ensure that buildings remain comfortable and resilient even in increasingly hot weather. To address this, multiple EU countries (BE, DK, FR) introduced Indoor Environmental Quality (IEQ) requirements to limit overheating risks by considering climate data on heat waves. Member States now have a chance to streamline IEQ requirements. Water-efficiency technologies in buildings alleviate system pressures in the case of droughts. The European Commission should support the roll-out of these solutions, technologies, and innovations in this sector to unlock its full potential. Effective data management and the strategic use of technology deliver significant energy and water efficiency in buildings. Efficient buildings can maintain comfortable indoor environments with less energy input during climate-related disruptions. This resilience reduces the need for imports or over-reliance on a single energy source, particularly during extreme weather events, which are exacerbated by climate change. While 75% of heating and cooling needs are met using fossil fuel sources, decarbonised heating and cooling solutions are key to Europes resilience, as well as smart building design, cooling buildings thanks to interior and exterior solar shading, and natural night ventilation. Efficient buildings can also better integrate on-site renewable energy systems. They will reduce our vulnerability to international and regional energy market fluctuations and climate-related disruptions in energy supply. Additionally, efficient buildings also strengthen Europes energy system by reducing energy demand during peak hours. Our recommendations Support the implementation of the Energy Performance of Buildings Directive and the Energy Efficiency Directive: Ensuring Member States consider climate resilience in their National Building Renovation Plans. The Commission should help MS to design adequate strategies to address specific segments of the stock and different ownership profiles (schools, elderly homes, commercial buildings etc). Mainstream climate resilience considerations in the implementation of relevant provisions such as IEQ, Energy Performance Certificates (EPCs), Renovation Passports, Zero Emission Buildings (ZEB) definition, and Minimum Energy Performance Standards (MEPS). Use forecast climate data when running building simulations and planning building designs to reflect real climate change impact. Include water consumption in buildings in the European Water Resilience Strategy and the European Affordable Housing Plan. The Commission should present measures to incentivise rain- and greywater harvesting across buildings, encourage the uptake of metering equipment, innovative digital solutions and water management products, and integrate nature-based solutions for stormwater management. Tackle the skills gap in the energy and water-efficiency sectors: plan for training programmes and digital upskilling initiatives Support investors in reaching a resilient building portfolio through the Taxonomy. More recommendations attached
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Meeting with Rosalinde Van Der Vlies (Director Energy)

7 Jul 2025 · The upcoming activities of EBE in the context of the ongoing policy initiatives

Response to European Affordable Housing Plan

4 Jun 2025

The Affordable and Sustainable Housing Plan is an excellent opportunity to adopt a holistic approach to lower running costs, improve living conditions, and empower building owners and tenants across Europe. With a supportive and stable policy/financing framework, energy efficiency technologies and solutions can be deployed at scale to improve the long-term affordability and comfort of housing in the EU. Efficient buildings can deliver far-reaching benefits for European households beyond energy savings and decarbonisation goals, in improving their well-being, affordability and availability of housing. Efficient Buildings Europe recommends focusing on: Ensure a stable, long-term framework to facilitate planning and investments. The efficient buildings/construction sector needs long-term market predictability to plan investments, hire and train workers, and ramp up production. Fast-tracking the implementation of the EED, EPBD, and RED will deliver tangible savings for EU building owners and tenants. The deployment of One Stop Shops will facilitate access to information, guidance, financing, and certified contractors. Improve the business case for efficient buildings and renovations, which can be made more affordable as several measures would positively impact the time to return on investment (ROI): Unlocking affordable private finance: Several population groups struggle to access affordable private finance. Banks must be encouraged to reach out to citizens and businesses and offer instruments to deliver energy renovations. Mortgage Portfolio Standards and EIB guarantees for renovation loans and the EIBs Action Plan for Affordable and Sustainable Housing could help. Stimulating private investments through EU funds: Empower national/local authorities through technical assistance on financial instruments and blended finance. Improving the electricity/gas price ratio: Price signals have a clear impact on the ROI of energy renovations. The review of the Energy Taxation Directive and ETS2 implementation should address this issue. Joint public procurement could facilitate implementation of EPBD and EED, which incentivise the public social housing sector to improve its building stock (aggregating projects delivers scale and lowers costs). Stimulate investments through reporting: update the EU taxonomy based on the EPBD and simplify reporting procedures. Industrialised/offsite construction and renovation processes could reduce time spent on site, costs and materials used. Thousands of projects have been completed in the EU, but barriers still prevent the upscaling of modular constructions and renovations: Segmented national building codes and slow certification processes; Tools to aggregate projects and specific support through public procurement; Lack of recognition and support for digital tools (e.g. building information modelling and digital building logbooks). Design a long-term public support framework. Allocate sufficient long-term funding for efficient buildings in the next MFF, and provide a clear long-term perspective for managing authorities. Encourage them to allocate a sufficient share of the renovation budgets to administrative capacity, technical assistance, and workforce training. Extend the RRF spending deadlines to 2028 and encourage Member States to focus on renovating the worst-performing buildings. Develop a strong enabling framework. Launch a dialogue bringing together the sectors responsible for the delivery of the Affordable Housing Plan (manufacturers, contractors, building owners, banks, insurers, etc.). Support skills in the sector through the EU Pact for Skills and the Just Transition Platform in the regions most affected by the transition to climate neutrality. Support the development of public-private partnerships with public authorities to blend financial solutions and deliver energy-efficient renovate works at district and neighbourhood levels.
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Meeting with Martin Hojsík (Member of the European Parliament)

23 Apr 2025 · Housing situation in Europe

Meeting with Gabriele Bischoff (Member of the European Parliament) and Knauf Insulation and VELUX A/S (VELUX Group)

9 Apr 2025 · Housing

Meeting with Agnese Papadia (Cabinet of Commissioner Dan Jørgensen) and WWF European Policy Programme and

7 Apr 2025 · Energy efficiency renovations of buildings, housinG

Meeting with Markus Ferber (Member of the European Parliament)

1 Apr 2025 · Affordable Housing Plan / Clean Industrial Deal

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur)

25 Mar 2025 · Security of Energy Supply

Efficient Buildings Europe urges mandatory energy criteria in public procurement

7 Mar 2025
Topic — Evaluation of EU directives governing concession contracts and public procurement by authorities and entities.
Message — The group advocates for life cycle costing instead of lowest-price selection to reach climate goals. They propose making green procurement criteria mandatory while integrating digital building modelling tools.123
Why — Standardized rules would provide long-term visibility and create lead markets for energy-efficient technologies.45
Impact — Sellers of cheap, energy-inefficient equipment would lose their advantage as authorities prioritize environmental performance.67
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and BASF SE and

19 Feb 2025 · Exchange on Housing and Efficient buildings initiatives in Europe

Meeting with Dirk Gotink (Member of the European Parliament)

18 Nov 2024 · Housing

Meeting with Barry Andrews (Member of the European Parliament)

18 Nov 2024 · Energy Efficiency

Response to Establishment of a portfolio framework to increase lending towards energy performance renovations

5 Nov 2024

Efficient Buildings Europe (EBE) appreciates the opportunity to participate in the European Commissions first public consultation on a portfolio framework for increasing lending for energy renovations, proposed by the Energy Performance of Buildings Directive (EPBD). The latest I4CE report indicates that achieving the EUs 2030 targets in the building sector will necessitate a minimum of 335 billion in annual public and private investments from 2024 to 2030. This leaves a funding gap of 137 billion of additional investments in energy-efficient renovations and new buildings. Closing this investment gap will require a comprehensive approach that includes strengthening public finance mechanisms, refining and strategically targeting public incentives, mobilising private sector capital, and using blended financing models that integrate both public and private funds. Additionally, financing options must be tailored to the diverse needs of various consumer categories, considering factors such as financial needs, economic circumstances, geographical locations, and building types. EBE believes that a well-defined, science-based, and transparent framework can greatly accelerate investment in energy-efficient renovations, improve energy performance in the EUs worst-performing buildings, and provide financial institutions with an effective tool for managing climate-related risks, thereby contributing to the resilience of the European banking sector. Read our attached reply for more information.
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Meeting with Peter Liese (Member of the European Parliament)

23 Sept 2024 · Environmental Policy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

5 Sept 2024 · Renovation of primary schools

Meeting with Martin Hojsík (Member of the European Parliament) and Danfoss A/S

17 Jul 2024 · Energy efficiency, priorities of 10th legislative term, Industrial plan, housing

Meeting with Marcos Ros Sempere (Member of the European Parliament)

17 Jul 2024 · Meeting with Efficient Buildings Europe

Meeting with Bruno Tobback (Member of the European Parliament)

15 Jul 2024 · Challenges on renovation of houses and public buildings and prospects for the next mandate

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

11 Jul 2024 · buildings

Meeting with Maroš Šefčovič (Executive Vice-President) and

15 Mar 2024 · Clean Transition Dialogue for Cities

Meeting with Jens Geier (Member of the European Parliament)

12 Mar 2024 · Exchange on the Energy Performance of Buildings Directive (EPBD)

Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

Please find the summary of EuroACE's take and recommendations below and our full answer attached The Commission estimates that the EU invests 85-90bn in buildings energy efficiency each year . This is far from what would be needed to meet the EUs -55% GHGs target. The Renovation Wave strategy shows that the total necessary investment, including decarbonising heat in buildings, is 275bn per year to 2035. I4CE estimates the EU climate investment deficit in the building system, (i.e. the difference between the level of climate-friendly investments happening in the EU in the present; and the total investment needs required annually by 2030 to achieve the EU climate objectives) to be of at least 137 billion euros per year, or 0.9% of EU GDP. With forecasted total investment needs to 2030 over 3.5 trillion, both EU and national programs for energy efficiency have to be scaled up to reach the EUs climate and energy objectives. EuroACEs main takes and recommendations: - Existing EU Funding for energy efficiency in buildings o Working with financial institutions and ensuring programmes help draw in private finance early is and will become even more important to sustain implementation, avoid stop/start investment and extend delivery beyond 2026 o Visibility on national-level funding for energy efficiency and renovation measures is limited. More should be done to properly assess public investments in this sector. The design and publication of the National Buildings Renovation Plans in 2025 is the perfect occasion to get a clear picture and link funding streams to specific targets and policy measures. - The case for an EU energy efficiency mechanism o Creating a dedicated budget line for energy efficiency to reduce competition for climate financing and provide midterm visibility and stability for the actors involved. o Better linking cohesion policy investments to Member State plans to achieve 2030+ targets and to National Building Renovation Plans. Indeed, ex-ante conditionalities linking investments to the meeting of goals under the Energy Performance of Buildings Directive will help the EU to continue its low-carbon transformation and remain competitive. o Allowing funding to be directly used to implement national building renovation plans in Member States would also be effective. Indeed, considering NBRPs as a programming channel to which MFF funding can be allocated will ensure a larger umbrella under which various funding strands can be combined, leading to more flexibility and hence a better roll-out of these renovation strategies on the ground. - Encourage the emergence of new tools to finance energy renovations o Engage banks and private lenders through portfolio performance requirements o Design 0-rate loans suited for people having difficulties to access affordable finance
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

Please find the summary of EuroACE's position below and our full answer attached. Years of inaction on energy efficiency in the buildings sector are having a dramatic impact on households and public finances. Energy bills skyrocketed in some Member States compared to previous years, exposing millions to the risks of energy poverty and/or the inability to make mortgage payments. In turn, this has become a credit risk for banks, as demonstrated by the European Central Bank (ECB) climate stress test in 2022. The European think tank Bruegel assessed that around 4% of the EU GDP (540 billion in the EU, of which 158 billion has been earmarked by Germany alone) has been spent by Member States on subsidising energy bills for companies and households. This is twice the Commissions figure for additional investments needed per year in building renovations. I4CE estimates the EU climate investment deficit in the building system, (i.e. the difference between the level of climate-friendly investments happening in the EU in the present; and the total investment needs required annually by 2030 to achieve the EU climate objectives) to be of at least 137 billion euros per year, or 0.9% of EU GDP. The EU can provide some of the funds needed but new instruments are also required to unlock the necessary private investments. EuroACEs Main recommendations - The EU should stimulate private investments through EU funds o Design a Recovery and Resilience Facility 2.0 to avoid a funding cliff for energy renovations in 2026 + encourage provisions to progressively attract private finance and investments o When it comes to cohesion funds, use blended finance where relevant and empower national and local authorities through technical assistance on financial instruments o Make sure the EEFIC national hubs include stakeholder and private lender representatives - Encourage the emergence of new tools to unlock private funding o Engage banks and private lenders through portfolio performance requirements o Design 0-rate renovation loans suited for people having difficulties to access affordable finance o To incentivise lenders to design affordable green renovation mortgages, the European Central Bank (ECB) should apply a green discount rate on its loans to commercial banks, under the condition that, in turn, the commercial banks use these loans to offer zero-percent loans to their customers for energy efficient renovations. - Unlock finance for commercial real estate o The pay-for-performance financing model allows building owners to pay for energy-saving upgrades based on the actual energy savings achieved. It ensures that energy savings are quantifiable, verifiable, and accessible to all parties involved, thereby incentivising energy renovations. o Financial instruments like sustainability-linked loans and bonds are powerful tools for raising capital for energy renovations and the construction of efficient buildings. o The concept of property-linked finance has the potential to unlock significant investments for energy efficiency improvements and represents a promising avenue to finance energy-efficient real estate projects.
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

2 Jun 2023 · Meeting with EuroAce on NZIA

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

24 Apr 2023 · EPBD and NZIA

Meeting with Kadri Simson (Commissioner) and

3 Apr 2023 · Discussion on how to strengthen the EU-US cooperation to increase the deployment of renewables.

Meeting with Kathleen Van Brempt (Member of the European Parliament)

15 Feb 2023 · social aspects of renovation (APA)

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur)

4 Oct 2022 · EPBD

Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

3 Jun 2022 · To to discuss the ‘Fit for 55’ Package and, more specifically the proposed revision of the Energy Performance of Buildings Directive

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

10 May 2022 · Discussion on energy efficiency measures.

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 May 2022 · REPowerEU, building sector, renovation, energy efficiency

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

25 Apr 2022 · US-EU Task Force Convening: Clean Energy Technologies. Carrier, Tado and the European Council for an Energy Efficient Economy (ECEEE) also participated.

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

9 Mar 2022

EuroACE-Energy Efficient Buildings, welcomes the proposed recast of the Energy Performance of Buildings Directive (EPBD). The EPBD must play a more central role in the Fit for 55 Package. In line with the need to strengthen its level of ambition, our main recommendations are: - Minimum Energy Performance Standards (MEPS): we welcome the establishment of MEPS. However, the targeted level of ambition by MEPS needs to be strengthened, as this instrument should truly deliver against the objectives of the EU Renovation Wave Strategy. In addition, a more prominent role for good planning and holistic deep renovations (whether one-shot or staged) should be secured. At national level, Member States (MS) shall use their National Building Renovation Plans to establish trajectories for buildings to achieve progressively higher energy classes in line with a defined pathway towards a zero-emissions building stock by 2050. With these trajectories, MEPS can be designed for different building segments, for which the creation of building level roadmaps becomes easier and more economically feasible. In this regard, we welcome the establishment of a Renovation Passport scheme, whose deployment should be accelerated to promote holistic deep renovations which deliver on the multiple benefits. - Zero-emissions buildings (ZEB): the concept is a step forward in terms of addressing both the energy performance and operational carbon emissions of buildings. When defining a ZEB, Annex III should use both primary and final energy consumption indicators to adequately consider measures to reduce energy needs. Moreover, the thresholds in Annex III should be more ambitious. A clearer differentiation between ZEB and NZEB standards is needed, where ZEB must be more ambitious. - Provisions on new buildings: beyond the considerations on the ZEB standard, a more ambitious timeline and next steps for implementation of these provisions should be better addressed. EuroACE welcomes the requirement for new buildings to report on the Global Warming Potential and agrees that in the interest of creating a common vision to whole-life carbon, relying on the Level(s) framework and on standard EN15978 is a starting point. - Multiple benefits: We welcome the new provisions to better factor the multiple benefits (such as health, comfort and indoor air quality) associated with the optimisation of energy performance of the building stock. We suggest going a step beyond by addressing and defining “Healthy Indoor Climate”. - Energy Performance Certificates (EPCs): EuroACE welcomes the introduction of a common template for the issuing of EPCs, which will boost comparability across MS. We note the proposal aims at bringing greater convergence to how MS define their A to G scale by the end of 2025. This will support MEPS implementation and secure more harmonisation. We think it is equally important to ensure better EPC coverage. EPCs should be better linked with other instruments such as Renovation Passports (to spur deep holistic renovations – combining both active & passive solutions), Smart Readiness Indicator etc. via Digital Building Logbooks. - Digitalisation: We welcome the establishment of a common, harmonised EU scheme for rating the smart readiness of buildings. Technical Building Systems (TBS): changes to provisions on TBS are overall positive. EuroACE will suggest extending the scope of TBS to electrical installations and introducing a clear provision to require that outdated and inefficient TBS are replaced as part of holistic deep energy renovations. - Inspections: The inclusion of inspections of ventilation and air conditioning systems is welcomed. The introduction of a timeline to implement recommendations stemming from inspection reports is needed (3 years, with compliance checks). We welcome BACS provisions and support introduction of continuous electronic monitoring and control functionalities in new residential buildings and in those undergoing major renovations.
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Meeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards

Response to Review of Directive 2012/27/EU on energy efficiency

7 Oct 2021

EuroACE – Energy Efficient Buildings welcomes the opportunity to share its feedback on the proposed revision of the Energy Efficiency Directive as set out below. We call the co-legislators to consider: 1) Strengthening the collective effort of Member States towards the achievement of the binding EU Energy Efficiency target: - We welcome the proposal for a binding EU Energy Efficiency target but call for it to be increased to at least 40% for both primary and final energy compared to 2007 PRIMES projections. - National level contributions should be made mandatory and the reporting and planning requirements stemming from Governance Regulation, EED and EPBD made more coherent and strategically interlinked. 2) Keeping the ambition level for energy savings obligations and sectoral sub-targets high: - We welcome the new energy savings target (1.5%) for the period from 2024 to 2030. We believe that in case Member States underperform against the energy saving targets, the share of unachieved energy savings should be required to be fulfilled in the year following the year of underachievement to ensure the in-time achievement of the 2030 EE target. - We support and call for the retention of the new cumulative energy saving target for the public sector (-1.7% in final energy use) and the fact that energy improvements of buildings should play a big role in its achievement. 3) Further strengthening the ‘Exemplary Role’ of public bodies and avoid loopholes: - We welcome the extension of the renovation requirement to buildings owned by all public bodies, the rate and the ambition level of renovation, which is set at national NZEB level. It will be important that the EPBD revision strengthens the requirements stemming from its article 9 in a way that both new and existing buildings truly consume nearly zero or very low amounts of energy, and that the remaining energy is fully supplied by renewables sources. - We call for a better alignment between article 6 and 7 which deals with public procurement rules. New rental contracts should be conducted for ‘high-energy efficient buildings’ defined on the basis of article 9 EPBD rather than article 4 EPBD as stated in Annex IV of the EED RECAST. - We welcome the deletion of the alternative measures and we warn the co-legislators of a possible loophole stemming from the exemption created for MS, which, in exceptional cases, can count the purchase of new buildings as a replacement for a demolished building, if this is deemed sustainable and cost-efficient in both energy and life-cycle CO2 terms. In terms of carbon impact, renovation is a more sustainable activity but carbon assessment methodologies differ too much across Member States to create a homogeneous approach to define such ‘exceptional cases’. Further clarifications and coordination will be needed from the Commission to ensure that these cases are both well-defined and remain exceptional. 4) Better recognising the energy savings potential of energy audits and further promoting it: - EuroACE supports the introduction of mandatory energy management systems for the highest energy consuming companies but we believe that energy audits require the same mandatory nature to truly unlock their benefits. - The recommendations stemming from an energy audit should be strongly linked to the Energy Performance Certificates and enshrined into a Building Renovation Passport developed for the building owned and/or occupied by the enterprise subject to this exercise. - Information stemming from the energy audit should be transmitted beyond the management level to reach the building owner and local/regional authorities as well as to support both monitoring and planning activities when it comes to the improvement of the energy performance of buildings.
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Response to Setting out common indicators and detailed elements of the recovery and resilience scoreboard

25 Aug 2021

EuroACE – Energy Efficient Buildings welcomes the opportunity to react to the draft delegated regulation of the European Commission’s Recovery and Resilience Facility Scoreboard (RRFS). The RRFS’s purpose is to monitor and showcase EU Member States’ progress through the implementation of their National Recovery & Resilience Plans (NRRPs). In our view, the funding stemming from the Recovery & Resilience Facility (RRF) is a crucial tool to set MS on the right path towards the achievement of the EU’s Renovation Wave Strategy objectives of at least doubling the current renovation rates and stimulate deep renovation, while offering opportunities of socio-economic growth in the aftermath of the COVID-19 pandemic and attain the EU climate goals. As indicated in the draft delegated regulation, the RRFS differentiates between two different means of reporting:1) common indicators, compiled by MS in the context of the European Semester; 2) other elements (i.e., milestones/targets from each NRRP, reflecting the implementation of their reforms and investments), compiled by the Commission. As regards as the common indicators, we note that the RRFS puts forward the “savings in annual primary energy consumption” as the only metric used by MS to report on their investments on buildings. EuroACE believes that this indicator alone cannot portray the multiple benefits that buildings-related reforms and investments have on the society at large, and on the achievement of the Renovation Wave objectives. Therefore, we believe that, in the case of buildings, savings should be calculated on the basis of both annual primary and final energy consumption. Moreover, as several NRRPs already provide targets on the number of buildings or how many m² should be renovated via the support of the RRF, the achievement of such objectives should be assessed and categorised by building segment in the MS bi-annual RRFS reports. This should provide a better understanding of what the savings in annual primary and final energy consumption mean also in terms of depth of energy renovation. All of the above will support the production of better data on buildings and renovation, which will ultimately help public authorities in achieving their Long-term Renovation Strategies (LTRS) objectives. This is fully aligned with the ongoing Energy Performance of Buildings Directive (EPBD) revision which, among other priorities, intends to strengthen LTRS requirements and boost better data collection on buildings by, for example, updating the Energy Performance Certificates (EPCs) framework. On this last point, the current draft delegated regulation states that “for buildings, interventions shall be sufficiently documented to be able to calculate these values, for example by using EPCs or other monitoring systems put in place in Article 10.6 of the EPBD”. It is worth to note that, many of the NRRPs require EPCs to justify compliance with the energy savings obtained by RFF-funded activities impacting buildings’ energy performance. Considering this, we believe that a centralised aggregation process or database for these EPCs must be made available as part of the RRFS to determine the validity of the renovation investments. We would like to add that the Commission has acquired significant experience in tracking progress through reporting on the LTRS. For instance, the EU-funded project BuildUpon2 (https://www.worldgbc.org/our-renovation-strategy-framework) provides extensive detail on the Impact Framework to track progress on buildings which could be taken into consideration within the premises of the RRFS. In conclusion, as NRRPs and RRF funding are key instruments to boost both rate and depth of renovation across the EU, better-quality data on the renovated buildings and a more comprehensive reporting framework are needed by the RRFS to reliably assess and report on the progress towards the achievement of the Renovation Wave and of 2050 climate-neutrality goals.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

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’. To achieve the new 2030/2050 targets and make the Renovation Wave a reality, EuroACE in convinced that a tripling of the energy renovation rate in the EU is necessary. Therefore, it is not adequate to plan for a simple doubling of the energy renovation rate as indicated in the IIAR. Also, in increasing the rate there must be a simultaneous increased focus on the depth of renovations. To achieve this goal, we concur with the Commission that a horizontal approach to revise the EPBD is needed. Creating synergies between this Directive and other legislative initiatives stemming from the Package (EED, REDII, ESR, EU-ETS), where the Energy Efficiency First Principle (EE1) is respected, is crucial. -‘Option 3’ should be chosen as the pathway for the EPBD revision. Reinforcement of non-regulatory measures falling under ‘option 2’ should not be overlooked as they reinforce the whole EPBD implementation framework. On measures falling under ‘option 3’: -EuroACE welcomes the intention of the Commission to gradually phase-in Minimum Energy Performance Standards (MEPS). MEPS should address worst-performing buildings (thus tackling energy poverty) and also be extended, over time, to all building segments. Designing MEPS at national level should be supported by reinforced and 2050-proofed long-term renovation strategies, and they should be introduced with a sufficiently long lead time. A certain level of flexibility in their design should not come at the expense of a reinforced EPBD implementation framework, nor delay their penetration in building segments that will benefit the most (e.g., residential). -EuroACE concurs with the Commission that the EPC framework should be updated to ensure more coverage, comparability and data transparency. The introduction of Building Renovation Passports (BRPs) is also welcomed. Within the framework of BRPs, the introduction of Digital Building Logbooks could also be beneficial to spur digitalisation in the building sector and increase the volume and quality of data on buildings. - EuroACE believes that the introduction of a deep renovation standard is a positive proposal. A possible definition could cover energy renovations that deliver a reduction of 60% of (final) energy needs. Depending on its design, we see possible positive linkages between this standard and the EU taxonomy, only if the threshold set by screening criteria in its Delegated Act is ambitious enough. -EuroACE believes that the EPBD revision is an opportunity to update the requirements for new buildings against the new 2030/2050 targets and in alignment with the EE1 principle. The revision should also look at ways to include the quantification of multiple benefits of energy renovation in cost-benefits analysis methodologies and Impact Assessments modelling. -For new and existing buildings, EuroACE sees the EPBD revision as an opportunity to further optimise technical building systems to enhance energy efficiency and accelerate digitalisation in the building sector. More detail is set out in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Please find enclosed the detailed feedback from EuroACE - Energy Efficient Buildings. In short, EuroACE supports both the screening criteria for new buildings, and for acquisition of buildings (new and existing) outlined in section 7 of Annex I but calls on the Commission to update the requirement for the renovation of existing buildings from 30 to 60% energy savings.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

EuroACE strongly supports the Commission work in raising the 2030 climate target to at least 55% and the objective of reaching climate neutrality by 2050. All sectors will need to contribute and in particular, the buildings sector, as it represents 40% of the EU energy consumption and 36% of its GHG emissions. The ESR ambition should be raised in order to match with the updated climate & energy targets (as in Option 2 outlined in the Roadmap). The current ESR target to reduce non-ETS emissions by at least 30% compared to 2005, is for sure not compatible with climate neutrality by 2050. EuroACE is in favour of keeping the current ESR sectoral scope, i.e. the buildings sector should remain under the ESR and should not be moved to the EU ETS or to a newly created specific ETS. Carbon pricing is not an appropriate tool for the buildings sector, as most barriers which need to be overcome are non-economic barriers. The impact of an extended ETS to buildings would be marginal at best, and even counterproductive, as it is very likely to disrupt the energy efficiency policy ecosystem by appearing to be a silver bullet solution to a challenge that requires joined up policies. Repealing the ESR would be detrimental for energy efficiency, as it would reduce the Member States accountability for putting in place adequate measures. Public authorities should remain in the driving seat to deliver energy savings and therefore GHG emissions reduction. More details on our position is included in our Feedback to the ETS Roadmap, read here: https://euroace.org/wp-content/uploads/2020/11/2020_11_26-ETS-Revision-Commission-Roadmap-EuroACE-Feedback-FINAL.pdf ). Concerning the linkages with the energy efficiency regulatory framework (EED - Energy Efficiency Directive and EPBD - Energy Performance of Buildings Directive), which will also be reviewed in 2021, we reckon there is a strong link with the ESR. The ESR and the energy efficiency policies are strongly interconnected and mutually reinforcing. On one side, national energy efficiency policy measures put in place to transpose and implement the EED and the EPBD are often an important instrument used by Member States to meet their ESR targets (on GHG emissions reduction). More specifically, the contribution of the buildings sector through energy renovation, will become even more crucial in the next decade, with Long-Term Renovation Strategies and National Energy & Climate Plans in place to drive policies and actions in that sector, delivering a considerable amount of energy savings, and therefore, reducing GHG emissions. On the other side, the robust enforcement mechanism, and the national binding targets in the ESR are key, as they trigger (additional) energy efficiency action at national level in sectors such as buildings. The revisions of the ESR, EED and EPBD should therefore be an opportunity to reinforce those synergies, raise the ambition and help achieving both higher GHG and energy efficiency targets. All in all, EuroACE is in favour of keeping the current architecture of the ESR (including the buildings sector) and increasing its ambition.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please find the feedback from EuroACE - Energy Efficient Buildings, in the attached file.
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Meeting with Frans Timmermans (Executive Vice-President)

27 Oct 2020 · Questions and answers on the renovation wave

Response to Review of Directive 2012/27/EU on energy efficiency

14 Sept 2020

The main points of the EuroACE feedback on the EED Roadmap are: - The Commission recognises in its Roadmap the importance of energy efficiency and a lack of recent progress, but, unfortunately, it does not lead to a stronger and more forward-looking approach; - There is a big oversight, i.e. the question of raising the 2030 energy efficiency target at EU level towards at least 40%, and make it binding; - The opportunity to revise Article 5 is very welcome in relation with the upcoming Renovation Wave initiative. The scope of this provision should be widened to all public buildings, alternatives must be deleted, and the ambition must be increased regarding the depth of renovation to be achieved – that will benefit both economic recovery and wellbeing of citizens. All in all, Article 5 should be moved to the EPBD and integrated into the Long-Term Renovation Strategies; - The EED revision is also the opportunity to improve the enabling framework for energy efficiency and revise other articles of the Directive (6, 7, 16, 17, and 20); - A revision of the EED is much needed, but implementation of the current legislation should not be put on hold or pushed aside. For more detailed information about each point of our position, please read the attached Position Paper.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

For a more elaborated answer, see the attached file. The Renovate Europe Campaign (REC) welcomes the proposal for a Renovation Wave Initiative. We believe that, if well-designed and ambitious, it will be able to unlock the full potential tied up in our building stock. Being ambitious means, first and foremost, to work towards the tripling of the current low energy renovation rate per annum. This is a necessary milestone, not only in the Renovation Wave Initiative, but for the economic recovery period ahead. On this last point, we regretted to see that our Call for the creation of a Renovation Fund For All Europeans was not answered by the European Commission. In our view, this would have led to more certainty, and ultimately, the creation of a favourable ground for this Initiative to start. We agree with the list of barriers to energy renovation of buildings stemming from the Roadmap, however the inclusion of a process of ‘mix & match’ among best practices and successful initiatives at Member State-level, is what the REC recommends. The identification of “success factors” rather than just “pull factors” should be carried out and replicated. This would create a stronger data which will lessen information barriers by creating awareness within an ever-increasing pool of actors, especially among investors. To achieve this, we see that the creation/reinforcement of competent agencies in each Member State would support a better communication between them and the EU Institutions. We also welcome the integrated approach across different policy areas as part of the Renovation Wave strategy, although we would also like to stress importance on increasing the level of ambition (and complementarity with one another) of both NECPs and LTRSs. The Renovation Wave should not be just about buildings, but also about people. Greater importance should be given to supply and demand checks and balances within Member States’ energy renovation markets. Issues such as split-incentives, disruption during works, lack of sufficient range of attractive and accessible financial products may be solved via the creation of tailor-made and human-centric aggregated solutions on a segment-by-segment basis. We think that a segment-based approach should be complemented by an area-based approach, which will foster the industrialisation of building renovation. We agree that, in certain regions, this approach would be helpful in scaling up energy renovations whilst simultaneously delivering social, economic and environmental benefits to communities, badly needed in the short-term economic recovery phase. In conclusion, we would propose this Initiative to be more strategic, as the need to mastermind an economic recovery in the months ahead gives us more motivation than ever to ambitiously and enthusiastically address energy waste and a better indoor environment quality in our buildings. The partners of the Renovate Europe Campaign are ready to help in this great challenge of our times.
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Meeting with Kadri Simson (Commissioner) and

23 Apr 2020 · How building renovation can contribute to post covid-19 recovery, how to get renovation projects off the ground, how to remove regulatory obstacles and improve advice.

Response to 2030 Climate Target Plan

15 Apr 2020

EuroACE welcomes the work started by the European Commission to revise the 2030 target for GHG emissions reduction. This work should lead to an alignment of the 2030 target with our longer-term objectives, i.e. reaching climate neutrality by 2050 in order to respect our commitments to the Paris Agreement. Therefore, EuroACE believes that the 2030 target should be to reduce GHG emissions by 55% at least, compared to 1990 levels. The decade between 2021 and 2030 will be decisive in order to accelerate action and put the EU on track towards carbon neutrality by 2050. Therefore, a higher 2030 target is needed, not only to give industry and investors a clear indication where to go, and give them first-mover competitive advantage, but also to make the trajectory between 2030 and 2050 easier to achieve. We know from the experience of the EU energy & climate policies over the past years that the target trio approach (GHG, energy efficiency, and renewables) is key to achieve our decarbonisation objectives – it is crucial to keep it for the years ahead. The IA should also make clear that an increased GHG emissions reduction target implies an increase of the 2030 energy targets, i.e. energy efficiency and RES. The IA for the 2030 GHG target should also consider the Energy Efficiency First principle. Energy efficiency holds the biggest potential in helping the EU to achieve climate neutrality by 2050, as we know this principally means reducing emissions to close to zero. According to the International Energy Agency, 75% of additional investments to cut GHG emissions in Europe to respect the Paris Agreement will have to come from energy efficiency. It is estimated that the bottom-up potential for the energy efficiency target lies at 40% by 2030. More particularly, the buildings sector has the biggest potential in terms of efficiency gains, equating to half of the decarbonisation measures needed to achieve our Paris Agreement goal. Swift, strong and sustainable actions in energy efficient renovations will be crucial to attain a higher GHG emissions reduction target by 2030, as buildings represent 36% of the EU GHG emissions and 40% of its energy consumption. In the analysis supporting the Communication ‘A Clean Planet for All’, although only two (out of eight) scenarios were compatible with the objective of climate neutrality by 2050, reduction of energy consumption in buildings was also recognised as the policy delivering most of GHG emissions reduction in all scenarios. And with technologies available today, it is possible to reduce the energy consumption of buildings by 80% by 2050 compared to 2005. Keeping a focus on the long-term (2030 target and 2050 objective) should also lead to better short-term decisions (i.e. prioritising building renovation measures) that will be needed to underwrite economic recovery in current circumstances. EuroACE therefore welcomes that the Commission will reflect in the IA on what an increased climate target means for different sectors of the economy, and how this increased ambition needs to be translated into revised energy legislation, to be proposed by June 2021 (such as the Energy Efficiency Directive). The revision of the Energy Performance of Buildings Directive might also need to be considered at a later stage in 2021 as part of a gap filler package. As regards the extension of the ETS to emissions from buildings, EuroACE believes that it is not the most appropriate tool if the objective is to renovate buildings to be highly energy performing, delivering benefits to occupants and creating jobs in the construction sector. Finally, the IA for the 2030 climate target should focus on calculating and taking into account the (monetised) multiple benefits stemming from increased ambition. For energy efficiency, notably in the buildings sector, this could for example be the jobs created, public finances saved on unemployment schemes or healthcare payments, deaths prevented thanks to improved air quality.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

The ETD, which was published in 2003, is out of date and does not reflect at all the current ambition of EU energy & climate policies. EuroACE therefore welcomes the Commission proposal to update it in line with the Green Deal objectives. Moreover, the ETD does not reflect the decreased technology costs in a lot of sectors, such as energy efficient buildings – this should also be considered. Finally, we welcome the proposal to review the ETD using Article 192 TFEU as a legal basis, which would enable the discussions to take place in the framework of the ordinary legislative procedure, giving the European Parliament and Council equal footing. EuroACE believes that inequalities of treatment which are currently stemming from the implementation of the ETD, whether between supply side measures and demand side measures, or between different energy carriers, should be corrected. This would enable the rollout of the Renovation Wave based on fair and cost-effective measures. This means that the ETD should ensure a level playing field by reflecting and operationalising the Energy Efficiency First principle (definition in the Governance Regulation Article 2§17a). We think that taxation measures should incentivise and reward saving energy, not consuming more energy. The ETD revision could also serve as enabler of more investments and real actions into energy efficient building construction and renovation. As for the revenues stemming from the EU Emissions Trading Scheme, revenues coming from energy taxation should be targeted specifically at measures which serve the purpose of the Green Deal, and notably, to reduce our energy consumption. Therefore, we believe that the ETD should include provisions on revenue recycling and prioritise sectors such as energy renovation of buildings. Directing those revenues to the buildings sector would also help to correct or at least compensate the distributional effect of the energy taxes, which constitute a big part of energy bills. We also know that often, it is the households suffering from energy poverty (paying a proportionally higher part of their income on energy bills) who live in the worst performing segment of our building stock. Boosting the energy performance of those buildings would also enable to improve health and comfort of occupants, and therefore, reduce healthcare system costs. The ETD should also effectively deliver actions in energy efficiency, and not serve as basis for accounting tricks by Member States. National energy taxes are an instrument that can complement energy efficiency support schemes and regulatory actions. It can make investments in energy efficiency improvements more attractive and steer energy use behaviour in the right direction, if energy users are enabled to act. However, pricing signals alone are not an appropriate tool to overcome market barriers, mainly because the price elasticity of energy demand is very low, and most barriers are non-economic barriers. Specific support schemes and regulatory measures remain key in order to create demand for energy efficiency investments. Funding streams made available in that framework should be effective and reward compliance with expected savings. However, several Member States are using the weakness of the ETD, namely the low EU level of minimum taxes, in an accounting practice that undermines the goals of the Energy Efficiency Directive (EED). For the purpose of achieving their energy saving obligation under EED Article 7, they report energy taxes, even though the effectiveness and eligibility of those taxes to save energy is not demonstrated. Member States simply calculate the difference between the minimum EU tax level and the national tax and credit this difference as “additional” savings. Therefore, we call on the Commission to address this issue in the ETD revision, in conjunction with the EED revision planned in 2021, and to explore how increasing the minimum EU tax level could help address this loophole.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

EuroACE welcomes the proposal for a Just Transition Fund, recognising that some areas in the EU are more in need than others. However, considering the level of actions needed, we cannot consider €7.5bn/€7.8bn of additional money over the next MFF period (2021-2030) as enough to match with our ambition. To reach the 2030 energy efficiency target of 32.5%, investments in the decade 2021-2030 need to be at around €280bn every year. We reckon that the Just Transition Fund is only part of the picture, and that most investments will have to come from the private sector, but the proposed amount is still very low, if our aim is to help those territories and populations most in need to get on a path towards climate neutrality by 2050. We are calling the Commission and the two co-legislators to match the spending volume with the legislative ambition. For EuroACE, investing for the European Green Deal means investing in people. In the energy efficiency sector, technologies are already available to considerably reduce our energy consumption. In the building sector, we can easily decrease the energy consumption by 80% at least by 2050, compared to 2005. What is needed now, is to scale up quality existing programmes and replicate them in the territories which are most in need. The JTF should be about re-skilling, creating local quality jobs as well as providing citizens with comfortable homes, so that they can live in a healthy environment where the air is clean. We shouldn’t forget that on average, Europeans spend 21-22 hours a day inside a building. All these benefits are clearly stemming from energy renovation of buildings, which could also be the basis of wider urban regeneration or economic diversification programmes. Therefore, we welcome the inclusion in the JTF Regulation Article 4 of investments in technical assistance as well as in energy efficiency, but this should be more specific. We believe that investments in energy renovation of residential and commercial buildings should be explicitly included in the scope of eligible investments. We notice that the pillar 3 of the Just Transition Mechanism mentions investments in energy efficiency, including building renovation. But this pillar 3 would only apply to public buildings, which is a tiny proportion of the building stock in the EU. Therefore, the JTF, which is the pillar 2 of the Just Transition Mechanism, should specify that energy renovation of private residential and commercial buildings is an eligible investment, to benefit a wide range of the European population. Swift, strong and sustainable actions in energy efficient renovations will be key to attain climate neutrality by 2050, as buildings represent 36% of the EU GHG emissions, 40% of its energy consumption and 50% of all extracted material. The buildings sector is the biggest contributor to reaching climate neutrality, even more in CEE countries which will benefit greatly from the Just Transition Mechanism. A strong governance framework is needed to ensure that the Territorial Just Transition Plans (TJTP), which are drawn as a basis to get funding from the JTF, should be thoroughly drafted, assessed and implemented. It is crucial that Member States don’t end up drawing TJTP which are merely recycled strategies on paper, or not more than a tick-the-box exercise. Local and regional stakeholders should be involved in the drafting process and regularly consulted on the TJTP – its development, approval, and implementation. First, those TJTP should be fully in line with the NECP but also the Long-Term Renovation Strategy (LTRS), developed as required by the Energy Performance of Buildings Directive (EPBD). The LTRS, which were due by 10th March, should already outline in every Member States, the segments and areas of the building stock which are the worst performing. This should facilitate identification of key measures of the TJTP. Additional feedback is available in our attached Position Paper.
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Response to Climate Law

5 Feb 2020

Achieving climate neutrality by 2050 is of utmost importance if we are to respect our Paris Agreement commitments. EuroACE fully supports this objective and agrees that enshrining it into law, transforming it from a vision to an EU binding target, which all MS endorse, is key for achieving it. We know by experience that targets which are non-binding, such as the energy efficiency (EE) target, do not have the same political strength. This leads to sub-optimal implementation and therefore, missed benefits on the ground. Having a clear, legally enforceable objective, would give investors and industry the necessary confidence and therefore, would be a market booster. Having a legally binding target enables policymakers and stakeholders to rally behind, and to then devise, adopt and implement concrete measures to achieve it. As for the format of the Climate Law (CL), we would welcome a Regulation, which has the advantage of being directly applicable in MS, without transposition. The CL should also consider how it could be integrated in the GOV process and how NECPs should be updated to reach this goal. It is important that progress towards climate neutrality by 2050 is regularly reported, monitored, and reviewed. Enshrining climate neutrality by 2050 into law, should be the basis to align all EU funding, notably MFF, Taxonomy and EIB lending, towards that objective. It would also facilitate mobilisation of private investments. EE holds biggest potential in helping the EU to achieve climate neutrality by 2050. According to the IEA, 75% of additional investments to cut GHG emissions in Europe to respect the Paris Agreement will have to come from EE. Consequently, the EE First principle should be clearly set out in the CL, based on its legally agreed definition (GOV Article 2§17a). The CL should also recall that the EU energy & climate policies are based on a successful target trio approach (GHG emissions reduction, EE & RES). In that framework, EuroACE would welcome the inclusion in the CL of clear pathways, i.e. intermediate binding targets for 2030 and 2040. This would mean at least -55% GHG emissions reduction and 40% EE by 2030. In the buildings sector, there are already such ‘indicative milestones’ for 2030 and 2040, as included in the national LTRS. The buildings sector has the biggest potential in terms of efficiency gains, equating to half of the decarbonisation measures needed to achieve our Paris Agreement goal. Swift, strong and sustainable actions in energy efficient renovations will be key to attain climate neutrality by 2050, as buildings represent 36% of the EU GHG emissions, 40% of its energy consumption and 50% of all extracted material. With the upcoming Circular Economy Action Plan, the buildings sector will undoubtedly be even more the biggest contributor to reaching climate neutrality. The CL should also recall that the buildings sector is the only one having a 2050 objective in line with climate neutrality (EPBD Article 2A). Moreover, energy renovation of buildings helps delivering other benefits, which makes it particularly relevant in the framework of the EU Green Deal which wants to be socially fair and providing opportunities for both European businesses and citizens. The Commission indicates in the roadmap that an impact assessment is not required for the CL, as it will use the full analysis made in November 2018 in the framework of the preparations for the Communication ‘A Clean Planet for All’. We would like to recall that in this work, although only two (out of eight) scenarios were compatible with the Paris Agreement ambition, i.e. climate neutrality by 2050, reduction of energy consumption in buildings was recognised as the policy delivering most of GHG emissions reduction in all scenarios. It was also found that building renovation rate needed to be at 3% annually to deliver the savings required , but the modelling only used rates between 1.3 to 1.8% in the various scenarios, which is inconsistent
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Meeting with Dominique Ristori (Director-General Energy)

3 Nov 2017 · Clean Energy package

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

18 Sept 2017 · Energy Efficiency

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

14 Oct 2016 · Energy efficiency in buildings

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

6 Oct 2016 · EBPD/ENERGY EFFICIENCY PACKAGE

Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

3 Oct 2016 · Discussion on energy efficiency measures in the context of new Energy policy package

Meeting with Arunas Ribokas (Cabinet of Commissioner Vytenis Andriukaitis)

26 Sept 2016 · Commission energy efficiency package

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

22 Sept 2016 · Energy Efficiency

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

16 Jun 2015 · Energy Union

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

25 Feb 2015 · TTIP; Energy Union

Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

18 Feb 2015 · Energy Union

Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager)

17 Feb 2015 · Introduction to EuroACE

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

17 Feb 2015 · Meeting with EuroAce on Energy Union