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Equilibre des Energies

EdEn

Equilibre des Energies is a cross-sectoral association gathering companies from energy, building and mobility sectors involved in EU energy and climate policy.

Lobbying Activity

Meeting with Bruno Tobback (Member of the European Parliament)

23 Oct 2025 · Upcoming Grids Package

Meeting with András Gyürk (Member of the European Parliament)

22 Oct 2025 · Electricity grids

Equilibre des Energies urges EU to prioritize electrification in heating

9 Oct 2025
Topic — A consultation on accelerating the decarbonisation of European heating and cooling systems.
Message — EdEn advocates for replacing energy efficiency goals with an emissions reduction first policy framework. They request a mandatory ban on new fossil fuel boilers by the year 2035. They also suggest using carbon revenues to subsidize consumer purchases of electric appliances.123
Why — Removing primary energy metrics would increase market demand for the organization's electrical technologies.4
Impact — Fossil fuel providers and gas boiler manufacturers would see their market share disappear sooner.5
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Equilibre des Energies urges EU to adopt an Electrification Act

9 Oct 2025
Topic — The consultation addresses barriers to promoting electrification across the European Union's energy demand.
Message — EdEn recommends an Electrification Act to set targets and treat nuclear like renewables. They also suggest prioritizing European manufacturers for infrastructure and reforming grid connection rules.123
Why — These proposals would guarantee profitability and create a protected market for European energy companies.45
Impact — Fossil fuel suppliers and international equipment competitors would face higher taxes and market exclusion.67
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Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

25 Sept 2025 · Obstacles and avenues for EU electrification

Equilibre des Energies urges mandatory EU electrification targets

16 Sept 2025
Topic — Amending the European Climate Law to establish a 2040 emissions target.
Message — The association proposes a mandatory electrification target and technology neutrality for low-carbon sources like nuclear. They also request using international carbon credits and supporting carbon capture deployment.123
Why — These measures would increase market demand for their members' electricity and low-carbon technologies.4
Impact — Environmental advocates lose as international credits reduce the need for direct domestic emission cuts.5
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Response to Legislative initiative on CO2 transportation infrastructure and markets

11 Sept 2025

EdEn believes CO2 capture and storage will be needed to offset residual emissions from hard-to-abate industrial sectors. Industrial carbon removals from biogenic and possibly from atmospheric sources will also be an essential component in the manufacture of chemicals, plastic products and synthetic fuels. Yet, the targets set by the Commission for 2040 and 2050 appear very ambitious, especially for carbon removal targets, but also for CCS, as very few FIDs on capture projects or storage projects have been taken so far within EU 27. Setting up an appropriate regulatory framework will be crucial. At this stage of CCS and CCU development, EdEn recommends that the emphasis be equally put on four policy avenues for scaling up their deployment: 1. Accelerating the development of the technologies needed to capture, transport, store and use CO2 The CEF and the Innovation Fund already contribute to technological progress in carbon management. However, the highly complex application process for the Innovation Fund hampers its potential contribution to the deployment of projects. This complexity should be addressed by the Industrial Decarbonisation Accelerator Act, as announced in the Clean Industrial Deal, which will be aimed at tackling permitting bottlenecks and at accelerating the roll-out of clean energy technologies. 2. Facilitating the cross-border transport of CO2 Currently, the cross-border transport of CO2 for sub-seabed storage is regulated under the London Protocol (LP) which prohibits the export of waste (article 6). In 2019, LP Parties adopted a resolution allowing two or more countries to agree to export CO2 for geological storage. But this process will become increasingly burdensome as cross-border CO2 transport will develop. In order to enable a smooth process, the EU should adopt a framework, compliant with LP Protocol, to facilitate CO2 transport across Member States for the purpose of storage in sub-seabed geological formations. 3. Supporting a viable business model for the industrial deployment of CCS and CCU projects Carbon management technologies and in particular the technologies for the removal and use of biogenic carbon, are a long way from achieving economic balance, especially with the price of CO2 on the ETS market back at around 70/t. This price level is about only half of what it should be for carbon management technologies to be a viable option for companies to invest in. To fill the gap, a CCfD (Carbon Contract for Difference) mechanism at European level should be considered, based on similar grounds as the Hydrogen Bank. This process could be referred to as Carbon Bank or included in the scope of the Industrial Decarbonisation Bank as proposed in the Clean Industrial Deal. Such a funding mechanism could be financed by either EU ETS revenues or structured through a fund with more stable financial resources, on the example of Japan. As regards permanent carbon removals, EdEn welcomes the publication of the regulation 2014/3012 «Establishing a European Union certification framework for carbon removals». However, in order for carbon removal activities to attract economic players, the European Commission should ensure that certification processes are streamlined and can be easily navigated by businesses. 4. Ensuring consistency in the planning and risk sharing of the different elements composing the CCS value chain (capture, transport and storage) One of the main impediments to develop the CCS value chain, beyond the current lack of economic viability without public support, is the lack of coordination and planification. The risk as across the value chain are numerous (completion, commercial, standard, liability sharing etc) and these can only be mitigated through enhanced coordination and planification. This is sometimes done at national level with public entities looking at alignment between the various actors of the value chain and this model should be extended, possibly at the EU level.
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Equilibre des Energies supports electric mandate for large fleets

8 Sept 2025
Topic — This consultation aims to accelerate the transition to zero-emission corporate vehicle fleets.
Message — EdEn recommends a minimum threshold of 50 vehicles and focuses on electric deployment. They advocate for financial incentives and using ETS2 revenues to fund charging infrastructure.123
Why — Earmarked funds and subsidies would lower the high costs of vehicle acquisition.4
Impact — The hydrogen and synthetic fuel sectors face exclusion from primary deployment support.5
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EdEn Urges 50% EU Autonomy in Alternative Fuel Production

4 Sept 2025
Topic — The initiative provides a strategic framework for investments in renewable and low-carbon fuels.
Message — EdEn recommends setting a 50% autonomy target for alternative fuel production. They propose earmarking half of ETS revenues to bridge the price gap. They also advocate prioritising biomass for aviation and maritime sectors over buildings.123
Why — New funding and prioritised resources would lower investment risks for fuel producers.45
Impact — The building sector faces restricted biomass availability due to new transport priorities.6
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EdEn Urges Faster Grid Expansion and Distribution Funding

4 Aug 2025
Topic — Proposal to modernize and expand European energy infrastructure for a more resilient system.
Message — Synchronize grid expansion with electricity generation and improve funding access for distribution operators. Replace 'first come, first served' connection rules with maturity criteria to prioritize viable projects. Streamline permitting and standardize equipment to lower costs and accelerate deployment.123
Why — Access to European funds would reduce investment burdens while streamlined rules speed up projects.45
Impact — Speculative developers may lose grid priority under new project maturity and capacity rules.6
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Response to EU industrial maritime strategy

28 Jul 2025

EdEn welcomes the European Commissions public consultation in view of an EU Industrial Maritime Strategy. EdEn believes that the energy transition represents a strategic opportunity to revitalise and future-proof the maritime sector, provided that financial, technological, and market-related barriers to clean technologies are effectively addressed. In our response, EdEn presents recommendations to strengthen Europes industrial and technological base in the waterborne sector, and to accelerate the uptake of clean maritime solutionswith a particular focus on the deployment of alternative fuels for ships and the widespread implementation of Onshore Power Supply (OPS) systems: 1. Achieving strategic autonomy in the production of alternative fuels for waterborne transport The maritime sector faces significant challenges in reducing greenhouse gas emissions while maintaining its competitiveness, particularly against non-EU counterparts. Achieving decarbonisation will demand substantial investment in new infrastructure, next-generation vessels, and the large-scale production of low-carbon fuels and clean electricity. The scale of this investment will be closely tied to the level of strategic autonomy Europe seeks in producing alternative maritime fuels. To reach this autonomy, a number of critical barriers must first be addressed: Lack of fit-for-purpose financing instruments. Higher prices for alternative fuels is a significant disincentive to the uptake of alternative fuels. Financial support to bridge the green premium gap between conventional marine fuels and alternative fuels should be implemented. EdEn recommends earmarking maritime ETS revenues, revising the EU-ETS system so as to allocate 50% of the revenues from the maritime ETS towards the production of alternative fuels. It could also take the form of contracts for difference or fuel price incentives. No clear earmarking of biomass feedstocks towards the production of alternative fuels. Biomass feedstock is the main challenge for the production of marine and aviation biofuels as resources are limited in Europe. In order to cover the needs of these sectors, it will be necessary that a significant portion of the available biomass is directed to maritime transport, which implies that maritime transport should be given priority for its use over other sectors for which other decarbonation solutions are available. Lack of an industrial strategy for the production of alternative fuels in Europe. The EU currently does not have a clear vision of the level of autonomy it intends on reaching as regards the production of alternative fuels. Political focus also seems to prioritise the production of e-fuels vis-à-vis the production of biofuels which risks hindering the EUs production potential. EdEn recommends adopting a technology neutral approach promoting the production of both e-fuels and biofuels. As regards the production of biofuels, synergies with the heavy-duty road transport should be explored as part of the EUs industrial strategy. 2. Addressing port electrification bottlenecks Widespread deployment of Onshore Power Supply (OPS) systems is critical to achieving the European Unions climate and energy targets. As mandated by the FuelEU Maritime Regulation and the Alternative Fuels Infrastructure Regulation (AFIR), ships at berth will be required to use OPS or other zero-emission technologies from 1 January 2030 in ports covered by AFIR Article 9, and across all EU ports by 1 January 2035. To meet these ambitious timelines, it is essential to remove key barriers currently hindering OPS deployment: Addressing financial constraints associated with the deployment of OPS infrastructure. EdEn advocates for the adoption of supportive electricity pricing mechanisms and taxation regimes that improve the economic viability and competitiveness of OPS for both ports and ship operators. Ensuring adequate infrastructure and capacity planning.
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EdEn urges EU to turn ports into clean energy hubs

28 Jul 2025
Topic — The EU Ports Strategy aims to address challenges in security, competitiveness, and energy transition.
Message — The organization calls for turning ports into clean energy hubs by accelerating infrastructure and generation. They advocate for supportive electricity pricing and tax regimes to improve the viability of onshore power. Additionally, they request harmonized standards to ensure a reliable network for alternative fuels.123
Why — Supportive pricing and taxation would lower the financial burden of required green upgrades.45
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EdEn urges EU to prioritize electrification and industrial subsidies

8 Jul 2025
Topic — The consultation focuses on legislative support for European industrial decarbonisation and competitiveness.
Message — EdEn recommends prioritising electrification and removing regulatory barriers in environmental directives. They also call for financial support through subsidies and a European Carbon Bank.123
Why — The proposed changes would lower operational costs and accelerate project approvals for European energy companies.45
Impact — Environmental protections may be weakened as permitting thresholds rise and habitat regulations are bypassed.678
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EdEn urges EU to earmark carbon revenues for alternative fuels

8 Jul 2025
Topic — Review of the EU emissions trading system for maritime, aviation, and stationary installations.
Message — EdEn recommends that the EU "allocate 50% of the revenues" to support alternative fuels. They seek to "place low-carbon e-fuels and renewable e-fuels on an equal footing" regarding subsidies.123
Why — This would subsidize expensive fuel transitions and reduce their administrative reporting burdens.45
Impact — Renewable fuel producers lose their current funding advantage over cheaper low-carbon competitors.6
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Meeting with Bruno Tobback (Member of the European Parliament)

2 Jul 2025 · Carbon Management

Meeting with Christophe Grudler (Member of the European Parliament)

26 Mar 2025 · Politique énergétique et industrielle européenne

Meeting with Radan Kanev (Member of the European Parliament)

26 Mar 2025 · Building a clean and competitive industry in Europe

Meeting with Brigitte Van Den Berg (Member of the European Parliament)

6 Feb 2025 · Clean Industrial Deal

EdEn demands transparent pricing and equal subsidies for aviation fuels

6 Jan 2025
Topic — New rules for calculating price differences between sustainable aviation fuels and kerosene.
Message — The organization recommends that the methodology used to define the price of sustainable fuels be made public. They also call for ensuring a level-playing field between synthetic aviation fuels and low-carbon variants regarding allowance allocations.12
Why — This would allow their members to secure higher subsidies by accounting for actual logistics and certification costs.34
Impact — The environment and air transport decarbonisation suffer if low-carbon fuel production becomes uncompetitive.5
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EdEn Pushes for Faster Recognition of Nuclear Power

25 Oct 2024
Topic — The consultation defines how to calculate greenhouse gas savings for low-carbon fuels.
Message — The group requests immediate inclusion of nuclear electricity connections and power purchase agreements in the fuel methodology. They also demand updating nuclear emission factors to reflect technological progress and more recent national data.123
Why — These changes would ensure their nuclear-derived fuels meet emission thresholds and secure financial support.45
Impact — Competitors may face market distortions if safeguards against unfair state aid for nuclear are removed.6
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Meeting with Nathalie Loiseau (Member of the European Parliament)

22 Mar 2024 · Souveraineté énergétique

Equilibre des Energies urges expansion of EU carbon management

30 Aug 2023
Topic — The EU is assessing measures to optimize carbon capture and storage deployment.
Message — EdEn recommends including CO2 transport and utilization in carbon management strategies. They ask for clarification that capture, transport, and storage can be treated as separate green projects. They also seek a framework to simplify cross-border CO2 transport.123
Why — Industry members would enjoy lower operational costs and greater flexibility for green investments.45
Impact — Environmental protection groups may lose safeguards as industrial waste export rules are simplified.67
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EdEn urges EU industrial plan to boost heat pump sector

26 May 2023
Topic — The consultation seeks feedback on an action plan to accelerate heat pump deployment across Europe.
Message — EdEn recommends implementing an industrial plan through an IPCEI to support research for collective housing models. They urge relocating the entire value chain to Europe to reduce industrial dependencies. Additionally, they call for realistic F-gas phase-out timelines and support for installer training.1234
Why — This would help European manufacturers reclaim market share and reduce reliance on foreign components.56
Impact — Non-EU suppliers, notably Chinese firms, would lose dominance as Europe shifts toward domestic manufacturing.7
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EdEn Urges Inclusion of Medium Voltage Equipment in EU Taxonomy

3 May 2023
Topic — This consultation establishes classification criteria for environmentally sustainable economic activities across various sectors.
Message — EdEn requests restoring medium voltage equipment to the taxonomy and granting more time for chemical reporting. They also suggest including emergency aircraft and data center efficiency technologies.123
Why — These changes would enable members to secure more sustainable financing for their specific technologies.4
Impact — Industrial companies and green investors lose clarity due to uncoordinated chemical bans and inconsistent reporting.567
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Equilibre des Energies Urges Realistic EU Taxonomy Technical Criteria

3 May 2023
Topic — Classification of sustainable economic activities contributing to European Union environmental goals.
Message — The organization requests the explicit inclusion of medium voltage equipment and disaster management aircraft within the green investment framework. They also call for a three-year implementation period for chemical restrictions to allow for complex supply chain assessments.123
Why — These changes would reduce compliance burdens and ensure their technologies qualify for green funding.45
Impact — Environmental advocates lose faster protections as the association seeks to delay industrial chemical bans.6
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EdEn urges EU to permit CO2-neutral heavy-duty fuels

17 Apr 2023
Topic — The Commission is reviewing CO2 emission standards for new heavy-duty vehicles.
Message — EdEn recommends aligning heavy-duty vehicle regulations with passenger car standards. They propose a provision to register vehicles using CO2-neutral fuels after 2040.12
Why — This provides alternative decarbonization paths and incentivizes the development of e-fuels.3
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Equilibre des Energies pushes for uncapped biofuel feedstock lists

2 Jan 2023
Topic — This consultation updates the list of sustainable feedstocks for biofuel production.
Message — The organization recommends adding intermediate crops to Annex IX-A to avoid production limits. They also propose including category 3 animal fats and technical corn oil as sustainable feedstocks. They prefer a regulation over a directive to ensure uniform application across member states.123
Why — These modifications would provide investment clarity and allow companies to scale up biomethane production.45
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Response to Energy labelling requirements for local space heaters (review)

29 Jul 2022

During the Consultation Forum held on 24 June 2022 in Brussels, the Commission’s intention to bring together in a single energy label all room heaters, including electric room heaters, was confirmed. Several participants emphasized that this merger would result in: ● having all heat pumps at the top of the energy scale; ● having all electric room heaters (i.e using the Joule effect) at the bottom of the energy scale, in class G. Electric heaters would be particularly affected due to the CC primary energy conversion factor of 2.1 being applied to all systems using the Joule effect. As a result, electric radiators would only be able to reach a seasonal efficiency (etarh) of 48% (i.e. 100/ 2.1 %) at most. Because of this, electric radiators would be pulled to the bottom of the G label, well below the 75% upper limit proposed for this class. The advanced functionalities that the latest generation of electric radiators offer (such as precise regulation, drift limitation, presence detection, open window detection, programmability, controllability, auto-programming, etc.) would not be taken into account, despite having a significant impact on consumption and bringing up to 30% in energy savings. In addition, the labelling that is proposed would not “allow customers to identify products that are energy smart, that is to say, capable of automatically changing and optimising their consumption patterns in response to external stimuli” as is provided in Regulation 2017/1369. On the other hand, gas devices could reach up to class E depending on their performance, which appears totally contradictory to the EU’s strategy as regards reducing its dependence on gas and bringing CO2 emissions to zero. The Commission’s proposal is therefore not acceptable as is. EdEn considered three options that could make it possible to include electric heaters in an energy label while taking into account their specific functionalities and added-value. EdEn concludes that the third one, based on final energy efficiency, is the only one which can fulfill all the requirements.
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EdEn warns F-gas rules could stall European heat pump deployment

29 Jun 2022
Topic — The EU is revising regulations on fluorinated greenhouse gases to align with climate goals.
Message — EdEn recommends exempting heat pumps from the quota system to support decarbonization. They claim switching to propane refrigerants requires a fifteen-year transition period for safety.12
Why — This allows manufacturers to avoid immediate compliance costs and maintain current production.34
Impact — Environmental groups lose as high-warming chemicals remain in circulation for longer periods.56
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Meeting with Karima Delli (Member of the European Parliament)

16 May 2022 · clean energy

Response to Ecodesign requirements for local space heaters (review)

18 Feb 2022

Dear Ms Juul-Jørgensen, The undersigned associations, representing the European heating appliance manufacturing sectors and their installers, support the EU energy labelling policies and agree with the need to keep this legislation up-to-date and in line with the latest technological developments. Energy labelling is a tool that has delivered considerable energy efficiency savings across Europe by assisting consumers in selecting the most environmentally friendly products. It has also proven to be an effective tool to push the industry to produce more efficient products. As such, we welcome the publication of the report on the study concerning consumer understanding of the energy label for local space heaters (LSH) and air-to-air heat pumps.1 Based on this report, the Commission is evaluating the possibility of merging the energy labels for ≤ 12 kW air-to-air heat pumps (ENER Lot 10) and ≤ 50 kW LSH (ENER Lot 20), in an attempt to remove end-user confusion about which product type is more energy consuming on the basis of the energy label classes alone. Nonetheless, we have strong concerns regarding the option to merge the energy labelling classes for both product groups, as merging the energy labelling classes will not contribute to meeting the energy labelling’s objectives. In this letter, we explain that 1) LSH and air-to-air heat pumps are not comparable, 2) merging different energy labels will not help improving the effectiveness of the energy label, and that 3) the consumer study itself does not univocally support the merger of the energy labelling scales.
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Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

2 Feb 2022

La Commission européenne envisage la fusion des étiquettes énergétiques des dispositifs de chauffage décentralisés (produits du Lot 20) et des pompes-à-chaleur air-air (produits du Lot 10). À contrario, Équilibre des Énergies considère que ces deux lots doivent garder des étiquettes différenciées afin d’orienter les industriels et les consommateurs vers les solutions les plus pertinentes selon les contraintes architecturales des logements. En effet : • Les dispositifs de chauffage décentralisés et les pompes-à-chaleur air-air local sont deux dispositifs dont les fonctionnalités – bien qu’elles présentent des points communs – sont différentes et pour lesquels des critères de performance différenciés sont utilisés ; • Séparer les étiquettes est nécessaire afin d’exploiter la flexibilité et l’intelligence des émetteurs de chauffage décentralisés, deux qualités essentielles pour la mise en œuvre d’un système énergétique flexible et adapté au déploiement des énergies renouvelables; • Regrouper les deux étiquettes énergétiques en une seule aboutirait à dégrader la qualité des informations fournies au consommateur, compliquant ainsi la prise de décision d’achat éclairée ; • Une étiquette énergétique commune découragerait l’investissement et l’innovation en rendant impossible pour tous les dispositifs de chauffage décentralisés d’atteindre les catégories les plus élevées de cette nouvelle étiquette. Pour ces raisons, Équilibre des Énergies invite les pouvoirs publics à se mobiliser afin que la future législation – conformément aux dispositions des Règlements (EU) 2017/1369 et (EU) 2015/1186 – maintienne les pompes-à-chaleur air-air et les dispositifs de chauffage décentralisés sur des étiquettes énergétiques distinctes.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

5 Nov 2021

With energy efficiency and nuclear energy, renewables are crucial for achieving the transition to a carbon-neutral economy in the EU. For this reason, their development should be an important goal of the Fit for 55 package, and EdEn welcomes the proposal published by the Commission in July to revise the RED. However, EdEn would like to raise three concerns regarding this proposal: ➢ the proposal should ensure complementarity between the use of renewables and of low-carbon energies, which will also play a crucial part in reaching climate neutrality; ➢ all resources of renewable origin that meet sustainability criteria and that can be produced at an acceptable cost should be taken into account; ➢ sectors in which renewables can bring the most added value in terms of decarbonisation and in terms of cost-efficiency should be prioritised.
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Response to Review of Directive 2012/27/EU on energy efficiency

5 Nov 2021

Improving energy efficiency is a key part of achieving the EU's climate objectives for 2030 and 2050, which is why EdEn supports the European Commission's proposal to recast the Energy Efficiency Directive (EED). Nevertheless, EdEn recommends amending the draft proposal on two aspects in order to reflect the priority that should be given to GHG emission reduction as the ultimate goal of the Union’s energy and climate strategy. In this perspective, EdEn recommends: • integrating a climate performance dimension along with the energy efficiency dimension in the proposal; • focusing energy efficiency objectives on improving energy intensity rather than on reducing energy consumption in absolute value.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

4 Nov 2021

Substituting fossil kerosene for Sustainable Aviation Fuels (SAF) can lead to significant GHG emission reductions in the relatively short term but the development of SAF is hampered by several obstacles: • Insufficient maturity in terms of industrial development, lack of investment in production and improvements needed in process efficiency and SAF competitiveness; • limited availability of resources; • Uncertainty in the evolution of the EU-ETS and its upcoming combination with CORSIA; • Competitiveness issues for European air transport systems. These obstacles make it difficult for a competitive market to emerge without adequate support from regulation. In its position paper (attached), EdEn identifies the guiding principles and legislative solutions that should be implemented in order to: 1. Achieve adequate levels of SAF production; 2. Support the competitiveness of European air transport systems; 3. Ensure a smooth distribution of SAF.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

In the context of the Green Deal, the European Commission has announced that the EU would soon be raising its carbon emission reduction target for 2030 from 40% to at least 55% in view of achieving climate neutrality in 2050. With the building sector accounting for approximately 36% of CO2 emissions in the EU, the upcoming revision of the Energy Performance of Buildings Directive (EPBD) has a strong role to play in making it possible for the EU to reach its targets. In order for the revision of the EPBD to effectively improve the quality of the European building stock and to deliver the intended environmental and economic benefits, EdEn has put forward a set of recommendations targeted towards the following objectives: • Improving GHG-efficiency in the European building stock; • Promoting efficient renovation and the roll-out of modern heating solutions and e-mobility equipment; • Phasing out fossil fuels heating.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

EdEn welcomes the Commission’s proposal for a Regulation on batteries and waste batteries. We believe this proposal is an important step in reducing the environmental footprint of batteries throughout their whole life-cycle. In particular, the definition of carbon performance classes, associated with a maximum emission threshold appears to be an effective way of avoiding the placing on the market of non-sustainable batteries while making it possible to differentiate, among the batteries that can be placed on the market, the ones that have the lowest carbon footprint. We believe however that some other provisions need to be further assessed in order to take into account existing legislation and the diversity of battery technologies and applications. 1. Avoiding duplication of existing processes 2. Taking into account the specificities of each battery technology and application 3. Addressing availability issues and competition issues related to recycled content requirements 4. Carbon footprint of electric vehicle batteries
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

EdEn supports the Sustainable Finance initiative and the principles behind the Taxonomy framework proposal as the Taxonomy can be used to prioritise and accelerate investments towards decarbonised energy production and low-carbon technologies. We believe however that in order for the Taxonomy framework to contribute to the climate neutrality objective at its full potential, the following aspects of the draft regulation and annexes need to be improved: 1 - Creating a level playing field between decarbonised energy forms; 2 - Adopting a more technology neutral approach; 3 - Incentivising GHG emission reductions in the buildings sector.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

25 Nov 2020

Association EdEn believes that the Effort-Sharing Regulation (ESR) should be maintained in the sectors that are not covered by the emission trading scheme (Option 3 in the inception impact assessment). We also believe the ESR should introduce a sectoral domestic emission reductions target in the buildings sector. Why is a sectoral domestic emission reductions target in the buildings sector necessary? The building sector is responsible for 36% of the EU’s GHG emissions, which makes it the second heaviest emitter behind the transport sector. Contrary to the transport sector, which is subjected to strict sectoral regulations for GHG emission reduction (such as the Regulation on CO2 emission performance standards for new passenger cars and for new light commercial vehicles), the buildings sector is not subjected to any such regulation. As a consequence, GHG emissions from the building sector are not decreasing as fast as they could and should, which in turns delays the EU’s transition towards climate neutrality. How would a sectoral domestic emission reductions target in the buildings sector work? The setting of sectoral domestic emission reductions targets would follow the same rules as the current economy-wide domestic emission reductions target but it would also take into account national geographic and climatic data. Higher income Member States would take on more ambitious targets than lower income Member States and cost-effectiveness would also be taken into consideration. For each Member State the target would be derived from a linear reduction trajectory drawn from the average 2018-2020 domestic emissions related to the building sector. Why are these sectoral domestic emission reductions targets a better option than an EU-ETS extension? The EU-ETS system is a purely economic system based on the adaptation of economic actors to the price of carbon quotas. it is suitable for professional users. In the case of buildings, two-thirds of users are domestic users who on the one hand do not make economic calculations and on the other hand could react very negatively to tax increases on the price of fuels. The ESR approach makes it possible for Member States to implement the solution – or solutions – they think can be most efficient and socially acceptable in their country (regulatory, incentive, tax, etc.)
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Response to Revision of the CO2 emission standards for cars and vans

25 Nov 2020

The current text of the Regulation on CO2 emissions for cars and vans focuses on reducing tailpipe emissions as it is the source of most CO2 emissions related to internal combustion vehicles. Such a focus however has led to unintended consequences that can increase the GHG emissions related to the cars sector. In order to reduce tailpipe emissions, manufacturers are incentivised to use light-weight materials and to produce lighter vehicles.The production of these lighter materials (aluminum, magnesium, carbon fiber, glass fiber, etc) is typically GHG-intensive, which means that the tailpipe GHG emission reductions achieved can be compensated by an increase in upstream GHG-emissions, taking place in the production phase. In order to avoid this, we believe that, in addition to the existing CO2 criterion, the Commission should take the necessary steps in order to introduce the notion of carbon content for cars in the Regulation. Introducing this notion would also be consistent with the Commission’s project of introducing a carbon border adjustment in the near future.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

EdEn strongly believes, as the Commission does, that the energy efficiency legislation can play a key part in addressing both of the challenges the EU is currently facing: • Climate change - Energy efficiency requirements can lead to significant reductions in fossil fuels consumption and thus contribute to GHG-emission reductions; • Economic crisis - Energy efficiency requirements also contribute to fostering technological development and to rolling-out decarbonised and energy efficient equipment in the industry, in the buildings sector and in the transport sector. Nevertheless, EdEn would like to highlight that energy-efficiency should always be understood as a means towards an end - climate action and economic recovery - rather than as an end in itself. In order for the Energy Efficiency Directive (EED) to fully contribute to the climate neutrality objective, it is essential that a climate dimension be included in the text, which is currently not the case. Along with the inclusion of a climate dimension in the text of the EED, EdEn strongly believes that the existing provisions related to measuring energy efficiency improvements need to be based on clearer definitions. Finally, considering that the EU legislation for energy efficiency is based on two main texts: the EED and the Energy Performance of Buildings Directive (EPBD). It is crucial for these two pieces of legislation to be harmonised in order to ensure a smooth implementation of their provisions.
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Response to Sustainable and Smart Mobility Strategy

22 Jul 2020

Electrification of the transport system is the most effective way to achieve a sustainable and smart mobility system as renewable hydrogen is currently too expensive to be rolled-out on a massive scale and as gas combustion is a source of GHG-emissions. In view of electrifying the European transport system, EdEn recommends the following: 1) Rolling out charging points for electric vehicles The Alternative Fuels Infrastructure Directive requires each Member States to establish their “National Policy Frameworks” (NPFs) but provisions are not prescriptive enough which results in diverging interpretation and implementation across Member States. In order to develop a coherent infrastructure network throughout the EU, provisions need to be more prescriptive and more specific regarding the location and number of charging points that need to be installed. Additionally, EV drivers should be empowered, within certain limits, to request the deployment of charging points in uncovered areas, such as home and office. The roll-out of private charging infrastructure is essential to the development of a sound electric mobility network which is why we recommend the deployment of private charging points be included in the scope of the revised AFID. The EPBD provisions related to private charging infrastructure should also be strengthened, notably in regards to deployment of charging points in buildings owned by small and medium-sized enterprises. Additionally, we believe that energy performance certificates should include an evaluation of the charging point infrastructure of buildings. This evaluation could then lead to recommendations on possible improvements of the charging point infrastructure. Extending the scope of energy performance certificates to electric mobility infrastructure would be coherent with the inclusion of the SRI - which integrates an electric mobility dimension - in the energy performance certificate system, as proposed by the Commission. 2) Making electric mobility more consumer friendly Minimum requirements for harmonising payment methods across the EU should be pursued. Payment methods often vary across countries, with certain Member States relying heavily on cash payment and others relying on credit card payment. This inconsistency creates uncertainty for consumers. We recommend to support the development of ad-hoc payment and of credit card payment, possibly emulated by mobile phones. These solutions provide a high level of flexibility and harmonisation to a very high proportion of European consumers. Consumers need to be provided with clear, relevant and comparable information on publicly accessible charging points. The available information should include in particular (1) charging stations’ location, (2) their technical characteristics (type, power and payment methods) and (3) availability status. Pricing information must be improved, as the price displayed on charging points rarely matches the price really paid by the consumer. 3) Resolving imbalances in energy taxation In the current Energy Taxation Directive there is no link between minimum tax rates and their energy content and CO2 emissions. Thus, the minimum rate for electricity, natural gas and coal is identical despite gas and coal being CO2 emitters by nature while electricity is increasingly decarbonised. In order to develop electricity consumption and electric mobility in particular, the ETD should include a carbon-related component. In most Member States, electricity is subject to taxation when it is taken from the network to fill storage facilities and devices (such as batteries) and the same electricity is again subject to taxation when it is delivered to end-users. This double taxation hampers the development of energy storage projects and of Vehicle to Grid projects. Therefore it hampers the development of electric mobility. This double taxation should be abolished in the context of the upcoming legislative initiatives.
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Response to Modernising the EU’s batteries legislation

8 Jul 2020

In order to modernise EU rules on batteries, we recommend the following measures be integrated in the legislation: A) Introducing a strong carbon criterion in the batteries legislative framework Batteries are an essential part of the development of low-carbon mobility in the EU but if the production and use of batteries result in a high level of CO2 emissions, their entire purpose is defeated. In order for the battery industry to truly benefit the EU’s climate neutrality project it is essential that a carbon criterion be included in the new legislative framework for batteries. This carbon criterion could be implemented in various ways: • Government rebates on purchases of new zero-carbon and low-carbon vehicles could vary according to the batteries’ carbon content and therefore incentivise consumers to purchase low-carbon batteries; • Car constructors should be encouraged to buy batteries that are made in Europe. Importing batteries from third countries to Europe results in heavy CO2 emissions due to transport. This is especially true that currently the major batteries manufacturers are located in Asia. Incentivising car constructors to buy batteries locally would significantly reduce the carbon footprint of the European battery market; • The possibility of introducing a carbon border adjustment should be assessed. A carbon border adjustment would make it possible to discriminate against batteries that are manufactured in third countries with high CO2 emissions. In this perspective, the carbon content of batteries should be displayed on products that are commercialised in Europe. Batteries should be categorised according to the level (in kg) of GES per stored kilowatt-hour that has been emitted during the manufacturing process. In order for this categorisation to be implemented, a standardised scale with ratings ranging from A to G should be defined at the EU level. B) Abolishing double taxation for energy storage In most Member States, electricity is subject to taxation when it is taken from the network to fill storage facilities and devices (such as batteries) and the same electricity is again subject to taxation when it is delivered to end-users. This double taxation hampers the development of energy storage projects and it should be abolished in the context of the upcoming legislative initiatives. C) Mainstreaming battery reuse Electric vehicle batteries when they are no longer performant enough to be used in vehicles can still be of use as energy storage in private homes or in larger battery units. The current framework hampers such reuse as used batteries are considered waste. We recommend the upcoming revision address this issue and include provisions facilitating and incentivising electric vehicle batteries’ reuse. D) Reassuring buyers of used cars Being unsure of the quality of a used battery can deter consumers from buying second hand electric cars. In order to reassure them and to foster a dynamic market for second hand electric cars, it is essential that a battery quality indicator be defined at the EU level. We believe it should be made compulsory that the quality of the battery be assessed during periodic technical inspection of vehicles.
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Response to Strategy for smart sector integration

4 Jun 2020

In order to optimise sector integration, policy-makers need to agree on the main goal that is to be pursued. Decarbonisation and energy efficiency are two different goals that can be associated to some extent but not entirely. Improving energy efficiency makes it possible to reduce GHG emissions to some extent but it does not make it possible to achieve full decarbonisation. On the other hand, technologies such as carbon capture and storage and nuclear make it possible to achieve full decarbonisation but do not improve energy efficiency. In view of the Union’s climate objectives for 2030 and 2050, we believe the energy policy the EU should aim at improving energy efficiency, while still prioritising GHG-emission reductions. In this perspective, we recommend the following approach be adopted: 1. Reducing energy consumptions and improving energy efficiency a) achieving energy savings, in particular in the building sector which is the most consuming sector. In view of achieving such reductions, we believe the renovation wave strategy should encourage massive improvements in insulation in the European building stock; b) improving energy efficiency while still prioritising decarbonisation, through the use of new energy processes that are both more efficient and low-carbon, in particular through: • the roll-out of heat pumps in replacement of fossil fuel boilers; • the replacement of combustion engines by electric engines; • research and innovation in the field of electrolysers and fuel cells in order to develop hydrogen solutions; • the generalisation of waste heat recovery in the industry, possibly associated with high temperature heat pumps. 2. Increasing the share of clean energies consumption a) developing the use of decarbonised electricity in the building and transport sectors and in the industry; b) developing the use of renewable heat (solar, geothermal, biomass, renewable waste, etc.) when economically feasible. 3. developing synergies between various forms of energies and various sectors a) Hybrid solutions can be a good intermediate step towards full decarbonisation. In particular, we believe the use of the following technologies should be encouraged : • hybrid heat pumps; • hybrid rechargeable vehicles. b) Synergies between the building and the transport sector should be developed, in particular through: • facilitating the reuse of end-of-life vehicle batteries in buildings; • increasing the roll-out of charging points and of ducting infrastructure in buildings, possibly associated with the development of self-generation in buildings. 4. developing smart technologies in order to reduce peak power demand With the development of renewable energies and the progressive electrification of the European economy as planned in the Commission’s Long-term strategy, peak power management will play a crucial part in the smooth functioning of the energy system. This will in particular require the following: a) developing smart energy technologies that can be controlled by consumers and that bring flexibility to the system; b) developing energy storage: daily, multiday, and or even seasonal energy storage.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

22 May 2020

With the COVID-19 crisis having deeply shaken the European economy, the EU needs to elaborate a recovery plan that can deliver both economic and environmental benefits. EdEn truly believes that the renovation should be prioritised in the perspective of a green recovery as it can provide three key benefits: • creating jobs at the local level; • significantly reducing GHG emissions; • improving comfort and well-being for citizens. In order for the renovation wave strategy to effectively improve the quality of the European building stock and to deliver the intended environmental and economic benefits, EdEn has put forward a set of recommendations for the revision of the EPBD. These recommendations are targeted towards the following objectives: 1. Improving GHG-efficiency in the European building stock With the building sector accounting for more than a third of global European GHG emissions, it appears necessary to integrate dispositions directly targeting GHG emissions reduction in the legislative framework for buildings. In the automotive sector, decarbonisation is tackled with mandatory provisions directly targeting GHG emissions reduction while in the buildings sector, decarbonisation is only tackled indirectly with provisions targeting energy consumption reductions. We believe that this difference in approach is the reason why the automotive sector has seen positive results in GHG emissions reduction while the buildings sector has remained stagnant. We recommend that the renovation wave initiative address this shortcoming and make it mandatory to monitor both the carbon performance and the energy performance of buildings. 2. Accelerating the roll-out of modern heating solutions and e-mobility equipment While the existing framework encourages Member States to achieve a higher renovation rate of their building stock, the progression so far has been slower than what is necessary in order to phase-out inefficient heating solutions and to develop the required e-mobility infrastructure. In order to bridge this gap, we recommend to reinforce the current framework and make it more prescriptive. In this perspective, we have identified a number of provisions related to e-mobility readiness and to efficiency monitoring in buildings that we believe could be reinforced, either by making them compulsory or by reinforcing their target. 3. Unlocking new investment solutions for GHG-efficient renovation work The renovation sector is of strategic value for the EU in terms of employment, industrial activity and decarbonisation, which is why we believe it should a priority target for investment in the context of the European recovery plan. In this perspective, we have a identified a number of funds that should contribute to financing renovation schemes across Member States. Additionally, in order for this financing to support energy-efficient and GHG-efficient renovation work, we recommend that fossil-fuel equipment be excluded from receiving public subsidies as part of a renovation scheme.
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Response to Climate Law

7 Apr 2020

EdEn (Equilibre des Energies) recommends that the EU Climate Law should integrate the following provisions: - It should be specified that the trajectory mentioned in article 3 paragraph 1 is a trajectory for greenhouse gas emission reduction. It is necessary to specify that the trajectory that shall be set out is a GHG emission reduction trajectory. Otherwise, other types of trajectories that are not directly related to carbon emission reduction (increase in RES use, energy savings, investment in clean technology) could be considered ; - The trajectory as mentioned in article 3 paragraph 2 should start no later than two years after the text is adopted instead of starting from the Union's 2030 target. Emission reduction planning should start as soon as possible in order to make sure the EU reaches both its 2030 and 2050 targets. There is no reason why this planning should be delayed until 2030 ; - The principle of technological neutrality should be integrated among the principles according to which GHG emission reduction trajectories will be set out. In view of achieving our objectives for 2030 and 2050, price competitiveness and GHG performance should be the only criteria against which technologies are assessed. That is the reason why the principle of technological neutrality should be included in the core text of the regulation ; - Article 3 should make it mandatory for each Member State to set out a national trajectory to achieve the climate-neutrality objective. In order for the EU as a whole to efficiently follow a decarbonation trajectory in view of reaching both its 2030 and 2050 targets, it is necessary that Member States should set out their own national trajectories, in line with their 2030 and 2050 targets.
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Response to 2030 Climate Target Plan

30 Mar 2020

In order for the EU to reach its 2030 climate objectives, EdEn (Equilibre des Energies) recommends that the Energy Performance of Buildings Directive (EPBD) should be included in the Comprehensive Plan to be adopted in summer 2020, and in the following legislative package in 2021. This revision is necessary since the current text of the EPBD is not in line with the EU’s climate commitments as it does not include any mandatory GHG reduction provision, despite the building sector accounting for approximately 36% of GHG emissions in the EU. We call for a revision of the EPBD that would address this current shortcoming and set up a mandatory GHG emission criteria expressed in kilograms of CO2 equivalent per m2 per year (kg CO2e/m2/year) alongside the existing energy consumption criteria. This GHG emission criteria would also make it possible to impose and to monitor GHG emission reductions in the building sector. Regulation (EU) 2019/631 on passenger cars sets progressively decreasing objectives for passenger cars emissions in 2022, 2027 and 2032. We recommend that the same approach should be adopted in the building sector with each Member State being required to set progressive GHG emission reduction trajectories for their building stock by 2025, 2030 and 2035. These roadmaps should be consistent with their integrated national energy and climate plans to be notified to the Commission in accordance with Regulation (EU) 2018/1999. From a more global point of view, in the context of the coronavirus crisis, it is crucial to ensure that the economic rebound that will follow the crisis will not lead to a boom in fossil energy consumption as was the case following the 2009 crisis. We recommend that the Green Deal and the legislative initiatives that will be initiated in the coming months should encourage the economy to capitalize more extensively on low carbon electricity so that our economic activity can rebound without leading to a significant increase in fossil fuel consumption and in GHG emissions.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

2 Dec 2019 · discussion on climate and energy policy prospects